State v. McKnight
Annotate this CaseWilliam McKnight pleaded no contest to possession of marijuana with intent to distribute and was sentenced to thirty months' incarceration with twenty-four months' postrelease supervision. Because his crime fell in a border box on the drug grid, the trial court suspended the sentence and put McKnight on an eighteen-month probation. When McKnight violated the terms of his probation, the court revoked McKnight's probation and imposed a modified sentence of twenty-two months' incarceration with no period of postrelease supervision. Later, the State made a motion to correct an illegal sentence. The trial court imposed the modified twenty-two months' incarceration with twenty-four months' postrelease supervision. The court of appeals affirmed the trial court. The Supreme Court reversed the judgment of the court of appeals and the district court, vacating the sentence imposing postrelease supervision. The Court then affirmed the sentence originally imposed of twenty-two months' incarceration with no postrelease supervision, holding (1) once a legal sentence is pronounced from the bench, the trial court does not have jurisdiction to modify the sentence; and (2) the trial court in this case imposed a legal sentence, and therefore, it did not have jurisdiction to later modify that sentence.
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