State v. Smith
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The Supreme Court reversed the judgment of the appellate court affirming the judgment of the trial court denying Defendant's motion to correct an illegal sentence, holding that the trial court lacked subject matter jurisdiction to entertain Defendant's motion because the motion sought only to modify Defendant's conviction, not his sentence.
Defendant was convicted of felony murder and manslaughter. The trial court merged the conviction for manslaughter with the felony murder conviction for sentencing purposes. In his motion to correct an illegal sentence, Defendant argued that his sentence was illegal under the supervisory rule set forth in State v. Polanco, 61 A.3d 1084 (2013). The trial court concluded that Polanco did not apply retroactively and denied the motion. The appellate court affirmed. The Supreme Court reversed, holding that the trial court lacked jurisdiction to entertain Defendant's motion to correct an illegal sentence.
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