State v. Thomas

Summary

The Supreme Court of Maryland held that Maryland Rule 4-345(e)(1) unambiguously prohibits a circuit court from revising a sentence more than five years after imposition, even when the defendant timely filed a motion within 90 days. The Court also held that a court may defer a timely motion throughout the five-year period, and need not formally grant or deny it before the period expires. The Court overruled the contrary appellate precedent and reversed the appellate judgment.