Pippins v. State

Doloretine Pippins appeals the summary denial of her Florida Rule of Criminal Procedure 3.801 motion for jail time credit. See Fla. R. Crim. P. 3.801. She argues that the trial court erred in relying on the written plea form to deny her motion in the absence of a separate provision in the agreement explicitly waiving the additional credit that she seeks. We agree and reverse.

“Jail credit may be waived, but the waiver must be specific, voluntary and clear from the face of the record.” White v. State, 995 So.2d 1172, 1173 (Fla. 4th DCA 2008). Because the written plea form in the instant case…