Ray v. State

The subject is Maryland Rule of Procedure 4-345(a)’s provision that: “The court may correct an illegal sentence at any time.” The appellant, Bashawn Montgomery Ray, filed in the Circuit Court for Montgomery County on March 23, 2015, just such a motion to correct what he deemed to be an illegal sentence. On July 24, 2015, the court denied the motion without hearing or written opinion. This appeal followed. It presents an appropriate occasion for a macroscopic overview of Rule 4-345(a): its origin; its purpose; its resultant freedom from a filing deadline; its critical distinction between…