Patterson v. State

VILLANTI, Judge.

Alexander Patterson appeals the summary dismissal of his motion for jail credit filed under Florida Rule of Criminal Procedure 3.800(a). Patterson sought credit against his prison sentence for time spent in jail in New York. Because the trial court based its dismissal on the erroneous application of Florida Rule of Criminal Procedure 3.801, we reverse the dismissal order and remand for further proceedings.

Patterson pleaded no contest to lewd and lascivious battery on a child older than twelve but under sixteen years of age and was originally sentenced to fifty-one months in…