Johnson v. State, 205 So. 3d 814

Appellant Wayne Alan Johnson filed multiple pro se motions under Fla. R. Crim. P. 3.801 seeking jail credit for time in Polk County Jail between June–November 2014.
The postconviction court characterized Johnson’s first two filings as seeking out-of-state jail credit and dismissed them without prejudice, directing refiling under rule 3.850.
Johnson continued to file under rule 3.801; the court denied his third motion as facially insufficient and refused leave to amend, stating the claim was refuted by the record.
The court relied on a Polk County Sheriff’s Office certificate showing arrest and release dates, but that certificate did not show whether jail credit had been awarded.
The appellate court found the third motion was facially insufficient under rule 3.801(c), but the second motion (filed Oct. 28, 2015) contained the required information, oath, and the rule 3.850(n) certification and thus was facially sufficient.
The appellate court reversed and remanded, instructing the trial court to address the jail-credit claim asserted in the second motion as modified by the third motion.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the postconviction court properly denied Johnson’s 3.801 motion as refuted by the record	Johnson argued he was entitled to jail credit for custody from transfer into Florida (June 20/26, 2014) to sentencing (Nov. 19, 2014) and supported the claim in his filings	State (and trial court) argued the claim was facially insufficient or was an out-of-state credit claim referrable to rule 3.850; court relied on sheriff’s certificate to deny	Reversed — the record did not refute the claim; the second motion was facially sufficient and must be addressed on the merits
Whether dismissal with prejudice was appropriate after prior procedural defects	Johnson asserted his second motion cured pleading defects and included required oath/certification	State maintained prior defects justified dismissal and required refiling under rule 3.850	Reversed — dismissal with prejudice was improper because the second motion met rule requirements and meritorious resolution is preferred

James v. State, 185 So. 3d 649 (Fla. 2d DCA 2016) (reversal where piecemeal compliance with pleading requirements nonetheless warranted merits consideration)
Smith v. State, 100 So. 3d 201 (Fla. 2d DCA 2012) (postconviction proceedings must provide meaningful access to judicial process)