Davis v. StateAnnotate this Case
The Supreme Court approved the decision of the Fifth District Court of Appeal affirming the trial court's denial of Defendant's motion for discharge for expiration of speedy trial, holding that the Fifth District properly applied Melton v. State, 75 So. 2d 291 (Fla. 1954), and that an investigatory detention does not constitute an arrest for purposes of starting the speedy trial period in Fla. R. Crim. P. 3.191.
At issue was how the term "arrest" should be defined for purposes of starting the speedy trial period set forth in Rule 3.191, Florida's procedural speedy trial rule. The Supreme Court adhered to Griffin v. State, 474 So. 2d 777 (Fla. 1985), which adopted the definition of arrest from Melton for purposes of determining when the speedy trial period begins, and held that the Fifth District did not err in determining that there was no speedy trial violation in this case.