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Criminal procedure  — Jury instruction — Witness promised benefit

A jury in the Circuit Court for Prince George’s County convicted William Anthony Knight of robbery, theft of property with a value of at least $1,000 but less than $10,000, unauthorized use of a motor vehicle, transporting a handgun in a vehicle, and possession of a regulated firearm after being convicted of a disqualifying crime. The verdict was returned on January 17, 2014. On March 20, 2014, the court sentenced the appellant to an aggregate term of 33 years in prison with all but 23 years suspended, and five years’ supervised probation upon release.

The appellant filed a notice of appeal on June 17, 2014, almost three months after the judgments of conviction were entered (“The First Appeal”).

On August 27, 2014, the State filed a motion to correct inaccurate sentence in the court’s docket entries, the commitment order to the Department of Corrections, and the probation order. Each document stated that the court had imposed 18 years of unsuspended imprisonment. In fact, as the transcript of the sentencing hearing made clear, the court had imposed 23 years of unsuspended imprisonment. At a hearing on October 21, 2014, the court granted the State’s motion. Its order was entered on October 21, 2014, and was docketed on October 27, 2014. On October 24, 2014, the appellant filed a timely notice of appeal. (“The Second Appeal”).

Read the opinion here: