SIMMONS
v.
STATE OF FLORIDA

Fla. 1st DCA | 2026-09-23
No. 2025-2625
Colaw, J., Kelsey, J., Long, J., Treadwell, J.
2026 FL 12344 Florida District Court of Appeal, First District (2026)

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Holding

A defendant's request for jail credit beyond the amount agreed to in a plea bargain is not cognizable under Florida Rule of Criminal Procedure 3.800 or 3.801.


Headnotes

[1] A defendant's request for jail credit beyond the amount agreed to in a plea bargain is not cognizable under Florida Rule of Criminal Procedure 3.800 or 3.801.

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Facts & Procedural History

Jermaine R. Simmons appealed from a circuit court decision denying his request for jail credit beyond the amount agreed to in his plea bargain.…

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Opinion of the Court

FIRST DISTRICT COURT OF APPEAL

STATE OF FLORIDA

JERMAINE R. SIMMONS, Appellant,

v.

STATE OF FLORIDA, Appellee.

No. 1D2025-2625

On appeal from the Circuit Court for Alachua County. James M. Colaw, Judge.

September 23, 2026

PER CURIAM.

Appellant's request for jail credit beyond the amount agreed to in his plea bargain is not cognizable under Florida Rule of Criminal Procedure 3.800 or 3.801. See Johnson v. State, 60 So. 3d 1045, 1052 (Fla. 2011); Ancrum v. State, 281 So. 3d 611 (Fla. 1st DCA 2019).

AFFIRMED.

KELSEY, LONG, and TREADWELL, JJ., concur.


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