State v. Roat
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The Supreme Court affirmed the judgment of the court of appeals dismissing Appellant's appeal of the district court's denial of his motion to correct an illegal sentence, holding that the completion of a sentence does not necessarily render a case moot but that Appellant's appeal became moot as a consequence of the expiration of his sentencing conditions.
Defendant pled guilty to making a criminal threat and was sentenced to a term of imprisonment with a probation period. His probation was later revoked, and the prison term was imposed. The next year, Defendant pled guilty in a separate case to drug offense. The district court sentenced Defendant to thirty-four months in prison. Defendant later filed a motion arguing that both sentences were illegal because the court had improperly calculated his criminal history. The district court denied the motion. The court of appeals dismissed Defendant's appeal. The Supreme Court affirmed, holding (1) a case is moot when a court determines it is clearly and convincingly shown that the actual controversy has ended, that the only judgment that could be entered would be ineffectual for any purpose, and that it would not have an impact on any of the parties' rights; and (2) under the circumstances, Defendant's appeal was moot.
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