Justia Maryland Supreme Court Opinion Summaries

The Court of Appeals affirmed the judgment of the Court of Special Appeals affirming the trial court, which convicted Petitioner of rape and sentenced him to a term of seven years incarceration and five years of supervised probation.Before the Court of Appeals, Petitioner argued that the trial court erred in allowing the State to admit redacted portions of telephone calls Petitioner made to his mother while in pre-trial detention. The Court disagreed, holding that the trial court’s exclusion of the entire jail call transcript did not violate the common law doctrine of verbal completeness. View "Otto v. State" on Justia Law

Jurisdiction under the Maryland Uniform Postconviction Procedure Act (UPPA), Md. Code Ann., Crim. Proc. 7-101 to -109, is determined upon the filing of a petition for postconviction relief and, barring a procedural default, is not defeated upon the petitioner’s release from custody prior to completion of full review of the case, including any appellate review.After Petitioner filed an application for leave to appeal the denial of his petition for postconviction relief, Petitioner completed his sentence, including a three-year probationary period. The Court of Appeals dismissed the appeal, concluding that it lost jurisdiction to entertain the appeal once Petitioner was no longer in custody. The Court of Appeals vacated the Court of Appeals’ judgment and remanded to that court to consider the merits of Petitioner’s appeal, holding that whenever a timely petition for postconviction relief is filed, absent the petitioner’s procedural default, Maryland courts retain jurisdiction throughout consideration of the petition, including appellate review, despite any intervening release from custody. View "Kranz v. State" on Justia Law

The Court of Appeals here adopted the “prison mailbox rule” - under which the papers or pleadings of unrepresented, incarcerated litigants are deemed “filed” when formally delivered to prison authorities for mailing to the circuit court - in the postconviction context and applied it to the case at bar.Petitioner, who was unrepresented and incarcerated at the time of the relevant events, testified that he delivered a petition for postconviction relief to prison authorities three days before a statutory ten-year filing deadline. Prison authorities mailed the petition to the circuit court two days later, and the petition arrived and was date-stamped by the clerk one day after the deadline. The circuit court rejected the petition as untimely. The court of special appeals affirmed. The Court of Appeals reversed, holding (1) this Court hereby adopts the prison mailbox rule; and (2) as applied to Petitioner, Petitioner’s petition for post-conviction relief was timely filed when he delivered it to prison authorities at least two days before the limitations period expired. The Court remanded the case with directions that the circuit court accept the petition as timely filed and proceed to consider the merits of the petition. View "Hackney v. State" on Justia Law

The Court of Appeals here adopted the “prison mailbox rule” - under which the papers or pleadings of unrepresented, incarcerated litigants are deemed “filed” when formally delivered to prison authorities for mailing to the circuit court - in the postconviction context and applied it to the case at bar.Petitioner, who was unrepresented and incarcerated at the time of the relevant events, testified that he delivered a petition for postconviction relief to prison authorities three days before a statutory ten-year filing deadline. Prison authorities mailed the petition to the circuit court two days later, and the petition arrived and was date-stamped by the clerk one day after the deadline. The circuit court rejected the petition as untimely. The court of special appeals affirmed. The Court of Appeals reversed, holding (1) this Court hereby adopts the prison mailbox rule; and (2) as applied to Petitioner, Petitioner’s petition for post-conviction relief was timely filed when he delivered it to prison authorities at least two days before the limitations period expired. The Court remanded the case with directions that the circuit court accept the petition as timely filed and proceed to consider the merits of the petition. View "Hackney v. State" on Justia Law

The Court of Appeals reversed the judgment of the Court of Special Appeals, which held that the police did not have probable cause to search the trunk of a car owned and driven by Respondent.The suppression court denied Respondent’s motion to suppress, ruling that, under the totality of the circumstances, the officers had reasonable suspicion that the individuals in the vehicle were involved in criminal activity, permitting the continued detention, and that by the time the officers searched the trunk of Respondent’s vehicle they had amassed probable cause - based in part on drug evidence found on the person of Respondent’s front-seat passenger - to believe the trunk contained evidence of drug-related activity. The Court of Special Appeals reversed. The Court of Appeals vacated the judgment of the Court of Special Appeals, holding that the intermediate appellate court failed to review, in their entirety, the facts and circumstances that led the police to search the trunk of Respondent’s car and instead isolated certain facts while ignoring or minimizing others. View "State v. Johnson" on Justia Law

The Court of Appeals reversed the judgment of the Court of Special Appeals, which held that the police did not have probable cause to search the trunk of a car owned and driven by Respondent.The suppression court denied Respondent’s motion to suppress, ruling that, under the totality of the circumstances, the officers had reasonable suspicion that the individuals in the vehicle were involved in criminal activity, permitting the continued detention, and that by the time the officers searched the trunk of Respondent’s vehicle they had amassed probable cause - based in part on drug evidence found on the person of Respondent’s front-seat passenger - to believe the trunk contained evidence of drug-related activity. The Court of Special Appeals reversed. The Court of Appeals vacated the judgment of the Court of Special Appeals, holding that the intermediate appellate court failed to review, in their entirety, the facts and circumstances that led the police to search the trunk of Respondent’s car and instead isolated certain facts while ignoring or minimizing others. View "State v. Johnson" on Justia Law

In the context of a probable cause determination, the issue of a drug detection dog’s reliability is a legal question to be reviewed de novo.Sergeant Christopher Lamb initiated a traffic stop of a vehicle that Petitioner had been driving. A drug detection dog arrived at the scene of the traffic stop, scanned the vehicle, and alerted to it. Sergeant Lamb searched the vehicle and found drugs inside. The circuit court determined that the drug detection dog was reliable. The Court of Appeals affirmed, holding (1) the ultimate question of probable cause to conduct a warrantless search of a vehicle based on a drug detection dog’s alert is reviewed de novo, but the issue of a drug detection dog’s reliability is a factual question, and accordingly, an appellate court reviews for clear error a trial court’s determination as to whether a drug detection dog is, or is not, reliable; and (2) the circuit court in this case did not clearly err in determining that the drug detection dog was reliable, and under the totality of the circumstances, that the arresting officer had probable cause for the search. View "Grimm v. State" on Justia Law

The Court of Appeals reversed Defendant’s convictions arising out of a home invasion and robbery, arguing that the trial court erred in giving a missing witness instruction in this case.None of the victims of the crime at issue in this case identified Defendant as a participant in the robbery. Defendant testified that he had been at his mother’s home on the night of the robbery, but his mother did not testify. At the prosecutor’s request, the trial court gave a missing witness instruction that advised the jury that it could infer from the mother’s absence that she would have testified unfavorably to Defendant. The Court of Appeals reversed and remanded for entry of an order vacating Defendant’s convictions, holding that the trial court’s decision to give a missing witness instruction in this case was not harmless beyond a reasonable doubt. View "Harris v. State" on Justia Law

At issue was whether victim impact evidence in the form of a video displaying more than one hundred photographs of Defendant’s victims, with accompanying music, is permissible at a sentencing hearing.Defendant entered an Alford plea to two counts of first-degree murder, one count of robbery, and one count of child kidnapping. During sentencing, Defendant moved to exclude a video with approximately 115 photographs of the two victims set to background music. The sentencing judge allowed the video to be played. The Court of Appeals held that showing the video at the sentencing hearing did not violate Defendant’s constitutional rights. Specifically, the Court held (1) a sentencing judge has discretion to permit any additional form of victim impact evidence outside the constraints of Md. Code Ann. Crim. Proc. (“CP”) 11-402 and CP 11-403; (2) all prepared victim impact evidence, not including victim impact testimony, must be limited to the content prescribed under CP 11-402(e); (3) the Eighth Amendment does not prohibit a sentencing judge from considering victim impact evidence at a defendant’s noncapital sentencing proceeding; and (4) Defendant’s Fourteenth Amendment due process rights were not violated because the disputed victim impact evidence did not inflame the passions of the sentencing judge more than the facts of the crime. View "Lopez v. State" on Justia Law

The trial court in this criminal case did not err in admitting the testimony from the State’s cellular communication expert, Allen Hagy, and did not err in admitting evidence of Defendant’s silence during an investigation by his automobile insurer that was related to and concurrent with the police investigation in this case.After a third trial, Defendant was convicted of crimes associated with the murder of LaToya Taylor. The Court of Appeals affirmed the convictions, holding (1) the trial court properly exercised its discretion when it found that a sufficient factual basis existed in admitting Hagy’s expert opinion testimony, and the trial court’s decision to admit the testimony was not made in an arbitrary or capricious manner; and (2) there was no clear abuse of discretion in the trial court’s ruling to admit evidence of Defendant’s silence during the investigation by Defendant’s automobile insurer. View "Santiago v. State" on Justia Law