State v. Brown

Summary

The court held that a motion to correct an illegal sentence cannot be used to raise a constitutional challenge to the sentencing procedure, and the district court was not required to recast Brown's specifically labeled motion as a post-conviction motion under a different statute. The court nevertheless held that the sentencing judge unlawfully pronounced lifetime postrelease supervision for an off-grid indeterminate life sentence, vacated that oral pronouncement, and left the amended journal entry ordering parole in place. The court concluded that no new sentencing hearing or remand was necessary because the written judgment already conformed to the governing statute.