People v. Lake

Court changed mandatory supervised release (MSR) term in a criminal sentencing order nunc pro tunc, without prior notice to Defendant, 4 years after final judgment. Court's order changing sentencing order is void and must be vacated. Court did not have jurisdiction to sua sponte change order as more than 30 days had passed from entry of final judgment.The revestment doctrine does not apply, despite parties appearing in court after the nunc pro tunc order was entered, because both parties were not present and thus they did not actively participate in proceedings in which court sua sponte entered the nunc pro tunc order. (GRIFFIN and HYMAN, concurring.)