Cragg v. State

In Cragg v. State, 957 P.2d 1365, 1368 (Alaska App. 1998), the Court addressed the issue of suspended imprisonment in the context of AS 12.55.120(a). This statute declares that a defendant has no right to pursue a sentence appeal unless their composite time to serve exceeds 2 years for a felony, or 120 days for a misdemeanor. In Cragg, the Court rejected the argument that a substantial term of suspended imprisonment could trigger a right of sentence appeal: we held that a defendant has no right to pursue a sentence appeal if the defendant's time to serve is less than the statutory minimum, even though the defendant's total sentence (including suspended time) is greater than the statutory minimum.