Justia Maryland Supreme Court Opinion Summaries

In 1995, Petitioner was convicted of first-degree murder and the use of a firearm in the commission of a felony. In 2006, the Supreme Court determined in Clemons v. State that, under the Frye-Reed standard, Comparative Bullet Lead Analysis (CBLA) evidence was not generally accepted by the scientific community. Within a few years of his conviction, Petitioner sought post-conviction relief, arguing that the admission of “unreliable” CBLA evidence during his trial in the form of testimony from Agent Ernest Peele of the Federal Bureau of Investigation constituted a due process violation and that his attorneys provided ineffective assistance for failing adequately to cross-examine Agent Peele. The circuit judge denied relief, and the court of special appeals affirmed. The Court of Appeals reversed Petitioner’s conviction and remanded for a new trial, holding that Petitioner’s attorneys rendered ineffective assistance when they failed to investigate a report Peele co-authored in 1991 that presaged the flaws in CBLA evidence and to challenge the State’s scientific evidence on cross-examination at trial. View "Kulbicki v. State" on Justia Law

Appellant owned property located within the heart of a planned development. The City of Baltimore sought to condemn the property. When the City and Appellant were unable to agree upon a price to be paid for the property, the City filed a petition for condemnation. Prior to trial, the City filed a petition for immediate possession and title, alleging that immediate possession of the property was necessary. Ultimately, the circuit court concluded that Appellant was a “hold-out,” which justified a “quick-take” condemnation of the property. The Court of Appeals affirmed, holding that the facts of this case justified a “quick-take” condemnation action. View "Makowski v. Mayor & City of Baltimore" on Justia Law

After a jury trial, Defendant was convicted of first degree murder and the use of a handgun in the commission of a crime of violence. According to the State's theory of the case, Defendant was a hit man for the Black Guerilla Family gang (BGF) and was ordered by his gang boss to kill the victim. During trial, several witnesses testified that the murder was related to Defendant's affiliation with the BGF. The court of special appeals affirmed. The Court of Appeals reversed and remanded for a new trial, holding that the trial court abused its discretion in allowing a "gang expert" to opine as to the nature of gangs in general, the BGF specifically, and the import of Defendant's tattoos towards establishing that he was a member of a gang, as the probative value of the expert's testimony was substantially outweighed by unfair prejudice, and this error was not harmless.View "Burris v. State" on Justia Law

Defendants in this case were charged with criminal offenses, and both defendants waived their right to a jury trial. After bench trials, Defendants were found guilty and sentenced. Each defendant appealed, challenging the trial court’s acceptance of his jury trial waiver. Relevant to this consolidated appeal, the courts of special appeals held that the trial courts sufficiently satisfied the announcement requirement under Md. Rule 4-246(b). The Court of Appeals reversed in part, holding (1) so long as a trial judge determines that a jury trial waiver is made both “knowingly” and “voluntarily,” or uses synonyms that represent the same concepts, the court will have complied fully with Rule 4-246(b); (2) in both cases under review, the trial judges failed to comply with Rule 4-246(b); and (3) to the extent that Valonis v. State could be read to hold that a trial judge’s alleged noncompliance with Rule 4-246(b) is reviewable by the appellate courts despite the failure to object at trial, that interpretation is disavowed. Remanded for new trials. View "Nalls v. State" on Justia Law

Petitioner was charged with two counts each of possession of cocaine and distribution of cocaine. On the day of trial, Petitioner waived his right to a jury. Petitioner then pled not guilty as to one of the distribution charges. After a plea colloquy, the trial court found the plea to be “knowing and voluntary.” Petitioner was found guilty of distribution of cocaine after a bench trial. Petitioner appealed, contesting the validity of the court’s acceptance of his jury trial waiver. The court of special appeals affirmed. The Court of Appeals affirmed, holding that the trial court’s announcement after the plea colloquy that Petitioner’s actions were “knowing and voluntary” was sufficient to establish that the judge analyzed the disposition and appearance of Petitioner in order to determine Petitioner’s actual understanding and voluntariness for both the jury waiver and the plea. View "Morgan v. State" on Justia Law

After a bench trial, Defendant was convicted of first, third, and fourth degree burglary, theft under $1000, and malicious destruction of property having a value of less than $500. Defendant appealed, challenging the trial judge’s acceptance of his jury trial waiver. The court of special appeals affirmed, concluding that the trial judge sufficiently satisfied the announcement requirement under Md. Rule 4-246(b). The Court of Appeals reversed, holding (1) because the trial judge’s announcement did not state that Defendant’s jury trial waiver was both knowing and voluntary, the judge did not comply with Rule 4-246(b); and (2) the appropriate sanction for the judge’s noncompliance with Rule 4-246 was reversal. View "Szwed v. State" on Justia Law

After a jury trial, Petitioner, a dentist, was convicted of various sexual crimes against a minor patient. In the circuit court, while self-represented, Petitioner filed a petition for DNA testing, requesting that the clothes the victim wore on the day of her rape be tested. After a hearing, the circuit court denied the petition. Petitioner appealed, arguing that, under Maryland Rule 4-707(b), he was entitled to appointed counsel at the hearing on the petition. The Court of Appeals affirmed, holding (1) Rule 4-707(b) does not entitle an indigent petitioner to be appointed counsel for the purposes of a petition under Md. Code Ann. Crim. Proc. 8-201; (2) the circuit court did not abuse its discretion in not considering whether to appoint counsel for Defendant for purposes of the petition under section 8-201; and (3) the circuit court applied the correct standard in ruling on the petition under section 8-201. View "Fuster v. State" on Justia Law

Petitioner was charged with conspiracy to commit theft, making a false statement to the police while under arrest, and related offenses after the vehicle in which he was an occupant was stopped by police officers and the police discovered multiple fake credit cards in the wallet of a female passenger. The police then arrested all occupants of the vehicle. Petitioner filed a motion to suppress, contending that the evidence was obtained as a result of an illegal stop. The circuit court denied the motion to suppress. Defendant appealed, contending that his Fourth Amendment rights were violated because the police lacked probable cause to arrest him. The court of special appeals held that police had probable cause to arrest Petitioner and therefore any evidence obtained by police as the fruit of that arrest was not subject to suppression. The Supreme Court affirmed, holding that Petitioner's claim was not properly before the appellate courts because Petitioner waived it by not raising it before the circuit court.View "Ray v. State" on Justia Law

Appellees in this case were seventeen-year-olds who would have been eighteen by the 2008 general election. After exhausting their administrative remedies, Plaintiffs filed separate complaints in the circuit court against the Maryland State Boar of Elections (MSBE), alleging that the MSBE violated several provisions of the Election Law Article by prohibiting seventeen-year-olds who would be eighteen by the next general election from casting any votes in non-partisan primary elections for county school boards. The circuit court concluded that the voter eligibility requirements of the Maryland Constitution did not apply to non-partisan elections for Boards of Education, municipal elections, and local ballot questions not mandated by the Constitution. The Court of Appeals vacated the circuit court and held that seventeen-year-olds who will turn eighteen by close of voter registration before the next general election were constitutionally and statutorily entitled to vote in primary elections, whether partisan or non-partisan, subject to all other provisions of the Constitution and statutory election law. Remanded.View "State Bd. of Elections v. Snyder" on Justia Law

The supervisory employee exception to the handgun law allows such an employee to carry a handgun, with the employer's permission, within the enclosed premises of the business in which the employee works. Petitioner, the head of security for a nightclub, was arrested by the county police for carrying a handgun without a permit in the open parking lot of the nightclub. Petitioner filed a lawsuit against the county and three of the police officers involved in his arrest for a violation of the Maryland Declaration of Rights, false arrest and imprisonment, and malicious prosecution, contending that his arrest was illegal because the parking lot should be considered to be "within the confines" of the nightclub. A jury found in favor of Petitioner on his state constitutional claim and on the false arrest and imprisonment claim. The court of special appeals reversed, holding that the parking lot of the club was not "within the confines of the business establishment." The Court of Appeals affirmed, holding that when Petitioner left the "confines" of the nightclub and took his handgun into the parking lot, he was no longer with the supervisory employee exception to the handgun law.View "Blue v. Prince George's County" on Justia Law