State v. Hoffman, 397 P.3d 789

Amelia Hoffman was charged with possession/use of a controlled substance (third-degree felony) and pleaded no contest to amended attempted possession, a class A misdemeanor.
Defense and prosecution jointly recommended: 12 months Salt Lake County probation, a substance-abuse evaluation with recommended treatment, 50 hours community service, and a $50 recoupment fee.
The district court imposed a 365-day jail sentence and $4,625 fine, then suspended both and placed Hoffman on 12 months supervised probation with the recommended conditions plus standard probation terms (no drugs/alcohol, avoidance of drug venues/people, random drug testing).
Hoffman did not object at sentencing and responded “okay” when conditions were imposed.
On appeal she argued the supervised probation and conditions were improper, seeking review under plain error and alternatively under Utah R. Crim. P. 22(e) (illegal sentence).

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the district court erred in imposing 12 months supervised probation and substance-abuse conditions	Hoffman: sentence was excessive/unfair; supervised probation and conditions improper	State: sentence followed the joint recommendation and standard probation practice; no error preserved	Court: Claim invited by joint recommendation and lack of objection; plain error doctrine unavailable; no review on merits
Whether the claim can be reviewed as an "illegal" sentence under Utah R. Crim. P. 22(e)	Hoffman: labels the sentence "illegal" and violative of due process, so rule 22(e) allows review despite lack of preservation	State: sentence neither beyond statutory range nor imposed by a court lacking jurisdiction; rule 22(e) is narrow and doesn’t cover routine sentencing disagreements	Court: Rule 22(e) inapplicable—Hoffman’s challenge is a routine sentencing complaint, not an illegal sentence; appeal denied

Anders v. California, 386 U.S. 738 (U.S. 1967) (counsel must move to withdraw with a brief if appeal is wholly frivolous and provide the client a copy)
State v. Alfatlawi, 153 P.3d 804 (Utah Ct. App. 2006) (plain error requires showing of error, obviousness, and harm; invited error precludes plain-error review)
State v. Thorkelson, 84 P.3d 854 (Utah Ct. App. 2004) (rule 22(e) review of illegal sentence is "narrowly circumscribed")
State v. Telford, 48 P.3d 228 (Utah 2002) (defining illegal sentence as where court lacks jurisdiction or imposes sentence beyond statutory range)
State v. Jaeger, 973 P.2d 404 (Utah 1999) (appellate briefs must develop authority and reasoned analysis; bald citations are insufficient)