Teresa Schlabach, Petitioner v. State of Florida, Respondent

Summary

The court held that a trial court retains jurisdiction to modify a sentence when a rule 3.800(c) motion is filed within sixty days, even if the court does not rule within that period, provided it rules within a reasonable time. The court rejected a jurisdictional interpretation that would penalize defendants for delays in scheduling or deciding motions, quashed the district court's decision, and reinstated the resentencing order. Justice Canady, concurring in the result, agreed that the governing precedent required that disposition and also supported referral of the timing issue for rulemaking.