State v. Schlick, 214 A.3d 1139

In 2005 Schlick was sentenced (suspended portion) and placed on probation; after a probation violation the court revoked probation and reimposed the suspended portion on September 15, 2008.
Schlick requested his 2008 attorney file a Rule 4-345 motion to modify sentence, but counsel failed to do so; Schlick later filed a postconviction petition asserting ineffective assistance of counsel.
On March 20, 2013 the postconviction court granted relief and permitted Schlick to file a belated motion for modification within 90 days; Schlick filed the motion May 24, 2013.
The circuit court dismissed the motion on August 8, 2017, holding its revisory power expired five years after the 2008 reimposition (Sept. 15, 2013).
The Court of Special Appeals reversed, and the Court of Appeals granted certiorari to resolve whether postconviction-ordered belated motions affect the five-year revisory window in Md. Rule 4-345(e).
The Court of Appeals held the postconviction grant implicitly restored the full benefits of Rule 4-345(e): the circuit court retained revisory power for five years from the postconviction order (i.e., until March 20, 2018), so dismissing Schlick’s motion in Aug. 2017 was premature.

Issue	Schlick's Argument	State's Argument	Held
When does the 5-year revisory period run after probation revocation?	It runs from the date sentence is reimposed (Sept. 15, 2008).	Agrees that reimposition triggers the period, not the original 2005 date.	Reimposition on revocation is treated as an "original sentence" for Rule 4-345(e); five-year clock runs from Sept. 15, 2008.
Does a postconviction grant of permission to file a belated Rule 4-345 motion restore the court's 5-year revisory power?	Yes — implicit in granting a belated motion is restoration of the court’s five-year revisory period measured from the postconviction order.	No — the five-year limit in Rule 4-345(e) is mandatory and cannot be extended; belated filing does not automatically entitle a belated ruling outside the original five-year window.	Held for Schlick: postconviction relief to file a belated motion restores the full Rule 4-345(e) benefits, including a five-year revisory period running from the postconviction court’s final order.
Was dismissal of Schlick’s motion in Aug. 2017 lawful because revisory power had expired?	N/A (relief sought).	Dismissal proper because five-year revisory period from 2008 had expired Sept. 2013.	Dismissal was premature; circuit court retained revisory power until March 20, 2018 (five years from postconviction order).

State v. Flansburg, 345 Md. 694 (1997) (ineffective assistance that prevents timely Rule 4-345 filing may justify permission to file a belated motion)
McDonald v. State, 314 Md. 271 (1988) (sentence reimposed on probation revocation is treated as an original sentence for modification deadlines)
Greco v. State, 347 Md. 423 (1997) (timely-filed Rule 4-345 motion preserves court authority to act even if held sub curia)
State v. Crawley, 455 Md. 52 (2017) (interpretation of Maryland Rule 4-345 is a question of law reviewed de novo)
Tshiwala v. State, 424 Md. 612 (2012) (noting adoption of five-year limit in Rule 4-345)
United States v. Benz, 282 U.S. 304 (1931) (reducing a sentence is a judicial act altering the judgment)