State v. Brown

Summary

The court held that Brown's sentence was complete and therefore not illegal because the pronounced "hard 40" sentence implicitly included parole eligibility after 40 years, and the omitted advice about appellate rights was collateral to the sentence. The court nevertheless remanded for a nunc pro tunc order correcting the journal entry's erroneous reference to lifetime postrelease supervision. The court reviewed the newly raised illegal-sentence arguments despite their lack of preservation because an illegal sentence may be corrected at any time.