State v. Waterfield, 248 P.3d 57

Background

Waterfield challenged district court orders revoking probation and restarting probation on RSAT eligibility and sentencing grounds.
The April 14 restart of probation was challenged as an illegal sentence; the district court later treated it as illegal and set it aside.
The May 19 order allegedly executed Waterfield's original sentence rather than resentencing him, affecting RSAT eligibility and sentencing status.
The court discussed whether Rule 22(e) permits correcting illegal sentences and whether Rule 30(b) oversights applied to a clerical error.
Objections Waterfield raised to the PSI were not fully resolved on the record, triggering a remand to address unresolved PSI objections.

Issues

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the April 14 restart of probation was correctly treated as an illegal sentence.	Waterfield argues the April 14 order improperly restarted probation without suspending the original sentence.	State contends the restart was within the court's discretion and not a jurisdictional violation.	The district court erred in treating the April 14 order as an illegal sentence under Rule 22(e).
Whether the May 19 order constituted resentencing or execution of the original sentence.	Waterfield claims May 19 was a post- RSAT-eligibility resentencing.	State argues it was execution of the original sentence following probation revocation.	Execution of the original sentence, not a resentencing, and Rule 22(e) did not apply.
Whether the RSAT mootness and related screenings affected Waterfield's rights.	Waterfield asserts mootness of RSAT issues prevented proper consideration of his RSAT screening.	State asserts the court still reviewed the RSAT screening process and ensured proper consideration.	The court erred in deeming RSAT issues moot but no prejudice shown; remand for PSI resolution.
Whether the district court properly resolved Waterfield's objections to the PSI on the record.	Waterfield contends the court failed to resolve multiple PSI objections on the record.	State maintains the court addressed some objections, but others were unresolved.	The district court did not adequately resolve certain objections; remand for resolution.
Whether Waterfield was prejudiced by the district court's handling of the PSI objections.	Waterfield argues improper PSI handling could have affected his treatment and sentencing prospects.	State contends any potential prejudice is not established and briefing is lacking.	Prejudice not adequately shown; remand limited to addressing remaining PSI objections; otherwise affirm.

Key Cases Cited

State v. Candedo, 2010 UT 32 (Utah Supreme Court 2010) (defines scope of Rule 22(e) correction for illegal sentences)
State v. Thorkelson, 2004 UT App 9 (Utah App. 2004) (limits on what constitutes a 'patently illegal' sentence)
State v. Rodrigues, 2009 UT 62 (Utah Supreme Court 2009) (clerical error in judgment may be corrected under Rule 30(b))
State v. Anderson, 2009 UT 13 (Utah Supreme Court 2009) (execution of a suspended sentence after probation revocation)
State v. Gustafson, 38 Or.App. 437 (Or.App. 1979) (execution of a previously imposed sentence does not constitute a new sentence)
State v. Jaeger, 1999 UT 1 (Utah Supreme Court 1999) (trial court must address objections to PSI on the record)
State v. Veteto, 2000 UT 62 (Utah Supreme Court 2000) (formal resolution required for objections to the PSI; general statements insufficient)