Supreme Court of Florida

Jahquell Davis v. State of Florida

December 19, 2019286 So. 3d 170

Summary

The Court approved the Fifth District’s decision holding that Davis’s investigative detention did not begin the speedy-trial period under Florida Rule of Criminal Procedure 3.191. It held that, under the rule as currently interpreted, courts must continue applying the established four-part arrest test, although formal arrest would better align the rule with the Sixth Amendment right and the Court referred the issue for possible rule amendment.