Bonilla v. State, 92 A.3d 595

Bonilla was indicted in 1989 for two first-degree murders; State sought life without parole.
In 1990 Bonilla pleaded guilty to counts I and III under an ABA plea agreement with specific sentencing terms.
The judge imposed: count I life; count III life with all but 20 years suspended, consecutive; State withdrew life-without-parole notice as part of deal.
Bonilla cooperated against DeLeon, testified, and the sentencing reflected the plea terms; defense misstated the counts at sentencing.
In 2011 Bonilla moved to correct illegal sentence seeking conforming to the ABA agreement; in 2012 the court re-sentenced count III to life and count I to life with 20 years suspended, consecutive to count III.
The State cross-moved, arguing sentences must conform to the plea agreement for both counts; appellate review focused on legality of increasing/counting corrections under Md. Rule 4-345(a).

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the circuit court erred in increasing count III’s sentence	Bonilla argues 4-345(a) did not permit increase when below agreement	State argues court could correct to conform to ABA agreement	Court permissibly corrected to conform with agreement; affirmed

Hoile v. State, 404 Md. 591 (Md. 2008) (legal definition and correction of illegal sentences under 4-345(a))
Dotson v. State, 321 Md. 515 (Md. 1991) (binding plea agreement and later sentence modification)
Chertkov v. State, 335 Md. 161 (Md. 1994) (inviolate binding plea and enforceability concerns)
Carlini v. State, 215 Md. App. 415 (Md. Ct. Spec. App. 2013) (dicta on Chertkov language and 4-345(a) illegality standard)
State v. Hannah, 307 Md. 390 (Md. 1986) (probationary dispositions and mandatory terms context)
State v. Griswold, 374 Md. 184 (Md. 2003) (reinstating convictions after erroneous reconsideration)
Mateen v. Galley, 146 Md. App. 623 (Md. Ct. Spec. App. 2002) (illegal sentence may be corrected by legal imposition)