Justia Maryland Supreme Court Opinion Summaries

After a jury trial, Petitioner was convicted of multiple counts of second degree murder and other crimes. The court of appeals affirmed, concluding that the trial court erred in prohibiting Petitioner's cross-examination of a State's witness regarding the witness' expectation of leniency in a separate pending case should he testify against Petitioner but that the error was harmless. The Court of Appeals reversed, holding (1) the trial court erred in limiting Petitioner's cross-examination of the witness with regard to his expectation of leniency; and (2) contrary to the conclusion of the intermediate appellate court, the effect of that error was not harmless to the result of the trial. View "Dionas v. State" on Justia Law

Petitioner was convicted of second degree assault and sentenced to ten years in prison and three months probation. After Petitioner was sentenced, he tore up a copy of his probation papers while seated next to the exit door in the courtroom. Subsequently, while walking down a hall outside the courtroom, Petitioner threatened in front of a law enforcement officer to harm a witness/victim. The trial court revoked Petitioner's probation, determining that, through his actions, Petitioner committed direct criminal contempt of court and violated Md. Code Ann. Crim. Law 9-303(a), the retaliation statute. The court of special appeals affirmed. The Court of Appeals affirmed in part and reversed in part, holding (1) section 9-303(a) does not require communicating a threat to a victim/witness or a belief that the threat may be communicated to the victim/witness, and in this case, Petitioner committed a threat within the meaning of the statute; and (2) the record did not support a finding that Petitioner was in direct contempt of court when he tore up his personal copy of the probation papers following his sentencing. Remanded. View "Hammonds v. State" on Justia Law

After a jury trial in 1998, Appellant was convicted of murder and sentenced to death. In 2011, Appellant filed a second motion to correct an illegal sentence, claiming that his death sentence was unconstitutional and illegal under Article 16 of the Maryland Declaration of Rights, which provides that "sanguinary Laws ought to be avoided as far as is consistent with the safety of the State[.]" Appellant claimed that at the time the clause was adopted as Article 14 in 1776, a sanguinary law meant the death penalty for any crime, and therefore, Article 14 abrogated capital punishment for any offense that did not impact State security. The circuit court denied Appellant's motion. The Court of Appeals affirmed, holding (1) where death was the common law penalty for murder and the sanguinary laws clause applied only to legislative action, the death penalty was not abrogated by Article 14; and (2) if the sanguinary laws clause was retroactive, it was not intended to include death as a possible penalty for murder. View "Miles v. State" on Justia Law

After a jury trial, Petitioner was convicted of controlled substance and resisting arrest offenses. The court of special appeals affirmed, holding (1) the trial court did not violate Maryland Rule 4-215(e) by failing to respond to a letter Petitioner sent to the court prior to trial seeking to discharge his counsel; and (2) the evidence was sufficient to support Petitioner's conviction for resisting a lawful arrest. The Court of Appeals reversed in part and affirmed in part, holding (1) Petitioner's letter to the trial court was sufficient to trigger Rule 4-215(e), and the trial court's failure to inquire into the reasons behind Petitioner's request to discharge counsel was reversible error; and (2) the court of special appeals did not misinterpret Maryland's resisting arrest statute in finding that the evidence was sufficient to support Petitioner's conviction for resisting arrest. Remanded. View "Williams v. State" on Justia Law

Petitioner was charged with assault, reckless endangerment, firearms violations, and a drug-related offense. Petitioner sought to suppress detectives' observations during and after an investigatory stop of Petitioner on the ground that the stop violated the Fourth Amendment. The suppression court granted Petitioner's request, determining that the investigatory stop violated the Fourth Amendment because the detectives did not have a reasonable suspicion that Petitioner had committed a drug-related crime or a traffic infraction. The court of special appeals reversed. The Court of Appeals affirmed, holding that, although the suppression court correctly concluded that the series of acts the detectives observed were by themselves innocent, taken together, those acts supported the detectives' suspicion that Petitioner was engaged in criminal activity. View "Holt v. State" on Justia Law

Petitioner owned land in the Town of Goldsboro in Caroline County. Lake Bonnie provided the water source for the property, on which Petitioner operated a campground. In the mid-1990s, the Maryland Department of Environment (MDE) reported water quality impacts on Lake Bonnie due to failing septic systems in the Town and ordered the Town to take action regarding the septic systems. As of 2010, however, the Town had failed to comply with the order, and MDE had failed to enforce the order. Consequently, Lake Bonnie was polluted, the campground was destroyed, and the bank foreclosed on Petitioner's property. Petitioner sued the Town, County, MDE, and State, alleging several causes of action. All counts were dismissed against the Town, County, and State. The court of appeals affirmed. The Supreme Court affirmed in part and reversed in part, holding (1) because it was not clear from the face of her complaint that Petitioner's causes of action for negligence, trespass, and inverse condemnation were barred by limitations, the court of special appeals erred in affirming the motion to dismiss on those counts; and (2) Petitioner's causes of action for nuisance were barred by limitations, and the court of appeals correctly affirmed the motion to dismiss. View "Litz v. Md. Dep't of Env't" on Justia Law

Defendant was charged with murder and expressed a desire to have a bench trial. During the jury trial waiver colloquy, the trial judge provided Defendant with advice that the judge was not required to give Defendant and that was also erroneous. After a jury-waived trial, Defendant was convicted of first degree murder and sentenced to life imprisonment. Defendant appealed, arguing that his waiver of the right to a jury trial was not knowing and voluntary. The Court of Appeals reversed and remanded for a new trial, holding (1) the trial judge's erroneous advisement may have misled Defendant to believe a jury trial was a less attractive option than it actually was, thereby influencing Defendant's decision to waive his jury trial right; and (2) accordingly, the trial judge did not ensure that Defendant's waiver was knowing. View "Winters v. State" on Justia Law

In 1999, Petitioner pled guilty to a drug offense. Petitioner subsequently filed a petition for a writ of error coram nobis, asserting that his guilty plea was not voluntarily made due to his counsel's failure to advise him of the possible immigration consequences of his plea. The circuit court denied the petition. While Petitioner's appeal was pending, the U.S. Supreme Court decided Padilla v. Kentucky. On appeal, the court of special appeals determined that Padilla did not retroactively apply to vacate Petitioner's conviction. The Court of Appeals reversed. On remand, the court of special appeals again affirmed the denial of Petitioner's petition because Petitioner had not raised the issue of ineffective assistance of counsel in his plea. The Court of Appeals granted certiorari, but prior to oral argument, the U.S. Supreme Court held that Padilla did not apply retroactively. The Court of Appeals affirmed the denial of Petitioner's petition for coram nobis relief, holding that Petitioner's claims of involuntariness or ineffective assistance of counsel did not have independent state bases in Maryland in 1999. View "Miller v. State" on Justia Law

In 2003, Appellant was convicted of rape. The Court of Appeals reversed, holding that the Maryland DNA Collection Act, which permits law enforcement authorities to collect DNA samples from individuals arrested for certain crimes, violated the Fourth Amendment as applied to Appellant. The U.S. Supreme Court reversed, holding that the DNA search of Appellant did not violate his Fourth Amendment rights. On remand, Appellant asked the Court to consider the issues left unresolved by King I. The Court of Appeals held (1) the Maryland DNA Collection Act does not violate Article 26 of the Maryland Declaration of Rights; and (2) the trial judge did not improperly shift the burden of proof to the defense to demonstrate how the State failed to comply with the Act, and even if a statutory violation were proven, there was no reversible error. View "King v. State" on Justia Law

Plaintiffs, each of whom was arrested for a crime and brought before a District Court Commissioner for an initial appearance, filed a complaint against the District Court of Maryland and several court officials alleging that they were denied public defender representation during their initial appearance proceedings. Plaintiffs contended that the initial appearance proceeding is a critical stage of the criminal proceeding requiring state-furnished counsel pursuant to the Public Defender Act (Act) and that the failure to provide counsel violated their due process rights. The Court of Appeals held that the Act required the public defender to represent indigent criminal defendants at the initial appearance proceedings. While motions for reconsideration of the Court's opinion were pending, the General Assembly passed statutes amending the Act to provide that representation was not required to be furnished to an indigent individual at an initial appearance before a district court commissioner. The Court proceeded to hold that, under the due process component of the Maryland Declaration of Rights, an indigent defendant has a right to state-furnished counsel at an initial appearance before a district court commissioner. Remanded. View "DeWolfe v. Richmond " on Justia Law