Bishop v. Municipality of Anchorage

In Bishop v. Municipality of Anchorage, 685 P.2d 103 (Alaska App. 1984) the Court explained the term "illegal sentence": The term "illegal sentence" has been narrowly construed. It applies only to sentences which the judgment of conviction did not authorize. Examples of illegal sentences would be: (1) a sentence that was contrary to the applicable statute, i.e., in excess of the statutory penalty; (2) a written judgment not conforming to the oral pronouncement of sentence; or; (3) "a sentence that is ambiguous with respect to the time and manner in which it is to be served." Rule 35(a) does not permit consideration of matters outside the sentencing record, nor does it authorize a collateral attack on the proceedings which resulted in the sentence imposed. (Id. at 105.)