Jerartis Icon v. State of Florida

Summary

The Third District Court of Appeal of Florida affirmed an order striking Jerartis Icon’s motion to clarify concurrent sentences and jail with prison credits as successive. The court held that Florida Rule of Criminal Procedure 3.801(d) prohibits consideration of a successive motion for jail credit, and that the attached prior motion and denial established the motion’s successive nature.

Holdings

1. Because Rule 3.801(d) expressly prohibits a trial court from considering a successive motion for jail credit, the trial court did not err by striking Icon's successive motion.

Questions Presented

1. Whether the trial court erred by striking Icon's April 2, 2024 Rule 3.801 motion as successive.

Disposition

affirmed