Matthews v. State, 36 A.3d 499

Petitioner pled guilty to attempted first-degree murder, two counts of first-degree assault, and unlawful handgun use under a plea agreement.
The State agreed to nol pros remaining counts and argued for incarceration within the top of the guidelines, a cap of 23 to 43 years, and that cap applied to actual and immediate incarceration at disposition.
The court stated it agreed to cap any sentence and advised it could impose from the five-year minimum to life; Petitioner was sentenced to life with 30 years executed and other terms concurrent.
Postconviction relief sought; alleged the State breached the plea by requesting life instead of a 43-year total; the postconviction court ordered a new sentencing proceeding.
At re-sentencing, the State argued the original sentence could be re-imposed; Petitioner argued the cap of 43 years, including suspended time, bound the court.
The Court of Special Appeals held the Rule 4-345(a) challenge improper and the sentence was legal; this Court granted certiorari to decide if the plea cap governs legality of sentence.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether Rule 4-345(a) permits challenging a sentence that violates a binding plea agreement	Matthews: Rule 4-345(a) can address inherent sentence illegality from plea terms	State: Rule 4-345(a) does not cover breach-based or plea-cap violations	Yes; Rule 4-345(a) can challenge plea-cap violations
Whether the re-imposed sentence violated the plea cap by exceeding the bound total	Matthews: sentence exceeded the cap of 43 years including suspended time	State: cap limited to executed time; suspended portion could exceed cap	Sentence exceeded the cap and was illegal
How the sentencing cap should be interpreted (executed vs total including suspended time)	Ambiguity resolved in petitioner’s favor; cap includes total, including suspended time	Cap applies only to executed time	Ambiguity resolves in petitioner’s favor; cap includes total time
What record governs interpretation of the plea agreement terms	Record at plea hearing determines what was reasonably understood about the cap	Record may be ambiguous or unclear; court may interpret	Record is ambiguous; interpret in petitioner’s favor
Remedy for an inherently illegal sentence under Rule 4-345(a)	Courts should vacate and remand for sentencing consistent with cap	No automatic remand; may re-impose within cap	Vacate and remand for resentencing consistent with 43-year cap, 30 executed years

Solorzano v. State, 397 Md. 661 (Md. 2007) (plea agreement fixed maximum sentence; sentence breached requires relief)
Cuffley v. State, 416 Md. 568 (Md. 2010) (breach of plea cap where sentence exceeded within-guidelines term held illegal)
Dotson v. State, 321 Md. 515 (Md. 1991) (plea agreement fixed maximum; panel-imposed excess was illegal)
Walczak v. State, 302 Md. 422 (Md. 1985) (exception to finality for Rule 4-345(a) relief)
Chaney v. State, 397 Md. 460 (Md. 2007) (probationary conditions not inherently illegal; relief depends on illegality in sentence)