State v. Brown, 211 A.3d 335

Andrew Brown was convicted of multiple offenses arising from armed robberies and a nonfatal shooting; among them were conspiracy to rob Glover (Count 10) and use of a handgun in a crime of violence (Count 19).
At sentencing the court announced multiple 20-year terms: for three counts it said “suspend all but 10 years,” but as to Count 10 it announced “20 years, suspend all but time served,” followed by two years probation.
The court also imposed a 10-year sentence (first five without parole) on the handgun count to run consecutive to Count 10.
After pronouncement, the court and counsel engaged in informal colloquy about aggregate exposure; the court later made ambiguous remarks suggesting “suspend all but 10” in describing the aggregate, but never expressly acknowledged or corrected any mistake on the record.
The commitment record and docket entries reflected a 20‑year term with all but 10 suspended on Count 10, but the transcript reflected “all but time served.” The Court of Special Appeals ordered correction of records to match the transcript; the State sought certiorari.

Issue	Plaintiff's Argument (State)	Defendant's Argument (Brown)	Held
Whether an anomalous announced sentence qualifies as an “evident mistake” under Md. Rule 4-345(c)	The court’s “time served” remark was an evident slip; the court intended “all but 10” given context and consecutive handgun term	There was no evident mistake; any correction must be express and on the record	A mistake is “evident” only if clear/obvious; an anomalous sentence alone is not enough to show an evident mistake
Whether the court’s later informal statements corrected any such mistake under Rule 4-345(c)	The court’s subsequent remarks showing an aggregate 20/10 explanation amounted to correction of the slip	Correction must be an on-the-record acknowledgment of error; informal remarks are insufficient	A correction under Rule 4-345(c) requires the trial court to acknowledge the mistake and indicate it is being corrected on the record before the defendant leaves; informal colloquy does not suffice

State v. Sayre, 314 Md. 559 (Court of Appeals of Maryland) (holding a court may not increase a sentence after pronouncement; illustrates an ‘‘evident mistake’’ corrected only within the rule’s limits)
Simpkins v. State, 88 Md. App. 607 (Court of Special Appeals of Maryland) (illustrating an obvious mispronouncement and issues about timing of correction)
Greco v. State, 347 Md. 423 (Court of Appeals of Maryland) (noting the 4-345 amendments modified Sayre)
Lawson v. State, 187 Md. App. 101 (Court of Special Appeals of Maryland) (reiterating that transcript controls over conflicting commitment records)