STATE v. THOMAS

No. 15, Sept. Term, 2023.

322 A.3d 32 (2024)

488 Md. 456

STATE of Maryland v. Steven Anthony THOMAS.

Supreme Court of Maryland.

August 29, 2024.


Attorney(s) appearing for the Case

Argued by Jer Welter, Asst. Atty. Gen. (Anthony G. Brown, Atty. Gen. of Maryland, Baltimore, MD), on brief, for Petitioner/Cross-Respondent.

Argued by Stephanie Asplundh, Asst. Public Defender (Natasha M. Dartigue, Public Defender of Maryland, Baltimore, MD), on brief, for Respondent/Cross-Petitioner.

Counsel for Amicus Curiae Maryland Crime Victims' Resource Center, Inc.: Victor Stone, Esquire, Pauline Mandel, Esquire, Maryland Crime Victims' Resource Center, Inc., 1001 Prince George's Boulevard, Suite 750, Upper Marlboro, MD 20774.

Counsel for Amicus Curiae Maryland Criminal Defense Attorneys' Association: Michelle M. Martz, Esquire, Michelle M. Martz, P.A., 21 East Church Street, Frederick, MD 21701, Megan E. Coleman, Esquire, President, MCDAA, MarcusBonsib LLC, 6411 Ivy Lane, Suite 116, Greenbelt, MD 20770, Lisa J. Sansone, Esquire, Law Office of Lisa J. Sansone, 1002 Frederick Road, Baltimore, MD 21228.

Argued before: Fader, C.J., Watts, Hotten, Booth, Biran, Gould, Eaves, JJ.


At common law, the circuit court's power to revise a sentence expired at the end of the term in which the sentence was imposed. State v. Schlick (Schlick II), 465 Md. 566, 574, 214 A.3d 1139 (2019). The harshness of this common-law rule was ameliorated in 1951, when this Court adopted the predecessor to today's Rule 4-345...

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