Justia Maryland Supreme Court Opinion Summaries

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

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

Petitioner was charged with possessing marijuana, importing into Maryland between 5 and 45 kilograms of marijuana, and related offenses. Near the beginning of the trial of his criminal case, after the prosecution's first witness had completed his direct testimony and before cross-examination by the defense, the circuit court permitted petitioner to discharge his attorney and represent himself. At issue was whether, under the Sixth Amendment to the United States Constitution and Article 21 of the Maryland Declaration of Rights, petitioner's decision to waive counsel and to represent himself satisfied the Johnson v. Zerbst standard of an intelligent and knowing waiver of counsel. The court held that petitioner did not intelligently and knowingly waive counsel where the circuit court failed to inform him of the full range of penalties he faced as a subsequent offender and where the record did not show that petitioner had previously been told of the maximum penalties he faced as a subsequent offender.