State v. Carlisle
Annotate this CaseA jury found Jack Carlisle guilty of kidnapping and gross sexual imposition (GSI) and sentenced him to three years' imprisonment for kidnapping and one year of imprisonment for GSI, to be served concurrently. The trial court later vacated Carlisle's sentence due to change of circumstances, namely the cost of Carlisle's dialysis, and imposed a sentence of five years of community control. The court of appeals reversed, concluding that the trial court lacked authority to modify Carlisle's sentence because his convictions had been affirmed on appeal. The Supreme Court affirmed but on different grounds, holding that the trial court in this case lacked the requisite authority to modify Carlisle's sentence, as absent statutory authority, a trial court is generally not empowered to modify a criminal sentence by reconsidering its own final judgment. Remanded.
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