Padilla-Padial v. State

Angel Padilla-Padial appeals the summary denial of his pro se “Motion to Correct Illegal Sentence,” which was filed pursuant to Florida Rule of Criminal Procedure 3.800(a), and raised his alleged entitlement to additional jail credit. The trial court treated it as a Florida Rule of Criminal Procedure 3.801 motion to correct jail credit, and denied it on the merits. However, because the motion was filed during the pendency of Padilla-Padial’s direct appeal of his judgment and sentence (case number 5D13-3356),1 the trial court lacked jurisdiction to rule on the motion. See Mann-Stack v.…