Criswell v. State

Summary

The court dismissed the appeal from orders denying the appellant’s postconviction petitions because he was no longer incarcerated on the convictions at issue. It held that physical incarceration is required to proceed under Rule 37.1 and that granting relief would have no further effect after release. The court therefore did not address whether the petitions were timely or whether the circuit court correctly denied relief on that basis.