Hill, et al. v. State
Annotate this CasePetitioners attempted to vacate their escape convictions where they were sentenced to terms of imprisonment with a deferred, or "springing," start date and the sentencing judge informed them that if they stayed out of further legal trouble during that time, they could return to court before the start date and have their sentences vacated; where petitioners did not return to court and later failed to report on the respective start dates; and where petitioners were charged and pled guilty to second degree escape. At issue was whether a conviction and/or sentence for second degree escape was legally valid if it was predicated on the failure to obey a court order to report to a place of confinement where that court order was legally invalid. The court held that petitioner's failure to report for imprisonment was sufficient to support their escape convictions. The court also held that the subsequent ruling in Montgomery v. State allowed petitioners to challenge, in the appropriate venue, the validity of their "springing" sentences but did not, however, allow them to engage in self-help. The court further held that Maryland law had clearly foreclosed, as a defense to escape, a challenge to the validity of the underlying conviction or sentence.
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