Justia Maryland Supreme Court Opinion Summaries

Petitioner was convicted of first-degree felony murder. Petitioner's defense at trial was that his participation in the crimes with which he was charged was coerced. Petitioner argued on appeal that the trial court's refusal to instruct the jury with respect to duress was error. The court of special appeals affirmed, rejecting, in the process, the State's argument that the defense of duress is not applicable to felony murder. The Supreme Court reversed, holding (1) in Maryland, duress is a defense to felony murder; but (2) to establish and be entitled to the defense of duress, a defendant need not first prove he attempted to stop or thwart the offense that he was compelled to commit. Remanded for a new trial. View "McMillan v. State" on Justia Law

At issue in this case was when "meaningful trial proceedings" begin for purposes of Md. Rule 4-215(e) regarding a defendant's request to discharge counsel. Defendant in this case requested to discharge counsel preceding voir dire the morning before trial. After roll call of the jury was taken, the judge excused the venire panel and allowed Petitioner to discharge counsel and proceed pro se. Defendant was tried and convicted. The court of special appeals affirmed, holding that, because meaningful trial proceedings had begun, Rule 4-215(e) did not apply to Defendant's request to discharge counsel. Therefore, the court of special appeals reviewed the trial judge's decision for abuse of discretion, finding none. The Court of Appeals affirmed, holding (1) the court of special appeals correctly held that once the venire panel was summoned to the courtroom, meaningful trial proceedings had begun; and (2) therefore, the court of appeals did not err in holding Rule 4-215(e) did not apply to Defendant's request to discharge his counsel. View "Marshall v. State" on Justia Law

Defendant was on probation for a drunken driving offense when his DNA was collected for a separate murder investigation. The DNA was taken from saliva that Defendant left on a straw in the course of complying with an alcohol monitoring program mandated by the terms of his probation. The DNA test resulted in incriminating evidence against Defendant. The State introduced the DNA and lab report into evidence, and Defendant was convicted of involuntary manslaughter. The court of special appeals affirmed, concluding that Defendant did not have a reasonable expectation of privacy in the testing straw or the DNA on it, and therefore, the seizure of Defendant's DNA without a warrant did not violate the Fourth Amendment. The Court of Appeals affirmed, holding (1) Defendant's Fourth Amendment rights were not violated when the State recovered his DNA from the straw utilized for the mandatory test; and (2) the evidence was sufficient to sustain Defendant's conviction. View "Corbin v. State" on Justia Law

Father filed for divorce from Mother. In that proceeding, the parties contested physical and legal custody of their daughters. Prior to the merits hearing, a circuit court judge ordered preparation by court-related personnel a custody investigation report to evaluate the custodial abilities of each parent. The report was completed one week before the merits hearing, and Mother's counsel was able to review the report for only ninety minutes. As a consequence, Mother's attorney moved to exclude the report. The circuit court denied the motion. The judge then granted a divorce and awarded custody of the children to Father with visitation to Mother. The court of special appeals affirmed. At issue on appeal was whether the circuit court's unwritten policy that limits counsel of record in child custody proceedings to viewing custody investigation reports only in person in the clerk's office during normal business hours was viable. Without affirming or reversing, the Court of Appeals remanded for supplementation of the record as to the full contours of the relevant policy. View "Sumpter v. Sumpter" on Justia Law

After a jury trial, Defendant was convicted of manslaughter by motor vehicle, participating in a race or speed contest, and failing to remain at the scene of an accident resulting in death. Defendant appealed, arguing that the trial court unduly restricted his counsel during closing argument by limiting which comparative standards of proof he could argue to the jury. The court of special appeals affirmed. The Court of Appeals affirmed because the trial court's refusal to allow a discussion of extraneous legal standards was not an abuse of its broad discretion in controlling the scope of closing argument so as to avoid potential confusion of the jury. View "Ingram v. State" on Justia Law

Respondent recorded a deed he had altered. At a bench trial, Respondent was convicted of counterfeiting pursuant to Md. Code Ann. Crim. Law 8-601. The court of special appeals reversed based on its conclusion that the evidence was insufficient to show an intent to defraud another. The Court of Appeals reversed and reinstated Respondent's conviction, holding (1) the trial's finding that Respondent had committed a fraud on the system of recordation satisfied the specific intent element of section 8-601 that a defendant have acted with the "intent to defraud another" because the fact that Respondent acted with the intent to defraud the system of deed recordation inherently reflected the intent to defraud anyone who would later seek to rely on the accuracy of the deed; and (2) Respondent did not act in good faith. View "State v. Neger" on Justia Law

Following his arrest at age sixteen, Petitioner was convicted of assault with intent to murder and other crimes even though the indictment returned by the Grand Jury did not charge assault with intent to murder. Petitioner did not raise this issue at trial, at sentencing, or on direct appeal. Not until sixteen years after his conviction did Petitioner file a motion to correct an illegal sentence, claiming that the trial court lacked the power to convict and sentence him for assault with intent to murder because that charge was not contained in the indictment. The circuit court denied the petition, and the court of special appeals affirmed. The Court of Appeals reversed the court of special appeals and vacated Petitioner's conviction and sentence for assault with intent to murder, holding (1) Petitioner's sentence for assault with intent to murder was illegal because that crime was not contained in the indictment returned by the Grand Jury; and (2) Petitioner's motion to correct and illegal sentence was timely because Maryland Rule 4-345(a) allows the trial court to correct an illegal sentence at any time. View "Johnson v. State" on Justia Law

This matter stemmed from an order of the circuit court granting Petitioner postconviction relief by vacating his conviction for first degree premeditated murder and leaving in place Petitioner's related convictions for felony murder and first degree rape. The court of special appeals reversed that order and reinstated Petitioner's conviction for first degree premeditated murder. The Court of Appeals granted Petitioner's writ for certiorari and the State's conditional cross-petition, holding (1) the court of appeals properly exercised jurisdiction when it decided the State's appeal; (2) Petitioner was not entitled to postconviction relief; and (3) the term-of-years Petitioner received for first degree premeditated murder, but not the sentence for first degree rape, was illegal and must be corrected on remand. Remanded. View "Greco v. State" on Justia Law

Petitioner Jerome Pinkney was convicted of second degree assault and sentenced to eighteen months imprisonment. Petitioner appealed, claiming that the trial court violated Maryland Rule 4-215(e) by failing to inform him of his right to discharge counsel and proceed to trial pro se. The intermediate appellate court affirmed, concluding that the trial judge was not required under the plain language and meaning of Rule 4-215(e) to inform Petitioner of the right to conduct his trial pro se in the absence of a statement by Petitioner reasonably indicating a desire to represent himself at trial. The Court of Appeals affirmed, holding that the trial judge was not required to inform Petitioner of his right to pro se representation in a situation where the trial court denied Petitioner's unmeritorious request to discharge trial counsel and petitioner made no statement that reasonably could be understood as indicating a desire to invoke the right to self-representation. View "Pinkney v. State" on Justia Law

In 1976, Petitioner Merle Unger was indicted for felony murder, armed robbery, and using a handgun in the commission of the felony. During the trial, the trial judge told the jury that all of the judge's instructions as to the law were advisory. In 1996, Unger filed a petition for postconviction relief, arguing that the judge's instructions at his 1976 trial violated his right to due process of law because they empowered jurors to ignore the law. The post-conviction trial court granted a new trial. The court of special appeals reversed, holding that because Unger did not object to the advisory instructions given in his case, he waived his right to receive postconviction relief. The Court of Appeals vacated the judgment of the court of special appeals and affirmed the circuit court's judgment, holding that the trial judge's instructions at Unger's trial, telling the jury that all of the court's instructions on legal matters were "merely advisory" were clearly in error, at least as applied to matters implicating federal constitutional rights. View "Unger v. State" on Justia Law