State of Maryland v. Anthony Allen Crawley, 455 Md. 52

Summary

The Maryland Court of Appeals held that a sentence for first-degree murder imposed pursuant to a plea agreement was illegal because it suspended all but 35 years of a mandatory life sentence without including a period of probation. Applying Greco v. State, the court ruled that the illegality could be corrected by reimposing the life sentence with all but 35 years suspended and adding a probationary period. The court reversed the Court of Special Appeals and upheld the corrected sentence.

Holdings

1. A substantively illegal sentence must be corrected under Maryland Rule 4-345(a) regardless of whether it was negotiated and imposed as part of a binding plea agreement.
2. The circuit court properly corrected Crawley's illegal sentence by reimposing life imprisonment, suspending all but 35 years, and adding a period of probation.
3. The four-year probation term was lawful and did not constitute an abuse of the circuit court's discretion.

Questions Presented

1. Whether the rule requiring correction of an illegal sentence for first-degree murder applies when the illegal sentence was imposed pursuant to a binding plea agreement.
2. Whether the circuit court properly corrected the illegal sentence by reimposing life imprisonment with all but 35 years suspended and adding a period of probation.
3. Whether the addition of four years of probation violated the plea agreement or constituted an abuse of discretion.

Disposition

reversed