State v. CoffeeAnnotate this Case
The Supreme Court affirmed the judgment of the court of appeals affirming the circuit court's order denying Defendant's postconviction motion for resentencing, holding that Defendant did not forfeit his ability to challenge inaccurate information raised by the State at his sentencing but that the circuit court's reliance on the inaccurate information was harmless error.
In his postconviction motion, Defendant argued for the first time that the circuit court violated his due process rights when it relied on inaccurate information at sentencing. The postconviction court concluded that the State introduced inaccurate information at the sentencing hearing, that the circuit court actually relied on the inaccurate information, but that the error was harmless. The court of appeals affirmed, concluding that Defendant forfeited his claim because he failed to object at the sentencing hearing. The Supreme Court affirmed, albeit on different grounds, holding (1) the forfeiture rule does not apply to previously unknown, inaccurate information first raised by the State at sentencing; and (2) the circuit court's error in relying on the inaccurate information at sentencing was harmless.