product of procedural error in Maryland

2021Thus, the review panel properly could have reduced Dotson’s sentence without the State’s consent. 21 imposed it [did] not preclude him from arguing on appeal that the sentence breached the plea agreement” because, under Dotson, “a sentence that is imposed in breach of a binding plea agreement is an illegal sentence that can be challenged at any time”); Matthews, 424 Md. at 517-18 (observing that a sentence imposed in violation of Rule 4-243(c) is “not merely the product of procedural error” but, rather, is “inherently illegal and thereby subject to correction under Rule 4-345(a)”).15 In compar

2019Maryland Rule 4-345(a) is intended to correct sentences that are "inherently illegal", not just "merely the product of procedural error." See, e.g. , Colvin v. State , 450 Md. 718 , 728, 150 A.3d 850 (2016) ("With this case, we reaffirm the rule that only claims sounding in substantive law, not procedural law, may be raised through a [Maryland] Rule 4-345(a) motion."); Matthews v. State , 424 Md. 503 , 512, 36 A.3d 499 (2012) ("[T]he illegality must inhere in the sentence itself, rather than stem from trial court error during the sentencing proceeding."); Tshiwala v. State , 424 Md. 612 , 619,

2021The State directs us to Bailey v. State, 464 Md. 685 (2019), wherein the Court of Appeals stressed: “Rule 4-345(a) is intended to correct sentences that are inherently illegal, not just merely the product of procedural error.” Id. at 696 (cleaned up).

2021The State directs us to Bailey v. State, 464 Md. 685 (2019), wherein the Court of Appeals stressed: “Rule 4-345(a) is intended to correct sentences that are inherently illegal, not just merely the product of procedural error.” Id. at 696 (cleaned up).

2019Maryland Rule 4-345(a) is intended to correct sentences that are "inherently illegal", not just "merely the product of procedural error." See, e.g. , Colvin v. State , 450 Md. 718 , 728, 150 A.3d 850 (2016) ("With this case, we reaffirm the rule that only claims sounding in substantive law, not procedural law, may be raised through a [Maryland] Rule 4-345(a) motion."); Matthews v. State , 424 Md. 503 , 512, 36 A.3d 499 (2012) ("[T]he illegality must inhere in the sentence itself, rather than stem from trial court error during the sentencing proceeding."); Tshiwala v. State , 424 Md. 612 , 619,

2019Maryland Rule 4-345(a) is intended to correct sentences that are "inherently illegal", not just "merely the product of procedural error." See, e.g. , Colvin v. State , 450 Md. 718 , 728, 150 A.3d 850 (2016) ("With this case, we reaffirm the rule that only claims sounding in substantive law, not procedural law, may be raised through a [Maryland] Rule 4-345(a) motion."); Matthews v. State , 424 Md. 503 , 512, 36 A.3d 499 (2012) ("[T]he illegality must inhere in the sentence itself, rather than stem from trial court error during the sentencing proceeding."); Tshiwala v. State , 424 Md. 612 , 619,

2020See Bailey, 464 Md. at 696 (“Maryland Rule 4-345(a) is intended to correct sentences that are ‘inherently illegal,’ not just ‘merely the product of procedural error.’” (citations omitted)); Tshiwala v. State, 424 Md. 612, 619 (2012) (“[W]here the sentence imposed is not inherently illegal, and where the matter complained of is a procedural error, the complaint does not concern an illegal sentence for purposes of Rule 4-345(a).”).

2019Maryland Rule 4-345(a) is intended to correct sentences that are "inherently illegal", not just "merely the product of procedural error." See, e.g. , Colvin v. State , 450 Md. 718 , 728, 150 A.3d 850 (2016) ("With this case, we reaffirm the rule that only claims sounding in substantive law, not procedural law, may be raised through a [Maryland] Rule 4-345(a) motion."); Matthews v. State , 424 Md. 503 , 512, 36 A.3d 499 (2012) ("[T]he illegality must inhere in the sentence itself, rather than stem from trial court error during the sentencing proceeding."); Tshiwala v. State , 424 Md. 612 , 619,

2020Instead, an illegal sentence “is one in which the illegality ‘inheres in the sentence itself; i.e., there either has been no conviction warranting any sentence for the particular offense or the sentence is not a permitted one for 26 the conviction upon which it was imposed and, for either reason, is intrinsically and substantively unlawful.’” Colvin v. State, 450 Md. 718, 725 (2016) (quoting Chaney v. State, 397 Md. 460, 466 (2007)).

2019Maryland Rule 4-345(a) is intended to correct sentences that are "inherently illegal", not just "merely the product of procedural error." See, e.g. , Colvin v. State , 450 Md. 718 , 728, 150 A.3d 850 (2016) ("With this case, we reaffirm the rule that only claims sounding in substantive law, not procedural law, may be raised through a [Maryland] Rule 4-345(a) motion."); Matthews v. State , 424 Md. 503 , 512, 36 A.3d 499 (2012) ("[T]he illegality must inhere in the sentence itself, rather than stem from trial court error during the sentencing proceeding."); Tshiwala v. State , 424 Md. 612 , 619,

2019Maryland Rule 4-345(a) is intended to correct sentences that are "inherently illegal", not just "merely the product of procedural error." See, e.g. , Colvin v. State , 450 Md. 718 , 728, 150 A.3d 850 (2016) ("With this case, we reaffirm the rule that only claims sounding in substantive law, not procedural law, may be raised through a [Maryland] Rule 4-345(a) motion."); Matthews v. State , 424 Md. 503 , 512, 36 A.3d 499 (2012) ("[T]he illegality must inhere in the sentence itself, rather than stem from trial court error during the sentencing proceeding."); Tshiwala v. State , 424 Md. 612 , 619,