I am writing pursuant to rule 24(i), Utah Rules of Appellate Procedure, to advise the Court of authority relevant to the above-referenced case that recently came to my attention. The following cases relate to defendant's claim that the trial court was without jurisdiction when it resentenced him while the case was on appeal. These cases support the State's argument that a sentence imposed on an unrepresented defendant is illegal and may be corrected by the trial court at any time under rule 22(e), Utah Rules of Appellate Procedure:
Public record document (some rights may be reserved).
Legal Brief, State v. Angelos, No. 20010509 (Utah Court of Appeals, 2001).