Justia Maryland Supreme Court Opinion Summaries

Articles Posted in September, 2011
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A jury convicted Appellant Jody Miles of first-degree felony murder and related offenses, including robbery with a deadly weapon and use of a handgun in the commission of a crime of violence. Miles was sentenced to death. The Court of Appeals affirmed Appellant's convictions and sentence. Miles subsequently filed a motion to correct an illegal sentence, arguing that he was entitled to a new sentencing hearing on the ground that the jury should have been instructed that a death sentence cannot be imposed unless every juror is persuaded beyond a reasonable doubt that the aggravating circumstances outweigh the mitigating circumstances. The circuit court denied the motion. The Court of Appeals affirmed, holding that Appellant was not entitled to a new sentencing hearing as Maryland's capital sentencing procedure did not violate the Sixth Amendment. View "Miles v. State" on Justia Law

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After a jury trial, Ronald Cox was convicted of multiple offenses related to a murder. The court of special appeals affirmed his convictions. The Court of Appeals granted Cox's petition for certiorari and affirmed, holding (1) the court of special appeals did not err in upholding the admission of hearsay testimony of a fellow inmate as (a) because the out-of-court statements were made voluntarily and were unprompted in casual conversation, they were not made with the primary purpose of creating an out-of-court substitute for trial testimony, and thus the statements were not testimonial and the Confrontation Clause did not bar their exclusion, and (b) the testimony was sufficiently attenuated from the taint of an earlier illegal search and arrest under the attenuation analysis set forth in Miles v. State, and (2) the evidence presented at trial was sufficient to allow a reasonable jury to find that Cox was guilty beyond a reasonable doubt. View "Cox v. State" on Justia Law

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After a jury trial, William Langley was convicted of first-degree murder, use of a handgun in the commission of a crime of violence, and wearing or carrying a handgun. The court of special appeals affirmed. At issue on appeal was whether the admission into evidence of a recording of a 911 call violated Langley's confrontation rights where the call was placed after the offense had been completed and the alleged perpetrator had left the scene and where the caller indicated that she was aware that the police had been notified and were in the process of responding. Upon applying the U.S. Supreme Court's recent Michigan v. Bryant to the facts of the case, the Court of Appeals affirmed, holding that the statements in the 911 tape were non-testimonial for Confrontation Clause purposes, and thus, Langley's right to confrontation was not infringed by the admission of the statements. View "Langley v. State" on Justia Law