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Wiggins v. State

Citations: 384 So. 2d 43; 1980 Fla. App. LEXIS 16862Docket: No. NN-382

Court: District Court of Appeal of Florida; May 23, 1980; Florida; State Appellate Court

Narrative Opinion Summary

Appellant Robert P. Smith, Jr. was convicted on two counts of uttering a forged instrument and appealed, claiming a violation of his right to a speedy trial under Fla.R.Crim. P. 3.191. The court found in favor of the appellant, determining that the trial period began on August 4, 1978, when he was taken into custody as a suspect and confessed to the charges, rather than on the later date of August 25, 1978, when he was formally arrested. The court noted that although he was arrested on one charge, he was in custody for all related charges. The previous conviction was reversed, and the appellant was discharged. Judges Ervin and Wentworth concurred with the decision.

Legal Issues Addressed

Custody for Multiple Charges

Application: The court recognized that being in custody for one charge encompasses custody for all related charges.

Reasoning: The court noted that although he was arrested on one charge, he was in custody for all related charges.

Reversal of Conviction

Application: Based on the violation of the right to a speedy trial, the appellant's previous conviction was reversed and he was discharged.

Reasoning: The previous conviction was reversed, and the appellant was discharged.

Right to Speedy Trial under Florida Rule of Criminal Procedure 3.191

Application: The court determined that the speedy trial period commenced when the appellant was taken into custody and confessed, rather than the date of formal arrest.

Reasoning: The court found in favor of the appellant, determining that the trial period began on August 4, 1978, when he was taken into custody as a suspect and confessed to the charges, rather than on the later date of August 25, 1978, when he was formally arrested.