State v. Harris
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This appeal involved two criminal cases against Mario Harris. In Harris I, Harris pleaded guilty to two offenses with forfeiture specifications. After the trial court imposed a sentence, Harris filed a motion for resentencing, which the court denied. The appellate court held that the trial court's denial of Harris's motion was not a final, appealable order because the sentencing court had failed to include the terms of forfeiture in the judgment of conviction. In Harris II, Harris pled guilty to an offense with an automobile-forfeiture specification. The trial court imposed a prison sentence and ordered the forfeiture. The court denied Harris's subsequent motion for resentencing. The appellate court held that the sentence was void because the trial court had failed to include a mandatory driver's license suspension as part of Harris's sentence. The Supreme Court consdoliated the cases and held (1) a journal entry of conviction need not include a related forfeiture in order to be a final appealable order; and (2) when a trial court fails to impose a mandatory driver's license suspension as part of an offender's sentence, that part of the sentence is void, and resentencing is limited to the imposition of the statutorily mandated term.
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