Justia Maryland Supreme Court Opinion Summaries

After a jury trial, Petitioner Khiry Montay was convicted of first-degree felony murder and related offenses, including use of a handgun in the commission of a crime of violence. The court of special appeals affirmed. The Court of Appeals reversed, holding (1) Petitioner's confession, which was obtained when he was one month past his sixteenth birthday, should have been suppressed as involuntary for several reasons, including the fact that the police unnecessarily delayed presenting Petitioner to a district court commissioner in order to interrogate him and the fact that the police ignored thirteen requests by Petitioner to speak to his mother; and (2) Petitioner was entitled to a new trial at which the State was prohibited from introducing evidence of Petitioner's inculpatory statement. Remanded. View "Moore v. State" on Justia Law

Petitioner Mark Denisyuk, a noncitizen, pleaded guilty to a deportable offense. Petitioner later filed a petition for postconviction relief, asserting that defense counsel was constitutionally ineffective by failing to notify him of the deportation risks of his guilty plea. The postconviction court held that Petitioner was prejudiced by defense counsel's failure to provide proper advice concerning immigration consequences. The court of special appeals reversed, holding that deportation was a collateral consequence of a criminal conviction and therefore did not fall within the scope of the Sixth Amendment's guarantee of effective assistance of counsel. Two days later, the U.S. Supreme Court decided Padilla v. Kentucky, which held that it is ineffective assistance to disadvise, or fail to advise, a client that deportation is a likely consequence of the guilty plea. On review, the Court of Appeals vacated the court of special appeals, holding (1) Padilla applies to postconviction claims arising from guilty pleas obtained after the enactment of the Illegal Immigration Reform and Immigrant Responsibility Act of 1996; and (2) in this case, defense counsel's failure to advise Petitioner of the deportation consequence of his guilty plea was constitutionally deficient, and counsel's deficient performance prejudiced Petitioner. Remanded for a new trial. View "Denisyuk v. State" on Justia Law

After a jury trial, Petitioner William Briscoe was convicted of possessing a regulated firearm after having been convicted of, inter alia, possessing cocaine and wearing, carrying, or transporting a handgun in a vehicle. The convictions were based on evidence law enforcement officers recovered while searching Petitioner's vehicle and glove compartment at the time of his arrest. Petitioner sought suppression of the handgun, claiming it was the fruit of an illegal search. The circuit court denied the motion. While Defendant's appeal was pending, the Supreme Court decided Arizona v. Gant. The State conceded that, under Gant, the search violated the Fourth Amendment but argued that Petitioner was not entitled to suppression by application of the good-faith exception to the Fourth Amendment's exclusionary rule. The court of special appeals did not reach the Gant issue, holding instead that the handgun was recovered during a valid inventory search. The Court of Appeals affirmed but on different grounds, holding (1) the search of the glove compartment was not a valid inventory search, but (2) the good-faith exception to the exclusionary rule applied to what, at the time, was a lawful search of the glove compartment. View "Briscoe v. State" on Justia Law

Petitioner Christopher Mansfield was tried in a bench trial at the circuit court on five counts charging statutory sex-related offenses. At the close of the evidence, the trial judge, sua sponte and over Petitioner's objection, declared a mistrial, explaining that her knowledge of Petitioner's prior convictions and the partiality it engendered made a mistrial manifestly necessary. Petitioner moved to dismiss the indictment on double jeopardy grounds, arguing that there was not manifest necessity for the granting of the mistrial where the trial judge had knowing of Petitioner's prior convictions well before the trial began. The motions judge and the court of special appeals upheld the decision. The Court of Appeals reversed, holding that under these circumstances, when it is the court that is the trier of facts, and the court's impartiality, whether due to a personal bias or prejudice toward a criminal defendant or an inability to resolve disputed factual allegations, is impaired, manifest necessity does not exist when the reasonable alternative of recusal existed prior to jeopardy attaching. Remanded. View "Mansfield v. State" on Justia Law

Petitioners were nonresidents who neither lived nor worked in Maryland but had a source of income in the State. In 2005, the Comptroller of the Treasury issued a notice of assessment against Petitioners' 2004 joint Maryland nonresident income tax returns for failure to pay the Special Nonresident Tax (SNRT). The assessment included the amount owed for the SNRT and interest. Petitioners challenged, on federal and state constitutional grounds, the State's authority to impose the SNRT. The tax court (1) declared the SNRT to be constitutional, and (2) denied Petitioners' request to abate the accrued interest, reasoning that the court lacked the authority to do so. The circuit court affirmed as to the constitutionality of the tax but determined that the tax court could abate the interest assessment. The court of special appeals affirmed. The Court of Appeals affirmed, holding (1) the SNRT does not violate the Commerce Clause, the Equal Protection Clause, or the Privileged and Immunities Clause of the U.S. Constitution; (2) the SNRT does not violate Maryland's equal protection doctrine; and (3) the tax court's power of review extends to the abatement of interest assessments. Remanded to consider whether Petitioners were entitled to the abatement of interest. View "Frey v. Comptroller of the Treasury" on Justia Law

Appellant Norman Derr was convicted of multiple sexual offenses in circuit court. On appeal, Derr challenged the admission of forensic evidence introduced at trial through the testimony of an expert witness who did not take part in or observe the physical testing of the evidence or independently determine the test results. At issue on appeal was whether the admission of the evidence and the testimony of the expert witness violated Derr's constitutional right to confrontation. The Court of Appeals reversed, holding (1) a testimonial statement may not be introduced into evidence without the in-court testimony of the declarant, unless the declarant is unavailable and the defendant had a prior opportunity to cross-examine the witness; and (2) the trial judge in this case erred in admitting the results of scientific testing through a surrogate analyst who did not, on the basis of the record, perform or observe the actual testing. View "Derr v. State" on Justia Law

A jury convicted Petitioner Robert Thomas of carrying a handgun. Petitioner appealed, contending that the trial court erred in not allowing him to impeach a State's witness's testimony with evidence of either the witness's prior conviction or the conduct underlying that conviction. The court of special appeals affirmed the judgment of conviction, concluding that the trial court did not abuse its discretion in disallowing either form of impeachment evidence. The Court of Appeals reversed in part and affirmed in part, holding the trial court (1) did not err or abuse its discretion in refusing to allow Petitioner to make impeachment use of the witness's prior conviction, but (2) committed reversible error in denying Petitioner's request to make impeachment use of the conduct underlying the prior conviction. Remanded for a new trial. View "Thomas v. State" on Justia Law

In 1974, Appellant Douglas Arey was convicted of first-degree murder and use of a handgun in the commission of a felony. In 2002, Arey filed a petition for postconviction DNA testing of evidence related to his conviction. The circuit court dismissed the petition, concluding that the evidence related to Arey's conviction no longer existed. The Court of Appeals reversed the dismissal of Arey's petition, holding (1) the circuit court's ruling that the State had performed a reasonable search for biological evidence relating to Arey's conviction was premature; and (2) the circuit court erred in ruling on Arey's petition for testing only two days after the State submitted an affidavit from a key witness because the court's ruling did not give Arey a reasonable opportunity to respond to the factual allegations contained in that affidavit prior to dismissal. Remanded. View "Arey v. State" on Justia Law

Petitioner Enrique Silva was convicted by a jury of two counts of first-degree premeditated murder. At trial, the State called three witnesses who were present at the crime scene, one of whom was an admitted accomplice to the murders. The other two witnesses denied involvement in the crime. The trial court denied Petitioners' request to instruct the jury that the two witnesses denying involvement were accomplices as a matter of law and, consequently, their testimony linking Petitioner to the murders required corroboration in order to be credited. The court of appeals affirmed the convictions, holding that the trial court correctly denied Petitioners' requested jury instruction. The Court of Appeals granted certiorari and affirmed, holding that Petitioner was not entitled to the requested instruction. View "Silva v. State" on Justia Law

A jury convicted Petitioners Cyrus Beads and Joseph Smith of several crimes against the person of three victims as well as several related offenses, including use of a handgun in the commission of a crime of violence. The court of special appeals consolidated Petitioners' appeals and affirmed their convictions. The Supreme Court reversed, holding (1) the trial court erroneously overruled objections to unfairly prejudicial comments made by the prosecutor, (2) the trial court erroneously concluded that the cross-examination of Smith's trial counsel "opened" the door to testimony that Smith had previously been incarcerated, and (3) because the trial court failed to take any corrective actions in response to the improper arguments and inadmissible evidence, these erroneous rulings were not harmless. Remanded for a new trial. View "Beads v. State" on Justia Law