Justia Maryland Supreme Court Opinion Summaries

Defendant was charged with armed robbery. During trial, a DNA expert testified regarding the work of another DNA analyst. The expert was a supervisor in the same lab, reviewed the work of the other analyst, and came to his own conclusion that was consistent with the conclusion of the other analyst. The analyst herself, however, did not testify. The Court of Special Appeals concluded that the admission of the DNA case report without the analyst’s testimony violated Defendant’s ability to confront his accuser. The Court of Appeals affirmed, holding that the language “within a reasonable degree of scientific certainty” in the DNA report rendered the report testimonial within Williams v. Illinois. View "State v. Norton" on Justia Law

Defendant was charged with robbery with a dangerous weapon, conspiracy to commit robbery and first degree assault. During voir dire, the trial judge failed to accede to Defendant’s request that he be brought to the bench for conferences during voir dire. During one of those conferences, a juror who was questioned at the bench without Defendant’s presence was selected to serve on the jury. The Court of Special Appeals reversed Defendant’s conviction, concluding that his exclusion from bench conferences during voir dire was not harmless beyond a reasonable doubt. The Court of Appeals affirmed, holding that the judge’s error in failing to bring Defendant to the bench for conferences during voir dire was not harmless where the juror who was questioned at the bench without Defendant’s presence was selected to serve. View "State v. Yancey" on Justia Law

The State charged Petitioner with first-degree murder and other crimes. Petitioner moved to suppress a pretrial identification on the grounds that the identification was hearsay and inadmissible under the Confrontation Clause. The identification was made by the victim (“declarant”) two years before his death. The circuit court granted the motion to suppress, determining that the declarant’s identification of Defendant fell under the “dying declaration” exception to the rule against hearsay but was testimonial and inadmissible under the Confrontation Clause. The Court of Special Appeals reversed, concluding that the declarant made a dying declaration and that the Confrontation Clause does not apply to dying declarations. The Court of Appeals affirmed, holding (1) the State may appeal from a trial court’s exclusion of intangible evidence based on a determination that the evidence’s admission would be a constitutional violation; (2) the circuit court was correct in determining that the declarant’s identification of Defendant was a dying declaration; and (3) the Confrontation Clause is not applicable to dying declarations, and therefore, the Court need not address whether the declarant’s identification of Defendant was testimonial or non-testimonial. View "Hailes v. State" on Justia Law

After a retrial, Petitioner was found guilty of attempted second degree arson. Petitioner appealed, arguing that the prosecutor’s opening statement violated his privilege against self-incrimination guaranteed by the Fifth Amendment, Article 22 of the Maryland Declaration of Rights, and Md. Code Ann. Cts. & Jud. Proc. 9-107. Specifically, Petitioner asserted that the prosecutor violated his right to protection from adverse comment on his decision not to testify at trial by referring in opening statement to what Petitioner “will tell” the jury. The Court of Special Appeals affirmed. The Court of Appeals reversed, holding that the prosecutor’s remarks ran afoul of the prohibition against making an adverse comment upon a defendant’s failure to testify, and the error was not harmless. Remanded for a new trial. View "Simpson v. State" on Justia Law

This case arose out of the fatal shooting of Manuel Espina by Prince George’s County police officer Steven Jackson. Petitioners, Espina’s estate and family, filed suit against Respondents, Jackson and the County, alleging survival and wrongful death claims, as well as a claim on behalf of Espina’s son for a violation of his constitutional rights arising out of his treatment and arrest following Espina’s death. A jury returned a verdict against Respondents in the amount of $11,505,000. The trial court, looking to the Local Government Tort Claims Act’s (LGTCA) limits on liability, reduced the judgment entered against the County to $405,000 but left intact the full jury award as to Jackson. The Court of Special Appeals affirmed the judgment in part and reduced the award entered against the County to $400,000. The Court of Appeals affirmed, holding (1) the LGTCA, where applicable, limits the damages recoverable against a local government for violations of the state constitution; (2) applying the LGTCA damages cap to Petitioners’ constitutional tort claims violated neither Article 19 nor the supremacy of the state Constitution; and (3) the Court of Appeals correctly reduced Petitioners’ wrongful death and survivorship actions to an “individual claim” under the LGTCA. View "Espina v. Jackson" on Justia Law

Two security guards employed by SSA Security, Inc. and four of their confederates carried out a conspiracy to set fire to several homes. The resulting fires destroyed ten homes and damaged twelve others. Appellants asserted various civil claims against SSA and the five convicted arsonists, contending that the Maryland Security Guards Act (“Act”) section 19-501 established a basis for SSA’s strict liability for its employees’ intentional torts and civil rights violations. A federal district judge granted summary judgment in SSA’s favor as to the negligence claims and the claims premised on strict liability under section 19-501, concluding (1) section 19-501 was merely a codification of the common law and did not expand the doctrine of respondeat superior; and (2) any intentional acts of SSA’s employees were outside the scope of employment. Appellants appealed, arguing that the Act extends the vicarious liability of security guard agencies beyond the state common law doctrine of respondent superior. The federal appellate court certified a question of law to the Court of Appeals regarding the meaning of section 19-501. The Court answered that section 19-501 has the same meaning as Maryland’s common law doctrine of respondent superior. View "Antonio v. SSA Sec., Inc." on Justia Law

Appellant pled guilty to kidnapping and third-degree sexual offense. Defendant was sentenced to terms of imprisonment. Defendant also signed an order of probation, in which he agreed to the condition of obeying the probation agent’s lawful instructions. When Defendant was released under mandatory supervision, he agreed to comply “as directed” by his parole/probation agent with a sexual offender management program, which “may include…polygraph testing[.]” Defendant’s probation agent instructed Defendant to report for a polygraph examination, but Defendant did not report for the polygraph examination. The circuit court subsequently determined that Defendant violated the order of probation. The Court of Special Appeals reversed, holding that the probation agent’s instruction to report for a polygraph examination created a more onerous condition of probation that was outside the ambit of the conditions laid down by the sentencing court in violation of the separation of powers doctrine. The Court of Appeals reversed, holding that a probation agent’s instruction to comply with a condition of mandatory supervision is consistent with the separation of powers doctrine. View "State v. Callahan" on Justia Law

After a jury trial, Petitioners Traimne Allen and Howard Diggs were convicted of attempted first degree murder and related offenses stemming from a home invasion and robbery. Petitioners appealed, arguing that the trial court erred in excluding certain DNA “match” evidence. The Court of Special Appeals affirmed, concluding that the DNA match evidence was properly excluded. The Court of Appeals affirmed, holding that Md. Code Ann. Pub. Safety 2-510 prohibits the introduction at trial by a criminal defense of evidence of a DNA match to prove the identity of another individual without first establishing additional confirmatory testing and does not infringe upon a criminal defendant’s constitutional right to present a defense. View "Allen v. State" on Justia Law

After a jury trial, Defendant was convicted of first-degree rape and first-degree sexual offense. The court of appeals affirmed. Defendant filed a petition for a writ of certiorari, which the Court of Appeals granted, contending, among other things, that the trial judge lacked the authority to deny his motion to postpone because only a county administrative judge or that judge’s designee may deny a motion to postpone. The Court of Appeals affirmed, holding (1) a circuit court judge may deny a motion to postpone in a criminal case; (2) the trial judge did not abuse his discretion in denying the motion to postpone to obtain counsel and to review discovery materials; and (3) Defendant’s constitutional right to a speedy trial was not violated in this case. View "Howard v. State" on Justia Law

Two years after she was raped, the victim reported her suspicion that Petitioner was the rapist. Petitioner went to the police station for an interview but refused to provide a DNA sample. After Petitioner left the station, the police took swabs of the armrests of the chair in which he had sat and submitted those swabs for DNA analysis. That DNA sample matched DNA collected from the victim’s home on the day of the rape. Petitioner was charged with first-degree rape and related offenses. Petitioner filed a pre-trial motion seeking suppression of the DNA evidence. The suppression court denied the motion, concluding that Petitioner had no reasonable expectation of privacy in the DNA evidence left on the chair. The court of special appeals affirmed the denial of the suppression motion. Petitioner filed a petition for a writ of certiorari but conceded that the police lawfully obtained his genetic material from the armrests of the chair. The issue before the Court of appeals was whether law enforcement’s testing of the identifying loci within that DNA material was a search for purposes of the Fourth Amendment. The Court of Appeals affirmed, holding that the DNA testing at issue was not a search under the Fourth Amendment. View "Raynor v. State" on Justia Law