DeAngelo v. State

James David DeAngelo appeals the postconviction court order summarily denying his motion filed under Florida Rule of Criminal Procedure 3.801. We affirm the order as it relates to DeAngelo’s claim for out-of-state jail credit. However, we reverse the denial of his claim for Polk County jail credit and remand for further proceedings.

Police arrested DeAngelo following a traffic stop in Maryland after they discovered a fugitive warrant from Polk County for violation of probation. On January 3, 2013, after authorities transported him back to Polk County, the court sentenced DeAngelo to thirty…