The Supreme Court of Maryland issued an opinion Tuesday clarifying when criminal sentences are legally "imposed" under state law, ruling that trial courts retain authority to modify sentences throughout the entire sentencing hearing without violating double jeopardy protections.
In *Reyes v. State*, the state's high court held that a sentence is not imposed under Maryland Rule 4-345 until the sentencing proceeding ends. The ruling resolves questions about the temporal boundaries of sentencing procedures and provides guidance for trial courts on when sentence modifications are permissible.
The case centered on Jeffrey Reyes, whose sentence was increased by the trial court during his sentencing hearing in Prince George's County Circuit Court. Reyes challenged the increase, arguing it violated Maryland Rule 4-345's restrictions on sentence modifications and constituted an illegal sentence increase that violated double jeopardy protections.
Justice Killough, writing for the court, rejected Reyes' arguments. The court held that the defendant's sentence was not illegally increased because the trial court made the modification before the sentence was imposed. "The trial court increased the Defendant's sentence before the sentence was imposed, thus avoiding Double Jeopardy violations and the confines Maryland Rule 4-345 places on sentence increases and modifications," the opinion states.
Maryland Rule 4-345 governs sentence imposition and modification procedures in criminal cases. The rule generally restricts a court's ability to modify sentences after they have been imposed, with limited exceptions for correction of illegal sentences or sentences imposed in violation of a plea agreement.
The Supreme Court of Maryland determined that Rule 4-345 "is inapplicable for any modification made in a sentence before the end of the sentencing hearing." This interpretation gives trial courts flexibility to reconsider and adjust sentences during the hearing process while maintaining the rule's restrictions on post-imposition modifications.
The timing distinction established by the court addresses potential constitutional concerns about double jeopardy, which generally prohibits subjecting defendants to multiple punishments for the same offense. By holding that sentences are not "imposed" until the hearing concludes, the court avoided potential double jeopardy issues that could arise from increasing a sentence after it has been formally imposed.
The case originated in the Circuit Court for Prince George's County under case number C-16-CR-23-000311. Oral arguments were held Oct. 1, 2025, and the opinion was filed Nov. 24, 2025. The case was designated as No. 17 for the September Term 2025.
The court's seven justices participated in the decision, with Chief Judge Fader and Justices Watts, Booth, Biran, Gould, Eaves, and Killough hearing the case. Justice Killough authored the majority opinion.
The ruling provides clarity for trial courts across Maryland about their authority during sentencing proceedings. Defense attorneys and prosecutors now have clearer guidance about when sentences become final and when modifications remain permissible.
The decision also reinforces the importance of the temporal aspects of criminal procedure. By establishing that the entire sentencing proceeding must conclude before a sentence is considered "imposed," the court has created a clear demarcation point for applying various procedural rules and constitutional protections.
For practitioners, the ruling emphasizes that trial courts retain discretion to reconsider sentencing decisions throughout the hearing process. This could be particularly relevant in complex cases where new information emerges during victim impact statements, allocution by the defendant, or arguments by counsel.
The court's interpretation of Rule 4-345 aligns with the principle that criminal procedures should be clear and predictable while preserving judicial discretion within appropriate bounds. The ruling ensures that trial courts can fully consider all relevant factors before finalizing sentences without being constrained by premature application of modification restrictions.
The decision in *Reyes v. State* represents the latest guidance from Maryland's highest court on criminal sentencing procedures. The ruling joins other recent decisions that have clarified the scope of judicial authority in criminal cases and the application of procedural rules designed to protect defendants' rights while ensuring fair and consistent sentencing practices.
Legal observers note that the decision provides needed clarity about the intersection of Maryland Rule 4-345, double jeopardy protections, and trial court authority. The ruling should reduce uncertainty about when sentences become final and help prevent future appeals based on timing challenges to sentence modifications made during hearings.