Perez v. State, 2015 Ark. 120

Omar Perez pleaded guilty in 2013 to multiple felonies and received 120 months’ imprisonment; an additional 120 months was suspended. Judgment entered September 6, 2013.
He received credit for 45 days in custody before sentencing.
On May 21, 2014, Perez filed a pro se motion in the trial court seeking additional jail-time credit for pretrial detention days.
The trial court denied the motion as untimely (filed more than 90 days after entry of judgment).
Perez appealed the denial, arguing that the failure to award full credit made the judgment illegal and thus not subject to the Rule 37 time bar.
The Supreme Court of Arkansas dismissed the appeal for lack of jurisdiction, holding the motion was governed by Rule 37.2(c)’s 90-day jurisdictional deadline and was untimely.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether request for additional jail-time credit is untimely	Perez: claim renders judgment illegal; therefore not subject to Rule 37 time limit	State: claim is a collateral attack to correct sentence imposed in an illegal manner and must meet Rule 37.2(c) deadline	Court: claim is governed by Rule 37.2(c); Perez filed after 90 days, so trial court lacked jurisdiction; appeal dismissed

Delph v. State, 300 Ark. 492, 780 S.W.2d 527 (court defines "illegal sentence" and explains correction/illegal-manner concepts)
Hayes v. State, 2014 Ark. 104, 431 S.W.3d 882 (standard of review for postconviction relief)
Atkins v. State, 2014 Ark. 393, 441 S.W.3d 19 (sentence illegal on its face if it exceeds statutory maximum)
Reed v. State, 317 Ark. 286, 878 S.W.2d 376 (Rule 37.2(c) governs claims of sentences imposed in an illegal manner for guilty pleas)
Cooley v. State, 322 Ark. (request for credit is a motion to correct a sentence imposed in an illegal manner)