Justia Maryland Supreme Court Opinion Summaries

After a jury trial, petitioner Ricky Savoy was convicted of involuntary manslaughter, use of a handgun in the commission of a crime of violence, and carrying a handgun. Petitioner appealed, arguing that the trial court's instruction to the jury on the standard of proof violated due process by reducing the state's burden of proof to below the constitutionally-required standard of proof beyond a reasonable doubt. Petitioner made no objection to the instruction at trial and argued to the court of special appeals that the erroneous instruction was a structural error that is per se reversible, even in the absence of a contemporaneous objection. He argued, alternatively, that the intermediate appellate court should reverse the judgments on the basis of plain error, as permitted by Maryland Rule 4-325(e). The intermediate appellate court affirmed. On appeal, the Supreme Court vacated and remanded the case for a new trial, holding (1) that the intermediate appellate court erred when it held that the reasonable doubt instructions did not constitute structural error or violate petitioner's fundamental right to a fair trial; and (2) this case was appropriate for the exercise of plain error review. View "Savoy v. State" on Justia Law

Petitioner Raymond Lupfer was convicted of second-degree murder, first-degree assault, and use of a handgun in a crime of violence. During the trial, the prosecution elicited testimony regarding the fact that Lupfer remained silent after he was arrested and advised of his Miranda rights. Petitioner appealed. The intermediate appellate court affirmed, explaining that a defendant's post-arrest, post-Miranda silence is permissible where the silence is introduced for the limited purpose of rebutting an impression created by the defendant that defendant cooperated fully with the police. The Supreme Court reversed and remanded, holding that because Lupfer did not open the door sufficiently under the open door doctrine with his statements at trial regarding his pre-arrest actions and intentions, the state was not entitled to elicit testimony regarding his post-arrest, post-Miranda silence. The Court concluded that when the prosecution elicits such evidence to rebut an implication that the defendant merely intended, at some undetermined point in the future, to cooperate with police, the probative value of such evidence is dwarfed by the danger of unfair prejudice. View "Lupfer v. State" on Justia Law