Dustin Dale Limbocker, Appellant v. State of Arkansas, Appellee

Summary

The court affirmed revocation of Limbocker’s suspended imposition of sentence and his six-year prison sentence. Although the original sentencing order improperly made the imprisonment and suspended sentence consecutive, the error made the order illegal in application rather than void in its entirety, and the circuit court properly corrected it to make the sentences concurrent. The court also concluded that Limbocker showed no actual harm because his subsequent offenses occurred within the lawful suspension period and he did not challenge the revocation basis. Justice Danielson, joined by Justice Hart, dissented, arguing that the void sentence could not support revocation for conduct occurring before correction.