State v. Smith

Summary

The court held that the trial court lacked subject matter jurisdiction over the defendant’s motion to correct an illegal sentence because the alleged cumulative convictions had no effect on the sentence imposed. The requested vacatur would have modified only the conviction, not the length, computation, or structure of the sentence, so the motion should have been dismissed rather than denied on the merits. The court therefore did not reach whether the Polanco rule applied retroactively.