State v. Holdcroft
Annotate this CaseAfter a jury trial, Appellant was convicted of aggravated arson and arson. The trial court sentenced Appellant to ten years imprisonment for aggravated arson and five years for arson, to be served consecutively. The trial court notified Appellant that a postrelease-control sanction would be imposed but failed to state the duration of the sanction and which conviction it was part of. After Appellant completed his prison term for aggravated arson and began serving his prison term for arson, the trial court imposed postrelease control related to Defendant's aggravated-arson offense. Appellant appealed the sentencing judgment, arguing that because he had served the prison sentence for his aggravated-arson offense, the trial court lacked jurisdiction to impose postrelease control related to that offense. The court of appeals affirmed, holding that a trial court may resentence a defendant in order to correctly impose postrelease control if the defendant is still serving a prison term for any of the other offenses included in the same judgment entry of sentence. The Supreme Court reversed, holding that when Defendant completed his prison term for aggravated arson, the trial court lost the authority to impose a postrelease-control sanction for that offense.
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