Colvin v. State

We examine in this case whether an alleged procedural error in the finalization of a verdict is a cognizable claim under Maryland Rule 4-345(a), which permits the courts of this State to correct an illegal sentence at any time. The scope of this rule, allowing collateral and belated attacks on the sentence and excluding waiver as a bar to relief, is narrow. We hold that the procedural error alleged in the present case does not come within the narrow meaning of Rule 4-345(a) and therefore is not a cognizable claim under that rule.

I

The trial, verdict, sentence, and direct appeal.

Roderick Colvin…