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RONALD HASKINS v. STATE OF MARYLAND

Criminal procedure — Illegal sentence — Merger of handgun and assault convictions

In 1999, Ronald Haskins was convicted of first-degree assault, use of a handgun in the commission of a felony or crime of violence, and related offenses based on evidence that he shot a woman. The court sentenced him to 20 years’ imprisonment for the handgun offense and to a consecutively run term of 20 years for the first-degree assault. (The remaining convictions were merged for sentencing purposes.) This Court affirmed the judgments on direct appeal. Haskins v. State, No. 926, September Term, 1999 (filed August 29, 2000).

Twenty years later, Mr. Haskins filed a Rule 4-345(a) motion to correct an illegal sentence in which he maintained that the sentencing court erred in failing to merge—either under the required evidence test or the rule of lenity—the handgun offense into the firstdegree assault conviction for sentencing purposes.

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