Justia Maryland Supreme Court Opinion Summaries

A jury convicted Petitioner Anthony Miller of two counts of second degree murder. The court of special appeals affirmed. Petitioner then filed a petition for writ of certiorari. The question Petitioner presented was whether the lower courts erred by ruling admissible a handwriting expert's testimony that Petitioner might have written the victim's signature on an important questioned document and that fact prevented Petitioner's elimination as a suspect in the case. The Court of Appeals granted the writ and affirmed, holding that the lower courts did not err in their conclusions that the handwriting expert's testimony was admissible as (1) because an expert opinion regarding handwriting need not be based on absolute certainty in order to be admissible, Petitioner was not unfairly prejudiced by the testimony even though the expert was unable to express the definite opinion that petitioner had forged the victim' signature on the document; and (2) Petitioner was not unfairly prejudiced by what occurred during the expert's redirect examination as the questions the expert was asked on cross-examination "opened the door" to the opinion that was elicited on redirect examination. View "Miller v. State" on Justia Law

A jury convicted Appellant Jody Miles of first-degree felony murder and related offenses, including robbery with a deadly weapon and use of a handgun in the commission of a crime of violence. Miles was sentenced to death. The Court of Appeals affirmed Appellant's convictions and sentence. Miles subsequently filed a motion to correct an illegal sentence, arguing that he was entitled to a new sentencing hearing on the ground that the jury should have been instructed that a death sentence cannot be imposed unless every juror is persuaded beyond a reasonable doubt that the aggravating circumstances outweigh the mitigating circumstances. The circuit court denied the motion. The Court of Appeals affirmed, holding that Appellant was not entitled to a new sentencing hearing as Maryland's capital sentencing procedure did not violate the Sixth Amendment. View "Miles v. State" on Justia Law

After a jury trial, Ronald Cox was convicted of multiple offenses related to a murder. The court of special appeals affirmed his convictions. The Court of Appeals granted Cox's petition for certiorari and affirmed, holding (1) the court of special appeals did not err in upholding the admission of hearsay testimony of a fellow inmate as (a) because the out-of-court statements were made voluntarily and were unprompted in casual conversation, they were not made with the primary purpose of creating an out-of-court substitute for trial testimony, and thus the statements were not testimonial and the Confrontation Clause did not bar their exclusion, and (b) the testimony was sufficiently attenuated from the taint of an earlier illegal search and arrest under the attenuation analysis set forth in Miles v. State, and (2) the evidence presented at trial was sufficient to allow a reasonable jury to find that Cox was guilty beyond a reasonable doubt. View "Cox v. State" on Justia Law

After a jury trial, William Langley was convicted of first-degree murder, use of a handgun in the commission of a crime of violence, and wearing or carrying a handgun. The court of special appeals affirmed. At issue on appeal was whether the admission into evidence of a recording of a 911 call violated Langley's confrontation rights where the call was placed after the offense had been completed and the alleged perpetrator had left the scene and where the caller indicated that she was aware that the police had been notified and were in the process of responding. Upon applying the U.S. Supreme Court's recent Michigan v. Bryant to the facts of the case, the Court of Appeals affirmed, holding that the statements in the 911 tape were non-testimonial for Confrontation Clause purposes, and thus, Langley's right to confrontation was not infringed by the admission of the statements. View "Langley v. State" on Justia Law

Armardo Atkins was convicted of second degree assault in circuit court. On appeal, Atkins argued that the trial judge abused her discretion by instructing the jury that the State was not required to shoulder its burden of persuasion by the use of certain categories of demonstrative evidence. The court of appeals affirmed the convictions. The Supreme Court reversed, holding that the instruction that the State need not use certain investigative and scientific techniques violated Atkins's constitutional rights to due process and a fair trial because it resulted in a non-neutral commentary on the evidence, or lack thereof, invaded the province of the jury, and relieved the State of its burden to prove guilt beyond a reasonable doubt. Remanded for a new trial. View "Atkins v. State" on Justia Law

After responding to a domestic altercation between Mark Furda and his wife, police officers seized Furda's collection of weapons and transported Furda to the hospital for a mental health evaluation. Furda was later transferred to a behavioral health facility. Upon release, Furda requested the return of his firearms, which the trial court judge denied. Furda asked the judge to reconsider but purchased a new gun before the judge responded. When filling out the application to purchase the firearm, Furda certified, under penalty of perjury, that he had not been committed to a mental institution. Furda was later convicted of prejury and false information in a firearm application. The court of special appeals reversed the trial court's denial of Furda's motion for the return of his weapons but affirmed Furda's convictions. On review, the Court of Appeals affirmed, holding (1) in the State's required application to purchase a firearm, a question asking whether the applicant has ever been adjudicated mentally defective or has been committed to a mental institution was not impermissibly ambiguous; and (2) Furda knowingly and willfully answered that question falsely. View "Furda v. State" on Justia Law

After a jury trial, Kendall Northam was convicted of second degree murder and first degree assault. During the proceedings, Northam, who was represented by an assistant public defender, filed a pro se motion for change of venue that included a request for a court-appointed attorney. The motion was denied. On appeal, the court of special appeals held that Northam was entitled to a new trial on the ground that the circuit court had failed to comply with the requirements of Md. R. Crim. P. 4-215(e) by failing to permit Northam to explain the reasons for his request to discharge defense counsel. The Court of Appeals granted certiorari and reversed, holding that Northam waived his right to appellate review of the claim on the ground that he was not permitted to explain the reasons for requesting permission to discharge defense counsel. View "State v. Northam" on Justia Law

Respondent Perry Simms was charged with murder as well as various weapons charges. Before the trial, Simms filed a timely notice of alibi witnesses, listing the names of eleven individuals. Prior to admission, the notice was redacted so that it showed only the name of Simms's father. At trial, the notice was admitted into evidence by the State and submitted to the jury along with transcripts of jailhouse phone calls. The trial judge reasoned that the notice was probative evidence of guilt when considered in conjunction with the phone calls, in which Simms and other callers referred to people who could vouch for Simms's whereabouts on the night of the incident. The intermediate appellate court reversed and remanded the case for a new trial, holding that the circuit court abused its discretion by admitting, over objections, a redacted copy of the alibi notice and that the error was not harmless beyond a reasonable doubt. The Court of Appeals affirmed the judgment of the court of special appeals, holding that admission of the alibi notice was error and an abuse of discretion, and the error was not harmless. View "State v. Simms" on Justia Law

After a jury trial, Dedrick Wilkerson was found guilty of second-degree rape, second-degree assault, and false imprisonment. While investigating the crime, Wilkerson was placed in flex cuffs in his home and questioned for several minutes by detectives before he was advised of his Miranda rights. At trial, Wilkerson moved to suppress both his pre-advisement and post-advisement statements made during the interrogation. The trial judge suppressed the pre-advisement statements, finding the interrogation was custodial, and denied the motion with respect to the post-advisement statements. The court of special appeals affirmed Wilkerson's conviction, concluding that the interrogating officers did not engage in the two-step or pre-advisement warning question-first tactics prohibited in Missouri v. Seibert but holding that Wilkerson preserved his Seibert argument for appellate review. In the interest of justice, the Court of Appeals concluded that the appropriate disposition of the case was a limited remand to the circuit court so the record could be more fully developed on the possible Seibert contention and the trial court could make the appropriate findings. View "Wilkerson v. State" on Justia Law

Petitioner Warren Ballard was indicted on charges of first degree murder and related offenses. Ballard filed a motion to suppress a portion of what he disclosed during the latter half of his interrogation, arguing that, although he properly received Miranda warnings, he unequivocally invoked his right to counsel when he uttered the words, "You mind if I not say no more and just talk to an attorney about this" mid-way through the interrogation. The trial court denied the motion and later found Ballard guilty as charged. On appeal, the intermediate court of appeals affirmed, finding the trial court properly denied the suppression motion. The Court of Appeals reversed the judgment of the intermediate appellate court with instructions to reverse the judgments of the circuit court, holding that Ballard's statement constituted an unequivocal invocation of the right to counsel, and therefore, pursuant to Miranda and its progeny, the interrogating detective was required at that moment to cease all questioning. Because the state made substantive use of Ballard's statements made during the ensuing interrogation that should have been suppressed, the case was remanded for a new trial. View "Ballard v. State" on Justia Law