Matthews v. State

Maryland Rule 4-345, “Sentencing — Revisory power of court,” provides, in pertinent part, “(a) Illegal sentence. The court may correct an illegal sentence at any time.” Elroy Matthews, Jr., Petitioner, invoked Rule 4-345(a) to challenge the legality of the sentence he received following his plea of guilty to certain charges, in the Circuit Court for Baltimore County, as part of a plea agreement. Petitioner argued that the sentence was illegal because it exceeded the sentence to which the court had bound itself. The Circuit Court denied the motion without a hearing, and Petitioner appealed.…