State v. Bustillo

Summary

The court held that the sentencing court's failure to state the duration of probation orally, despite Maryland Rule 4-346(a), was a procedural error rather than an illegal sentence. The written probation order, signed by the defendant and counsel before leaving court, supplied the missing duration and conditions, and the sentencing court had authority to impose the split sentence. Because the issue was not preserved at sentencing and did not fall within the exception for illegal sentences, the court reversed and remanded with instructions to affirm the circuit court's judgment.