Teresa Schlabach, Petitioner v. State of Florida, Respondent

Summary

The court held that a trial court retains jurisdiction to modify a sentence when the defendant timely files a motion under rule 3.800(c), even if the court does not rule within sixty days, provided it rules within a reasonable time. The court rejected the view that the sixty-day period is an automatic jurisdictional bar, quashed the district court's decision, reinstated the resentencing order, and approved the conflicting district court decision. Justice Canady, concurring in result, agreed with the disposition and supported referring the issue of definite time limits for rule 3.800(c) motions to the Criminal Procedure Rules Committee.