Justia Maryland Supreme Court Opinion Summaries

Respondent Jeffrey Allen was twice tried and convicted on charges related to the robbery and murder of John Butler. Respondent was retried after the Court of Appeals affirmed the holding of the court of special appeals that Respondent was entitled to a new trial on the charge of felony murder. On retrial, the jury found Respondent guilty of first degree felony murder. Respondent argued on appeal that the trial court erred when it informed the jurors about his prior murder and robbery convictions, contending that the court's instructions amounted to the use of collateral estoppel against him. The court of special appeals agreed and reversed the felony murder conviction. The Court of Appeals affirmed, concluding that when the trial court informed the jury of Respondent's prior convictions, the court necessarily informed the jury that those two elements of felony murder were established as a murder of law, and thereby withdrew from the jury any consideration of them, which impermissibly estopped litigation on ultimate facts necessary to a finding that Respondent committed the crime charged, thereby impairing the function of the jury and depriving Respondent of his constitutional right to a trial by jury. Remanded for a new trial. View "State v. Allen" on Justia Law

Petitioner Erik Stoddard was convicted by a jury of child abuse resulting in the death of a child and manslaughter. The Court of Appeals affirmed, holding (1) the trial court erred by placing an impermissible restriction on Petitioner's right against self-incrimination and infringing his right to due process when it required him to testify prior to the completion of the defense case or to forgo testifying at all, but this error was harmless under the circumstances of this case and did not prejudice Petitioner; and (2) the trial court did not err in admitting evidence of prior bad acts and a question implying that Petitioner posed a threat to another child. View "Stoddard v. State" on Justia Law

Petitioner Matthew Tracy was incarcerated when he wrote a letter to a potential witness in a criminal case against Petitioner's half brother. After the woman who received the letter turned it over to the State's county attorney, Petitioner was charged with retaliating against a witness and intimidating and/or influencing a witness based on the contents of the letter. Tracy was convicted of both charges. The court of special appeals affirmed. The Court of Appeals (1) reversed the court of special appeals' judgment affirming Petitioner's conviction for retaliating against a witness, holding that Petitioner was charged and convicted under an inapplicable statute; and (2) otherwise affirmed. Remanded. View "Tracy v. State" on Justia Law

A jury convicted Petitioner Terry Stevenson of conspiracy to commit attempted armed robbery and reckless endangerment. The court of special appeals affirmed the conspiracy conviction and reversed Petitioner's conviction for reckless endangerment. Petitioner filed a petition for writ of certiorari for the Court of Appeals' review, questioning whether conspiracy to attempt armed robbery was a cognizable crime because it was doubly inchoate and defied logic. The Court granted certiorari. After analyzing case law from several different jurisdictions, including its own jurisdiction, the Court of Appeals affirmed, holding that conspiracy to commit attempted armed robbery, a doubly inchoate crime, was a cognizable offense. View "Stevenson v. State" on Justia Law

Petitioner Shawn Johnson was convicted of robbery, conspiracy to commit armed robbery, and related offenses. At trial, the State admitted two inoperable cell phones allegedly used by Petitioner's cousin, who was a State's witness at Petitioner's trial. While the jury was deliberating, one of the jurors inserted his own battery into one of the cell phones, turned it on, and discovered information corroborative of the cousin's testimony. Petitioner moved for a mistrial, alleging that the action of the juror constituted an improper investigation, thereby violating Petitioner's constitutional right to an impartial jury. The trial court declined to declare a mistrial. The court of special appeals affirmed the conviction. The Court of Appeals reversed, holding that the trial court abused its discretion in denying the mistrial without first conducting a voir dire of the jury to ascertain the nature and scope of potential prejudice resulting from at least one juror's exposure to the electronic data on the cell phone. View "Johnson v. State" on Justia Law

During Petitioner Darryl Harrod's first trial for possession with intent to distribute cocaine, a chemist called by the state testified and was subjected to cross-examination. A mistrial was subsequently declared. At the retrial, the trial court admitted the chemist's report and testimony without the presence of the chemist. Ultimately, Harrod was convicted of the charge. Harrod appealed, challenging the admission of the chemist's testimony and report. The court of special appeals affirmed. The Court of Appeals reversed, holding (1) it was error to admit the chemist's report and testimony and report during Harrod's retrial because the State failed to provide the requisite notice pursuant to Md. Code Ann. Cts. & Jud. Proc. 10-1003; and (2) the error was not harmless because the report and testimony were adduced to satisfy proof of the elements of the crime. View "Harrod v. State" on Justia Law

This appeal presented the Court of Appeals with its first opportunity to interpret Md. Code Ann. Crim. P. 8-301, which provided for petitions for writs of actual innocence based on newly discovered evidence. The two Appellants in these consolidated cases were serving their respective sentences when section 8-301 went into effect. Both Appellants filed pro se petitions for writs of actual innocence, which the circuit court denied without a hearing. The Court of Appeals reversed the order denying one Appellant's petition and affirmed the order denying the other Appellant's petition, holding (1) the denial of a petition for writ of actual innocence is an immediately appealable order, regardless of whether the trial court held a hearing before denying the petition; and (2) section 8-301 imposes a burden of pleading such that a petitioner is entitled to a hearing on the merits of the petition provided the petition sufficiently pleads grounds for relief under the statute, includes a request for a hearing, and complies with the filing requirements of section 8-301(b). View "Douglas v. State" on Justia Law

Petitioner Kenneth Barnes pleaded guilty to third-degree sexual offense involving a minor under the age of fifteen. Following his conviction, Barnes was directed to register as a sexual offender. Barnes was later convicted of violating the registration statute and was placed on probation. A subsequent violation of that probation resulted in prison time. Upon being released, Barnes filed a motion to correct an illegal sentence, arguing that his probation and incarceration were the result of the erroneous imposition of the sexual offender registration requirement. The circuit court denied the motion, and the court of special appeals affirmed. The Court of Appeals dismissed Barnes's case as moot, holding that Barnes's claim was not justiciable because he was not currently serving a "sentence" for the purposes of Maryland Rule 4-345(a), and therefore, there was no sentence for the Court to correct. View "Barnes v. State" on Justia Law

A jury convicted Petitioner Antajuan Wilson of first-degree murder and related offenses, including use of a handgun in the commission of a crime of violence. Petitioner appealed, arguing that he was entitled to a new trial on the ground that the circuit court erroneously refused to instruct the jury on the partial defenses of imperfect self defense and the rule of provocation. The court of special appeals affirmed. The Court of Appeals reversed, holding (1) because the evidence was sufficient to generate the issue of whether there was a reasonable doubt that Defendant did not kill in self defense, the trial court erred by refusing to instruct the jury on the mitigation defense of imperfect self defense; but (2) the circuit court correctly rejected the request for a rule of provocation instruction. View "Wilson v. State" on Justia Law

After a jury trial, Petitioner Arthur White was convicted of first-degree murder, conspiracy to commit murder, armed robbery, and related offenses. The court of special appeals (1) affirmed the majority of Petitioner's convictions, but (2) reversed his convictions for first-degree murder and use of a handgun in the commission of a crime of violence after determining that the jury instructions and the prosecutor's argument to the jury were plain error. The Court of Appeals reversed the judgment of the court of special appeals and directed that Petitioner's convictions of murder and use of a handgun be reinstated, holding that the circuit court did not commit plain error during the jury instructions or during the prosecutor's rebuttal argument. View "White v. State" on Justia Law