Bratt v. State

Larry Daniel Bratt v. State of Maryland, No. 39, September Term, 2019. Opinion by Hotten, J. CRIMINAL LAW—SENTENCING—CREDIT FOR TIME SERVED— CORRECTION TO COMMITMENT RECORD—MOTION TO CORRECT AN ILLEGAL SENTENCE The Court of Appeals held that the failure to award credit for time served against a sentence was not an illegality to which Rule 4-345 applies. Rather, Rule 4-345 applies to substantive illegalities that exist in the sentence itself. Failure to award credit is a procedural defect that is not appropriately addressed by a motion to correct an illegal sentence because it has no impact on…