Justia Maryland Supreme Court Opinion Summaries

In 2010, Respondent, a citizen of Ecuador, pled not guilty on an agreed statement of facts and was found guilty of second-degree child abuse. In 2013, Respondent filed a petition for writ of error coram nobis alleging that his trial counsel had rendered ineffective assistance by failing to advise him regarding the immigration consequences he could face as a result of conviction. The coram nobis court denied the petition. The Court of Special Appeals reversed and remanded, concluding that Respondent established that trial counsel did not provide him with the correct “available advice” about the risk of deportation. The Court of Appeals reversed, holding that trial counsel did not perform in a constitutionally deficient manner in advising Respondent as to the immigration consequences of a conviction for second-degree child abuse. View "State v. Sanmartin Prado" on Justia Law

In cases consolidated for this appeal, defendants were found guilty but not criminally responsible at the time of the commission of the offense and were committed to the Department of Health and Mental Hygiene. The court granted conditional releases on various occasions but each conditional release was subsequently revoked, resulting in recommitment to DHMH for treatment. The Maryland Court of Appeal held that the Circuit Court erred in determining that the statutory scheme, Criminal Procedure Article 3-114, for granting or revocation of the conditional release of a committed person violated the separation of powers provision found in Article 8 of the Maryland Declaration of Rights. The court also erred in revoking defendant’s conditional release and ordering his continued commitment for institutional inpatient care and treatment after the ALJ had found that defendant was eligible for conditional release and had recommended the same. The court held that under CP 3-114 the substantial evidence standard applies to a circuit court’s review of an ALJ’s findings of facts and recommendations. View "Stoddard v. State" on Justia Law

The Advice of Rights form assists law enforcement officers with making the advisements that are required by Md. Code, Transp. 16-205.1,2, (the implied consent, administrative per se law), which provides a basis for the automatic suspension of the licenses of drivers who refuse to submit to testing for alcohol and drugs. Seenath, a holder of a commercial driver’s license, argued that the Advice form violated due process under the U.S. Constitution and the Maryland Declaration of Rights because it does not advise that a holder of a commercial driver’s license who drives a non-commercial motor vehicle and fails an alcohol concentration test is ineligible for a “restrictive license,” which allows a driver to drive only for certain purposes, for example, in the course of employment. The Motor Vehicle Administration asked the Maryland Court of Appeal: “Does the standard Advice of Rights form (DR-15) provide the necessary information to a driver who holds a commercial driver’s license of the consequences of submitting to a test of blood alcohol content if the driver’s results are 0.08 or more?” That court responded “yes,” and held that the form is not misleading as to the eligibility for a restrictive license of a holder of a commercial driver’s license and comports with due process. View "Motor Vehicle Admin. v. Seenath" on Justia Law

After a joint jury trial, Petitioner was found guilty of second degree murder, conspiracy to commit murder, and use of a handgun in the commission of a crime of violence. The court of special appeals affirmed. Petitioners filed a petition for writ of certiorari, arguing that the prosecutor’s response to an allegation of racial and gender discrimination in the exercise of a peremptory challenge did not satisfy the requirement of Batson v. Kentucky that the State provide a specific explanation for each challenged strike which is racially, and with respect to gender, neutral. The Court of Appeals reversed, holding that the prosecutor’s explanation for striking the juror at issue, in addition to lacking the requisite specificity, violated Batson because the explanation was neither race- nor gender-neutral. Remanded for a new trial. View "Ray-Simmons v. State" on Justia Law

In 2012, the Maryland Department of Health and Mental Hygiene (DHMH) adopted new procedures regarding the application process for surgical abortion facilities, including the requirement that individuals and other entities obtain a license from the Secretary of DHMH before establishing or operating such a facility. In 2013, Petitioner, pursuant to the Public Information Act, requested the records of all applications submitted for a license under these regulations. DHMH responded by providing copies of the applications but with certain information redacted. DMHM filed a petition seeking judicial confirmation for its continued denial of the information. The circuit court granted the petition, indicating that DHMH’s decision to redact was made on the basis of public safety concerns for those individuals who proposed to operate the facilities. The court of special appeals affirmed. The Court of Appeals affirmed, holding that redaction and denial of the relevant information in this case was necessary to protect the public interest from a substantial injury. View "Glenn v. Dep’t of Health & Mental Hygiene" on Justia Law

Petitioner was convicted of first degree murder and sentenced to life imprisonment. The Court of Special Appeals affirmed. Two issues were presented in this appeal, first, whether Petitioner’s statement, “I don’t want to say nothing. I don’t know” was an ambiguous or clear invocation of his right to remain silent under Miranda, and second, whether Petitioner’s confession, given after he waived his Miranda rights, was voluntary or the product of inducement. The Court of Appeals affirmed, holding (1) Petitioner’s statement, “I don’t want to say nothing. I don’t know” was an ambiguous invocation of his right to remain silent; and (2) Petitioner’s confession was voluntary. View "Williams v. State" on Justia Law

In 2012, Petitioner voluntarily consented to a search of his person in the form of saliva and penile swabs for the purpose of furnishing DNA evidence to the police department to use in the investigation of a rape allegation. The DNA profile created from the extraction of Petitioner’s DNA excluded Defendant as a suspect of the alleged rape. Defendant’s DNA profile was subsequently uploaded to the local DNA database. Later, an automatic search resulted in a match between Defendant’s DNA profile and a DNA profile associated with an unsolved burglary committed in 2008. Based on that DNA evidence, Defendant was charged with burglary and related charges. Defendant moved to suppress the State’s DNA match evidence on the grounds that the subsequent use of his DNA to conduct a comparison search of the DNA databank exceeded the scope of his consent and therefore constituted an unlawful search under the Fourth Amendment. The suppression hearing judge denied the motion. The Court of Appeals affirmed, holding that, where Defendant’s consent to search was not expressly limited by him, the State, or the law, the Fourth Amendment did not preclude the police from retaining and using Defendant’s DNA profile created from his voluntarily provided DNA sample for additional, unrelated criminal investigations. View "Varriale v. State" on Justia Law

After a jury-waived trial, Petitioner was convicted of possession of oxycodone with intent to distribute. Petitioner appealed, arguing that he was entitled, by application of the rule established in Riley v. California, decided by the Supreme Court, to suppression of the evidence obtained as the result of the search of his cell phone incident to his lawful arrest. The Court of Appeals affirmed, holding that the officer who searched Petitioner’s cell phone acted in good faith on then-controlling authority in Maryland in searching Petitioner’s cell phone, and therefore, Petitioner was not entitled to have the cell phone data excluded at trial. View "Demby v. State" on Justia Law

Petitioner was convicted of possession with intent to distribute marijuana, possession of marijuana, and possession of drug paraphernalia. Petitioner appealed the denial of his motion to suppress text messages that the police obtained during the warrantless search of his cell phone incident to his lawful arrest. The Court of Appeals affirmed, holding that the trial court properly denied Petitioner’s motion to suppress the data obtained from his cell phone, as (1) in light of the U.S. Supreme Court’s decision in Riley v. California, officers must generally secure a warrant before conducting searches of data on cell phones; but (2) the police in this case acted in good faith on then-controlling authority in Maryland in searching Petitioner’s cell phone, and therefore, Petitioner was not entitled to suppression of the data obtained from his cell phone. View "Spence v. State" on Justia Law

Defendant was charged with carjacking and related offenses, various firearms offenses, and possession of illicit drugs. The morning of trial, Defendant’s attorney made an oral motion seeking to exclude evidence derived from a flip cell phone that was seized from Defendant incident to his arrest. The primary evidence obtained from the cell phone was a screen saver image that matched the custom wheel rims of the stolen car. The circuit court denied the motion to suppress. After a jury trial, Defendant was found guilty. The court of special appeals affirmed. Before the Court of Appeals, Defendant relied on the U.S. Supreme Court’s intervening decision in Riley v. California to argue that the arresting officer’s review of photos on Defendant’s cell phone without a warrant was an unconstitutional search, and therefore, the evidence derived from the cell phone should have been suppressed. The Supreme Court affirmed, holding (1) Defendant waived his motion to suppress by failing to make his motion within the time period and with the specificity required by the Maryland Rules; and (2) even had the motion been made in a timely manner, the screen saver image was admissible under Riley. View "Sinclair v. State" on Justia Law