Michael D. Spear v. State of Florida

Summary

The Court held that a trial court has inherent authority to correct sentencing documents that overreport jail or prison credit, but only subject to the procedural limits of Florida Rule of Criminal Procedure 3.800(b). Because the trial court made the corrections after the sentences had been affirmed and become final, the corrections were untimely and unauthorized. The Court quashed the district court's decision and remanded for further proceedings.