Justia Maryland Supreme Court Opinion Summaries

After being pulled over for a routine traffic stop, Petitioner Tyrone Smith was convicted of driving without a license. Petitioner was convicted under Md. Code Ann, Transp. 16-101(a) (the statute), which contains three parts. Petitioner appealed, claiming that the State must prove all three parts of the statute as elements of the offense beyond a reasonable doubt. The Court of Appeals affirmed, holding that the State need only prove the first part of the statute to convicted a defendant of driving without a license, and that the second and third parts are affirmative defenses that must be raised by a defendant. View "Smith v. State" on Justia Law

Petitioner Elliott McClain was convicted by a jury of first degree murder and related offenses. At trial, the State offered into evidence an audiotape of a prior statement by a State's witness without explicitly offering at that time a theory for its admission. The trial court admitted that audiotape, reasoning that it was admissible as either a prior consistent statement or a prior inconsistent statement. The Court of Appeals affirmed, holding that the trial court did not err (1) in admitting the audiotape statement as a prior inconsistent statement pursuant to Md. R. Evid. 5.802.1(a); and (2) in sending to the jury room during deliberations, absent a specific request from the jury, the audiotape statement of the witness and other prior audiotape statements that were admitted into evidence. View "McClain v. State" on Justia Law

Md. R. Evid. 5-804(b)(1) allows for the admission of "former testimony" hearsay when the party against whom the declarant's statement is offered had an opportunity to develop the testimony at a prior action or proceeding. Petitioner Leon Dulyx was found guilty by a jury of aiding and abetting a robbery and aiding and abetting theft under $500. Petitioner appealed, contending that the circuit court erred under Rule 5-804(b)(1) and the Confrontation Clause in allowing the State to introduce at trial testimony of a witness taken during a pre-trial hearing to suppress the witness's extrajudicial identification of Petitioner. The court of special appeals affirmed the judgments. The Court of Appeals reversed, holding that the court of special appeals erred when it held that Petitioner was given a "full and fair opportunity" to cross-examine the witness despite substantial limitations placed on Petitioner's ability to question him. Consequently, the witness's testimony at that hearing was not admissible at Petitioner's trial under the "former testimony" hearsay exception. Remanded. View "Dulyx v. State" on Justia Law

Petitioner Charles Phillips was arrested and subjected to a custodial interrogation. After about forty-five minutes of conversation, Petitioner expressed a desire to consult with an attorney. Following that expression, a police detective continued to engage Petitioner in conversation, during which Petitioner indicated a desire to continue talking to the detective and ultimately made a number of incriminating statements. Petitioner was subsequently convicted of first degree murder and armed robbery. The court of special appeals affirmed. The Supreme Court granted Petitioner's petition for certiorari to determine whether his inculpatory statements were elicited in violation of Edwards v. Arizona. The Court of Appeals reversed, holding that the conversation that ensued after Petitioner's invocation of his right to an attorney constituted a prohibited interrogation, and thus, Petitioner's inculpatory statements should have been suppressed. View "Phillips v. State" on Justia Law

In his sixth time before the court of appeals, Anthony Grandison, a prisoner on death row for his role in a pair of 1983 murders, presented various requests for relief. Grandison's previous appeals resulted in one order denying an appeal and four published opinions. Grandison subsequently filed numerous motions, the majority of which the circuit court dismissed. The court did grant Grandison's motion to fire two appointed attorneys, and Grandison proceeded pro se for part of the collateral proceedings. Grandison then argued that he had a right to counsel for those proceedings and requested that he be appointed counsel so that he could go back and litigate the denied collateral claims with the benefit of counsel. Grandison also appealed the denial of his various motions. The Supreme Court (1) held Grandison did not have a right to counsel during the collateral proceedings, and the circuit court did not err or abuse its discretion in allowing Grandison to discharge counsel and continue pro se; and (2) affirmed the denial and dismissal of Grandison's motions by the circuit court. View "Grandison v. State" on Justia Law

In 1990, Appellant Michael Washington was convicted by a jury of first degree rape and related offenses and was sentenced to life in prison. Appellant later petitioned for a search for DNA material pursuant to Md. Code Ann. Crim. Proc. 8-201, after which the sheriff's office conceded it had destroyed biological evidence relating to Appellant's conviction. A hearing judge denied Appellant's subsequent petitions relating to this destruction of evidence. The Supreme Court affirmed, holding (1) the lower court did not err in finding that the State performed a reasonable search for the requested biological identification; (2) the State's duty to preserve scientific identification evidence, pursuant to section 8-201(j) begins as of the date the statute was enacted and is not to be applied retroactively; (3) because the hearing judge did not err in determining that the scientific identification evidence was destroyed prior to the enactment date of the statute, the statute was not applicable and Appellant was not entitled to the relief provided; and (4) the lower court did not err in finding that Appellant's conviction did not rest upon unreliable scientific identification evidence and denying Washington's motion for a new trial on that basis. View "Washington v. State" on Justia Law

Petitioner Elroy Matthews invoked Md. Rule 4-345(a) to challenge the legality of the sentence he received following his plea of guilty to certain charges as part of a plea agreement. Petitioner argued that the sentence was illegal because it exceeded the sentence to which the court had bound itself. The circuit court denied the motion without a hearing. The court of special appeals held that a challenge to the legality of a sentence on the ground that it violates a binding term of a plea agreement is not cognizable under Rule 4-345(a), and even if it were, the sentence Petitioner received was not illegal. The Court of Appeals reversed, holding (1) Rule 4-345(a) is an appropriate vehicle for challenging a sentence that is imposed in violation of a plea agreement to which the sentencing court bound itself; and (2) the sentence Petitioner was serving was illegal because it exceeded the sentencing cap to which the circuit court agreed to be bound. Remanded for resentencing. View "Matthews v. State" on Justia Law

A police officer was dispatched to investigate a two-car collision, where she determined that one of the cars involved in the collision was owned by Respondent, Dana Carpenter. After a post-crash investigation, the officer requested Carpenter to submit to a chemical breath test, and Carpenter refused. Following a hearing, an administrative law judge (ALJ) suspended Carpenter's license for refusal to submit to the breath test. The circuit court reversed the suspension, determining that the police officer did not possess reasonable grounds to detain Carpenter. The Court of Appeals reversed the district court, holding that, pursuant to Md. Code Ann. Transp. 16-205.1(b)(2), the ALJ's determination that the police officer had reasonable grounds to detain Carpenter was supported by substantial evidence and was not premised upon an erroneous conclusion of law. Remanded with directions to affirm the decision of the ALJ. View "Motor Vehicle Admin. v. Carpenter" on Justia Law

After three separate trials for several criminal offenses, Appellant Benoit Tshiwala was sentenced to an aggregate of seventy years in prison. Appellant subsequently filed an application for review of his sentences, and a three-judge review panel reduced the total period of imprisonment to thirty-nine years. Thereafter, Appellant filed a motion for reconsideration of sentence, which was denied. Appellant then instituted the present action by filing a motion to correct an illegal sentence pursuant to Md. R. Crim. P. 4-345(a), alleging that the three judges who denied reconsideration were not authorized to rule on the motion. The circuit court denied Appellant's motion to correct an illegal sentence. The Supreme Court affirmed, holding that Tshiwala's claim was not cognizable under a motion to correct an illegal sentence because Tshiwala's claim did not involve an "illegal sentence" within the meaning of Rule 4-345(a). View "Tshiwala v. State" on Justia Law

Plaintiffs, each of whom was arrested for a crime that qualified as a serious offense and requested an attorney to represent him or her at the initial appearance, sought a declaration that they and the class of indigent persons they represented had the right, under the federal and state constitutions and the Public Defender Act, to be represented by the public defender at bail hearings, which were conducted as part of the initial appearance before commissioners at the central booking jail. The circuit court granted summary judgment for Plaintiffs, entered a declaratory judgment, and denied Plaintiffs' request for an injunction to enforce the rights declared. The Court of Appeals affirmed, holding (1) the bail hearing that occurs at the initial appearance before a Commissioner is a stage of the criminal proceeding under the Act; and (2) consequently, if a defendant qualifies for public defender representation, a bail hearing may not occur at the initial appearance unless the defendant has been afforded appointed counsel or waived the right to counsel. View "DeWolfe v. Richmond" on Justia Law