Brian Michael Robinson, Petitioner v. State of Florida, Respondent

Summary

The Florida Supreme Court affirmed the First District Court of Appeal’s interpretation that a defendant’s continuous physical absence from the state tolls the statute of limitations under §775.15(5) without requiring the State to prove a diligent search or that the absence hindered prosecution. The Court rejected the Second District’s contrary view and held that an address of record does not defeat a finding of continuous absence.