illegal sentence claim (Mississippi) · Go Syfert
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illegal sentence claim in Mississippi

9 Mississippi opinions name it 2 courts 2007–2020 0 in the last five years

The cases below were cited by Mississippi courts in a sentence that names this issue. Sides come from how each citing opinion treated the case (Syfertize flag on that citation), so a case can appear on both: that is where the law is contested. A red or yellow chip is the case's own overall treatment.

Followed or applied (18)

CaseFollowedCited
Ivy v. Stategreen
miss · 1999 · cited in 2 Mississippi opinions naming this issue, 2011–2012
2 sentences

2012See, e.g., Ivy v. State, 731 So.2d 601, 603 (¶¶ 13-14) (Miss.1999) (holding “that errors affecting fundamental constitutional rights, such as the right to a legal sentence, may be excepted from” the three-year time-bar); Weaver v. State, 785 So.2d 1085, 1087 (¶ 6) (Miss.Ct.App.2001) (holding PCR motions “alleging an illegal sentence are not subject to the time[-]bar”). ¶ 11.

2011See id. at 507-08 (¶¶ 12-14); Kennedy v. State, 732 So.2d 184, 186-87 (¶ 8) (Miss.1999); Ivy v. State, 731 So.2d 601, 603 (¶¶ 13-14) (Miss.1999). ¶ 6.

22
Rowland v. Statered
miss · 2012 · cited in 2 Mississippi opinions naming this issue, 2020–2020
2 sentences

2020Rowland v. State, 98 So. 3d 1032 , 1035–36 (Miss. 2012), overruled on other grounds by Carson v. State, 212 So. 3d 22 (Miss. 2016).

2020Although an illegal-sentence claim is an exception to the time, waiver, and successive- writ bars, Rowland v. State, 98 So. 3d 1032, 1035-36 (Miss. 2012), overruled on other grounds by Carson v. State, 212 So. 3d 22 (Miss. 2016),. a defective-indictment claim-which is the basis for Cummings's illegal-sentence claim-does not meet any recognized exception to the bars.

12
Kevin Brown v. State of Mississippigreen
missctapp · 2016 · cited in 1 Mississippi opinions naming this issue, 2020–2020
1 sentence

2020Chapman v. State, 167 So. 3d 1170, 1174-75 (Miss. 2015); Smith v. State, 149 So. 3d 1027, 1031 (Miss. 2014), overruled on other grounds by Pitchford v. State, 240 So. 3d 1061 (Miss .. 2017); Bell v. State, 123 So. 3d 924, 925 (Miss. 2013); Rowland, 98 So. 3d at 1035-36 ; see also Brown v. State, 187 So. 3d 667, 671 (Miss.

11
Bell v. Stategreen
miss · 2013 · cited in 1 Mississippi opinions naming this issue, 2020–2020
1 sentence

2020Chapman v. State, 167 So. 3d 1170, 1174-75 (Miss. 2015); Smith v. State, 149 So. 3d 1027, 1031 (Miss. 2014), overruled on other grounds by Pitchford v. State, 240 So. 3d 1061 (Miss .. 2017); Bell v. State, 123 So. 3d 924, 925 (Miss. 2013); Rowland, 98 So. 3d at 1035-36 ; see also Brown v. State, 187 So. 3d 667, 671 (Miss.

11
Eric James Foster v. State of Mississippigreen
miss · 2014 · cited in 1 Mississippi opinions naming this issue, 2020–2020
1 sentence

2020Foster v. State, 148 So. 3d 1012, 1016 (¶12) (Miss. 2014).

11
Donald Keith Smith v. State of Mississippigreen
miss · 2014 · cited in 1 Mississippi opinions naming this issue, 2020–2020
1 sentence

2020Chapman v. State, 167 So. 3d 1170, 1174-75 (Miss. 2015); Smith v. State, 149 So. 3d 1027, 1031 (Miss. 2014), overruled on other grounds by Pitchford v. State, 240 So. 3d 1061 (Miss .. 2017); Bell v. State, 123 So. 3d 924, 925 (Miss. 2013); Rowland, 98 So. 3d at 1035-36 ; see also Brown v. State, 187 So. 3d 667, 671 (Miss.

11
Richard Chapman v. State of Mississippigreen
miss · 2015 · cited in 1 Mississippi opinions naming this issue, 2020–2020
1 sentence

2020Chapman v. State, 167 So. 3d 1170, 1174-75 (Miss. 2015); Smith v. State, 149 So. 3d 1027, 1031 (Miss. 2014), overruled on other grounds by Pitchford v. State, 240 So. 3d 1061 (Miss .. 2017); Bell v. State, 123 So. 3d 924, 925 (Miss. 2013); Rowland, 98 So. 3d at 1035-36 ; see also Brown v. State, 187 So. 3d 667, 671 (Miss.

11
Sneed v. Stategreen
miss · 1998 · cited in 1 Mississippi opinions naming this issue, 2015–2015
1 sentence

2015Sneed v. State, 722 So. 2d 1255, 1257 (¶11) (Miss. 1998) (citation omitted).

11
Means v. Stategreen
miss · 2010 · cited in 1 Mississippi opinions naming this issue, 2014–2014
1 sentence

2014Means v. State, 43 So.3d 438, 442 (¶ 12) (Miss.2010).

11
Weaver v. Stategreen
missctapp · 2001 · cited in 1 Mississippi opinions naming this issue, 2012–2012
1 sentence

2012See, e.g., Ivy v. State, 731 So.2d 601, 603 (¶¶ 13-14) (Miss.1999) (holding “that errors affecting fundamental constitutional rights, such as the right to a legal sentence, may be excepted from” the three-year time-bar); Weaver v. State, 785 So.2d 1085, 1087 (¶ 6) (Miss.Ct.App.2001) (holding PCR motions “alleging an illegal sentence are not subject to the time[-]bar”). ¶ 11.

11
Hannah v. Stategreen
miss · 2006 · cited in 1 Mississippi opinions naming this issue, 2012–2012
1 sentence

2012But a defendant does not – simply by pleading guilty – waive the right to challenge a sentence that is, as a matter of law, illegal.2 Even if an illegal sentence claim can be waived, the waiver must be voluntarily and knowingly made because “[a] plea of guilty is not binding upon a criminal defendant unless it is entered voluntarily and intelligently.” 3 1 Hannah v. State, 943 So. 2d 20, 25 (Miss. 2006). 2 Berry v. State, 722 So. 2d 706, 707 (Miss. 1998); see also Burns v. State, 344 So. 2d 1189, 1190 (Miss. 1977). 3 Alexander v. State, 605 So. 2d 1170, 1172 (Miss. 1992) (citing Myers v. State

11
Alexander v. Stategreen
miss · 1992 · cited in 1 Mississippi opinions naming this issue, 2012–2012
1 sentence

2012But a defendant does not – simply by pleading guilty – waive the right to challenge a sentence that is, as a matter of law, illegal.2 Even if an illegal sentence claim can be waived, the waiver must be voluntarily and knowingly made because “[a] plea of guilty is not binding upon a criminal defendant unless it is entered voluntarily and intelligently.” 3 1 Hannah v. State, 943 So. 2d 20, 25 (Miss. 2006). 2 Berry v. State, 722 So. 2d 706, 707 (Miss. 1998); see also Burns v. State, 344 So. 2d 1189, 1190 (Miss. 1977). 3 Alexander v. State, 605 So. 2d 1170, 1172 (Miss. 1992) (citing Myers v. State

11
Berry v. Stategreen
miss · 1998 · cited in 1 Mississippi opinions naming this issue, 2012–2012
1 sentence

2012But a defendant does not – simply by pleading guilty – waive the right to challenge a sentence that is, as a matter of law, illegal.2 Even if an illegal sentence claim can be waived, the waiver must be voluntarily and knowingly made because “[a] plea of guilty is not binding upon a criminal defendant unless it is entered voluntarily and intelligently.” 3 1 Hannah v. State, 943 So. 2d 20, 25 (Miss. 2006). 2 Berry v. State, 722 So. 2d 706, 707 (Miss. 1998); see also Burns v. State, 344 So. 2d 1189, 1190 (Miss. 1977). 3 Alexander v. State, 605 So. 2d 1170, 1172 (Miss. 1992) (citing Myers v. State

11
Myers v. Stategreen
miss · 1991 · cited in 1 Mississippi opinions naming this issue, 2012–2012
1 sentence

2012But a defendant does not – simply by pleading guilty – waive the right to challenge a sentence that is, as a matter of law, illegal.2 Even if an illegal sentence claim can be waived, the waiver must be voluntarily and knowingly made because “[a] plea of guilty is not binding upon a criminal defendant unless it is entered voluntarily and intelligently.” 3 1 Hannah v. State, 943 So. 2d 20, 25 (Miss. 2006). 2 Berry v. State, 722 So. 2d 706, 707 (Miss. 1998); see also Burns v. State, 344 So. 2d 1189, 1190 (Miss. 1977). 3 Alexander v. State, 605 So. 2d 1170, 1172 (Miss. 1992) (citing Myers v. State

11
Burns v. Stategreen
miss · 1977 · cited in 1 Mississippi opinions naming this issue, 2012–2012
1 sentence

2012But a defendant does not – simply by pleading guilty – waive the right to challenge a sentence that is, as a matter of law, illegal.2 Even if an illegal sentence claim can be waived, the waiver must be voluntarily and knowingly made because “[a] plea of guilty is not binding upon a criminal defendant unless it is entered voluntarily and intelligently.” 3 1 Hannah v. State, 943 So. 2d 20, 25 (Miss. 2006). 2 Berry v. State, 722 So. 2d 706, 707 (Miss. 1998); see also Burns v. State, 344 So. 2d 1189, 1190 (Miss. 1977). 3 Alexander v. State, 605 So. 2d 1170, 1172 (Miss. 1992) (citing Myers v. State

11
Rowland v. Statered
miss · 2010 · cited in 1 Mississippi opinions naming this issue, 2011–2011
1 sentence

2011See id. at 507-08 (¶¶ 12-14); Kennedy v. State, 732 So.2d 184, 186-87 (¶ 8) (Miss.1999); Ivy v. State, 731 So.2d 601, 603 (¶¶ 13-14) (Miss.1999). ¶ 6.

11
Kennedy v. Stategreen
miss · 1999 · cited in 1 Mississippi opinions naming this issue, 2011–2011
1 sentence

2011See id. at 507-08 (¶¶ 12-14); Kennedy v. State, 732 So.2d 184, 186-87 (¶ 8) (Miss.1999); Ivy v. State, 731 So.2d 601, 603 (¶¶ 13-14) (Miss.1999). ¶ 6.

11
Cook v. Stategreen
missctapp · 2005 · cited in 1 Mississippi opinions naming this issue, 2007–2007
1 sentence

2007Ct.App.2005) (stating that defendant cannot reap the favorable benefits of an illegal sentence and then claim prejudice as a result thereof); Cook v. State, 910 So.2d 745, 747 (¶ 10) (Miss.Ct.App.2005) (holding that "an individual may not plead guilty to a crime, receive a lesser sentence than what is prescribed by statute, and then use the more lenient sentence as a sword to attack the entire sentence as illegal").

11

Distinguished, questioned or overruled (0)

CaseNegativeCited
No negative-treatment citations attached to this issue in Mississippi. Read the followed side critically anyway.

Also cited on this issue (2)

CaseCitedYears
Robert Carson v. State of Mississippi green
miss · 2016
2 sentences

2020Rowland v. State, 98 So. 3d 1032 , 1035–36 (Miss. 2012), overruled on other grounds by Carson v. State, 212 So. 3d 22 (Miss. 2016).

2020Although an illegal-sentence claim is an exception to the time, waiver, and successive- writ bars, Rowland v. State, 98 So. 3d 1032, 1035-36 (Miss. 2012), overruled on other grounds by Carson v. State, 212 So. 3d 22 (Miss. 2016),. a defective-indictment claim-which is the basis for Cummings's illegal-sentence claim-does not meet any recognized exception to the bars.

22020–2020
Terry Pitchford v. State of Mississippi green
miss · 2017
1 sentence

2020Chapman v. State, 167 So. 3d 1170, 1174-75 (Miss. 2015); Smith v. State, 149 So. 3d 1027, 1031 (Miss. 2014), overruled on other grounds by Pitchford v. State, 240 So. 3d 1061 (Miss .. 2017); Bell v. State, 123 So. 3d 924, 925 (Miss. 2013); Rowland, 98 So. 3d at 1035-36 ; see also Brown v. State, 187 So. 3d 667, 671 (Miss.

12020–2020

Statutes the citing opinions construe

MS § Miss. Code Ann. § 47-7-34 (3) MS § Miss. Code Ann. § 99-39-5 (3)

Counted by distinct opinions that both name this issue and are annotated to the section; sections every opinion cites regardless of issue are not filtered here, so read the counts against the total above.

Where else courts name it

TN 96 (1999–2026) PA 79 (1992–2026) KS 35 (1996–2026) FL 28 (1996–2026) NY 20 (2008–2026) IA 19 (2014–2026) CO 17 (2007–2026) TX 16 (2010–2026) MS 9 (2007–2020) NV 8 (2016–2021) UT 7 (1995–2023) LA 6 (1981–2025) OH 5 (2010–2017) CT 5 (2009–2021) MD 5 (2004–2026) AL 4 (2004–2022) HI 4 (2018–2023) MT 4 (2004–2024) AR 4 (2004–2020) NJ 4 (1995–2022) NM 2 (2008–2021) SD 2 (2017–2017) DE 2 (1987–2021) AK 2 (2023–2023) ND 2 (1981–2026)

Opinions by the citing court's state. A doctrine retained in one state and abandoned in another shows up here as a year span that stalls.

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