RAMIE A. HALBROOK Missouri Cases

Ramie A. Halbrook appealed the trial court's written judgment ordering his sentences for voluntary manslaughter and armed criminal action to run consecutively, arguing it plainly erred because the oral pronouncement at sentencing did not specify consecutive sentences. The appellate court agreed, holding that an oral pronouncement controls where it materially differs from a written judgment, and silence in an oral pronouncement mandates concurrent sentences under Rule 29.09. The court reversed the judgment and remanded with directions to correct the written judgment to reflect concurrent sentences.