Justia Maryland Supreme Court Opinion Summaries

A jury found the defendant guilty of second-degree assault. At the sentencing hearing, the trial judge initially announced a sentence of one year, suspending all but nine months to be served on home detention, followed by three years of supervised probation. While the judge was advising the defendant of his post-trial rights, the prosecutor questioned whether the sentence properly reflected the intended punishment and raised concerns about the remaining active time if probation was violated. After a brief colloquy and clarification, the judge revised the sentence, increasing it to five years, suspending all but nine months on home detention, and three years of supervised probation.The defendant appealed to the Appellate Court of Maryland, arguing that the trial judge had illegally increased the sentence after it had been imposed, in violation of Maryland Rule 4-345, which restricts modifications to sentences once they are imposed. The Appellate Court rejected this argument, holding that the sentence was not illegally increased because the revision occurred before the sentencing proceeding concluded, and Rule 4-345 was therefore not triggered.On further appeal, the Supreme Court of Maryland affirmed the decision of the Appellate Court. The Supreme Court held that under Maryland law, a sentence is not considered “imposed” under Rule 4-345 until the sentencing proceeding ends. Thus, a trial court retains authority to modify or increase a sentence during an ongoing sentencing hearing. Since the revision to the defendant’s sentence occurred before the conclusion of the sentencing proceeding—while the defendant was still present and the case was not over—Rule 4-345 did not apply, and the increase did not violate double jeopardy protections. The judgment of the Circuit Court for Prince George’s County was affirmed. View "Reyes v. State" on Justia Law

A defendant was found guilty by a jury of second-degree assault. At the sentencing hearing, the trial judge initially announced a sentence of one year, suspending all but nine months to be served on home detention, followed by three years of supervised probation. While the judge was advising the defendant of his post-trial rights, the prosecutor sought clarification about the sentence, noting that the initial announcement did not leave sufficient “backup” time for a probation violation. After a brief colloquy, the judge, realizing a misunderstanding regarding the sentencing guidelines, revised the sentence to five years, suspending all but nine months on home detention, and three years of supervised probation. The defendant remained in the courtroom, and the sentencing proceeding had not ended when the change was made.The defendant appealed to the Appellate Court of Maryland, arguing that the trial court had illegally increased his sentence after it was imposed, in violation of Maryland Rule 4-345, which restricts a court’s ability to modify a sentence once it has been imposed. The Appellate Court determined that the sentence was not illegally increased because the sentencing proceeding had not concluded when the change occurred, and thus, Rule 4-345 did not yet apply.The Supreme Court of Maryland reviewed the case to decide when a sentence is considered “imposed” under Maryland Rule 4-345 and whether the trial court’s increase was illegal. The Court held that a sentence is not imposed until the sentencing proceeding ends, which generally occurs when the judge signals the conclusion of the case, such as by remanding the defendant or calling the next case. Therefore, because the sentence was changed before the proceeding ended, the trial court retained authority to revise it, and Rule 4-345 was not triggered. The Supreme Court of Maryland affirmed the trial court’s judgment. View "Reyes v. State" on Justia Law

The case involved a defendant who was charged with attempted first-degree murder and related offenses in the Circuit Court for Montgomery County, Maryland. Before trial, both the defense and prosecution jointly requested a postponement of the trial date due to the resignation of the defendant’s public defender and the need for additional preparation time. During a status hearing, the defendant’s newly assigned counsel informed the court that the defendant wanted to represent himself and keep the original trial date. The matter was referred to the administrative judge, who questioned the defendant about his wishes. The defendant responded that he wanted an attorney but did not want the trial postponed, emphasizing his desire for a speedy trial and expressing frustration about his continued incarceration.After this exchange, the administrative judge postponed the trial date, and the defendant did not further request to discharge counsel or to represent himself. At trial, the defendant was represented by counsel and was convicted by a jury of attempted second-degree murder, armed robbery, and use of a firearm in the commission of a felony or crime of violence. The Appellate Court of Maryland affirmed the conviction, finding that the defendant had not expressed a present intent to discharge counsel or to represent himself, and that the trial court had provided an adequate opportunity for the defendant to clarify his wishes.The Supreme Court of Maryland reviewed whether the trial court violated the defendant’s constitutional and procedural rights by not conducting further inquiry into his alleged request for self-representation. The Supreme Court held that when a court is informed that a defendant may wish to represent himself, it must conduct a reasonable inquiry to determine if the defendant clearly and unequivocally asserts that right and must allow the defendant to explain his reasons for discharging counsel under Maryland Rule 4-215(e). However, if the defendant does not express a clear desire for self-representation or to discharge counsel, the court is not required to question him further. The Supreme Court affirmed the lower court’s judgment. View "Goodrich v. State" on Justia Law

Jamal Antoine Williams was charged with promoting a criminal organization after standing watch while a gang leader spray-painted a gang-related message on public property and posing for pictures in front of the graffiti. The criminal organization in question was the Rollin 30s Crips, a set of the transnational gang known as the Crips. Williams admitted to previous membership in the Crips and was identified as a participant in the graffiti incident through video surveillance and social media posts.In the Circuit Court for Montgomery County, Williams waived a jury trial and pled not guilty with an agreed statement of facts. The court found him guilty of promoting a criminal organization under CR § 9-805 and sentenced him to five years’ incarceration, with all but six months suspended, followed by supervised probation. Williams appealed, and the Appellate Court of Maryland affirmed his conviction, interpreting "promote" broadly to include his actions.The Supreme Court of Maryland reviewed the case and held that CR § 9-805 is a general intent crime, requiring the State to prove that the defendant knew the organization was a "criminal organization" as defined by the statute. The court further held that the statute applies only to individuals who exercise a leadership role in the criminal organization or, if not members, exercise discretionary authority in connection with the act of promotion. The court found that the evidence was insufficient to prove that Williams had a leadership role or exercised discretionary authority in the gang. Consequently, the Supreme Court of Maryland reversed the conviction and directed the lower court to enter a judgment of acquittal. View "Williams v. State" on Justia Law

A former Baltimore police officer, Christopher Nguyen, was charged with reckless endangerment for failing to prevent an assault on Wayne Brown by Kenneth Somers. Nguyen arrived at the scene to find Brown injured and Somers admitting to the assault. While Nguyen was investigating, Somers kicked Brown in the head. Nguyen was charged for not preventing this spontaneous assault.In the Circuit Court for Baltimore City, Nguyen was convicted of reckless endangerment after a bench trial. The court found that Nguyen had a duty to protect Brown and that his failure to prevent the assault was a gross departure from the standard of conduct expected of a reasonable officer. The Appellate Court of Maryland affirmed the conviction, holding that Nguyen had a duty to protect Brown as a member of the public and that his conduct constituted reckless endangerment.The Supreme Court of Maryland reviewed the case. The court held that the State failed to prove that Nguyen had a legal duty to protect Brown from an unforeseeable assault by Somers. The court noted that the common law duties of police officers do not extend to protecting individuals from spontaneous and unforeseeable assaults by third parties. Additionally, the court found that the State did not establish a special relationship between Nguyen and Brown that would create a duty to protect. Consequently, the Supreme Court of Maryland reversed the judgment of the Appellate Court, finding that the State did not meet its burden of proving a legal duty under the circumstances. View "Nguyen v. State" on Justia Law

The case involves Travis Rashad Shepperson, who was convicted in 2009 of first- and second-degree sexual offenses, use of a handgun in the commission of a crime of violence, robbery with a dangerous weapon, robbery, and theft. A key piece of evidence at trial was a DNA result showing the presence of the victim’s DNA on the barrel of a gun found in Shepperson’s possession. Sixteen years later, DNA testing on a different portion of the same gun barrel sample detected no DNA, leading Shepperson to file a motion for a new trial based on these new test results.The Circuit Court for Prince George’s County denied Shepperson’s motion for a new trial. The court found that the new DNA test results did not contradict the earlier DNA profile introduced at trial and did not undermine the State’s theory of the case. Additionally, the new result pertained to an act for which Shepperson was acquitted and bore no connection to the sex offenses for which he was convicted. Therefore, the court concluded that the new DNA result did not create a substantial possibility of a different verdict and did not warrant a new trial in the interest of justice.The Supreme Court of Maryland reviewed the case and affirmed the lower court’s decision. The court held that the postconviction court did not abuse its discretion in denying Shepperson’s motion for a new trial. The new DNA evidence was not considered favorable as it did not refute the State’s theory or materially undermine the evidence presented at trial. Furthermore, the absence of detectable DNA on a previously untested portion of the gun barrel swab did not materially undermine the evidence presented at trial. Thus, the new DNA result neither contradicted the State’s theory of the case nor created a substantial possibility that the jury would have reached a different verdict. View "Shepperson v. State" on Justia Law

Sergey Danshin was charged with the murder of Javier Gonzalez-Mena, which occurred outside a hotel room in Montgomery County, Maryland. Danshin claimed he acted in defense of Christina Jones, who he believed was in imminent danger from Gonzalez-Mena. Danshin's recorded statement to the police, introduced by the State at trial, indicated that he shot Gonzalez-Mena because he believed Jones was in immediate danger of death or serious bodily harm, and that his actions were necessary to protect her.The Circuit Court for Montgomery County denied Danshin's request to instruct the jury on the defense of others, concluding there was no evidence of an imminent threat to Jones. The jury convicted Danshin of first-degree premeditated murder, use of a firearm in the commission of a felony, and illegal possession of a firearm. Danshin's motion for a new trial was denied.The Appellate Court of Maryland affirmed the conviction, holding that there was not "some evidence" to support the defense of others instruction because Danshin denied shooting Gonzalez-Mena. The court relied on the precedent that inconsistent defenses, such as denying the act while claiming justification, do not warrant such an instruction.The Supreme Court of Maryland reviewed the case and held that there was some evidence to support the defense of others instruction. The court noted that Danshin's statements to the police provided sufficient evidence that he believed Jones was in imminent danger and that his actions were necessary to protect her. The court reversed the judgment of the Appellate Court and remanded the case for a new trial, instructing the lower court to provide the jury with the defense of others instruction. View "Danshin v. State" on Justia Law

James Russell Trimble, who was convicted of first-degree murder and other crimes committed when he was 17 years old, filed a motion for a reduction of his sentence under Maryland's Juvenile Restoration Act (JUVRA). This act allows individuals convicted as minors and who have served at least 20 years to seek a sentence reduction. Trimble argued that his age at the time of the offense and his rehabilitation efforts warranted a reduced sentence.The Circuit Court for Baltimore County denied Trimble's motion, finding that his age at the time of the crime did not support a sentence reduction, and that he continued to pose a danger to the public. The court also did not credit the testimony of Trimble's expert, who argued that Trimble's antisocial personality disorder (ASPD) had remitted. The court emphasized the brutal nature of the crime and the lasting impact on the victim's family.The Appellate Court of Maryland affirmed the circuit court's decision, holding that the circuit court did not abuse its discretion. The appellate court found that the circuit court had adequately considered all the required factors under JUVRA, including Trimble's age, rehabilitation efforts, and expert testimony. The appellate court also noted that the circuit court was not required to give special consideration to any particular factor, including rehabilitation.The Supreme Court of Maryland reviewed the case and affirmed the lower courts' decisions. The court held that under JUVRA, the circuit court has broad discretion to determine whether an individual is a danger to the public and whether the interests of justice will be served by a reduced sentence. The court is required to consider ten enumerated factors but is not required to give special consideration to any particular factor. The Supreme Court found that the circuit court had properly exercised its discretion in denying Trimble's motion for a reduced sentence. View "Trimble v. State" on Justia Law

Amondre Clark filed a successful petition for writ of habeas corpus after several of his convictions were vacated on October 20, 2023. The Division of Correction did not execute the next valid sentences and apply credit for time served under the vacated convictions. Instead, the Division tolled his next valid consecutive sentences, waiting to see if the State’s reprosecution would result in a new conviction. On April 17, 2024, Clark pled guilty to one charge and was sentenced to a new "time served" sentence. However, the Division did not release him, treating the new sentence as a "replacement sentence" for one of the vacated sentences and tacking on the consecutive sentences it had tolled.Clark filed a petition for habeas relief in the Circuit Court for Baltimore City, arguing that the Division incorrectly interpreted CP § 6-218(c) and (d). The habeas court agreed, ordering his immediate release. The Division appealed to the Appellate Court of Maryland, but the Supreme Court of Maryland granted Clark’s petition for a writ of certiorari.The Supreme Court of Maryland held that under CP § 6-218(d), when a criminal defendant’s term of confinement consists of multiple sentences and one or more convictions underlying those sentences is vacated, the defendant is entitled to receive credit for time served when the conviction is vacated, commencing on the date of the first invalidated sentence. The court also held that if a defendant is reprosecuted or retried and a new conviction results, CP § 6-218(c) applies to any leftover credit after credit has been given under CP § 6-218(d). The new sentence should be in last place in a chain of consecutive sentences, and the sentencing judge may make the new sentence consecutive or concurrent to any then-existing sentences.The court vacated the judgment of the habeas court and remanded the case to the habeas court with instructions to vacate the sentence entered on April 17, 2024, and remand the matter to the sentencing court to exercise its discretion with a full understanding of the status of the valid sentences. View "Bivens v. Clark" on Justia Law

Dallas Fenton was convicted of multiple sexual offenses against a fourteen-year-old child, including eight counts of third-degree sexual offense, one count of sexual solicitation of a minor, and one count of indecent exposure. He was sentenced to ten years for one of the third-degree sexual offenses (Count 1) and another ten years for a different third-degree sexual offense (Count 8), to be served consecutively.The Division of Correction (DOC) informed Fenton that he would not receive diminution of confinement credits for the sentence on Count 8 because he had been previously convicted of a similar offense (Count 1). Fenton's grievance with the Inmate Grievance Office (IGO) was dismissed, and the Circuit Court for Washington County partially granted and partially denied his petition for judicial review, ruling that he was entitled to good conduct credits but not other types of diminution credits for Count 8.The Appellate Court of Maryland held that Fenton was not prohibited from accruing diminution credits for Count 8, as the statute only applied if the previous conviction occurred before the commission of the offense for which the sentence was being served. The court vacated the circuit court's judgment and remanded the case for recalculation of Fenton's credits.The Supreme Court of Maryland affirmed the Appellate Court's decision, holding that under Md. Code Ann., Corr. Servs. § 3-702(c), diminution credits are precluded only if the offense was committed after a previous conviction for the same offense. The court concluded that Fenton was entitled to diminution credits for Count 8, as he had not been "previously convicted" at the time of the offense. View "Dept. of Pub. Saf. & Corr. Serv. v. Fenton" on Justia Law