Justia Maryland Supreme Court Opinion Summaries

A conviction that is more than fifteen years old is not irrelevant as a matter of law to a character witness’ opinion about a defendant.After he was convicted for second-degree assault, Defendant appealed, arguing that the trial court improperly admitted evidence of his 1990 battery conviction. The Court of Special Appeals held that the trial court was permitted to allow the State to impeach character witnesses with evidence of Defendant’s twenty-five-year-old battery conviction where each character witness testified regarding Defendant’s reputation for peacefulness. The Court of Appeals affirmed, holding (1) the trial court did not err in deciding that the 1990 battery conviction bore some legal relevance to the character witnesses’ testimony; and (2) the probative value of the 1990 battery conviction was not substantially outweighed by the danger of unfair prejudice. View "Williams v. State" on Justia Law

Data from a business record indicating locations and durations of time determined by a GPS device carried by Defendant was admissible without the need for the State to present expert testimony to explain the operation of, and science underlying, GPS devices.Defendant, an officer with the Maryland Transit Administration (MTA) police, was convicted of assaulting and raping a woman after driving her home following her involvement in a traffic accident with an MTA bus. During trial, the State introduced GPS data from the mobile GPS device Defendant carried as part of his job that matched the itinerary given by the woman in her testimony. On appeal, Defendant argued that the State should have presented expert foundation testimony concerning GPS devices as a prerequisite to the admission of such evidence. The Court of Special Appeals affirmed the convictions. The Court of Appeals affirmed, holding that the jury did not require expert testimony to understand the operation of a GPS device and the data it generated. View "Johnson v. State" on Justia Law

At issue was under what circumstances a defendant has properly invoked his right to request a discharge of counsel pursuant to Maryland Rule 4-215(e).The Court of Special Appeals vacated Defendant’s convictions because the circuit court failed to hold a Rule 4-215(e) hearing prior to Defendant’s trials. Before trial, Defendant sent two pieces of correspondence to the circuit court in which he expressed dissatisfaction with his counsel. The circuit court did not take action on either correspondence until after Defendant’s trials. After the trials had concluded, the circuit court denied Defendant’s request. The Court of Appeals affirmed the judgment of the Court of Special Appeals, holding (1) Defendant’s two letters to the circuit court sufficiently triggered Rule 4-215(e); (2) Defendant did not waive his request to discharge his counsel when he did not repeat his request prior to or during his trials; and (3) the circuit court committed reversible error when it failed to inquire into the reasons for Defendant’s request in a timely manner. View "State v. Weddington" on Justia Law

At issue was whether the revised and consolidated assault statute, contained in Md. Code Ann. Crim. Law 3-201(b), contemplates different crimes or whether the acts constitute second degree assault.Petitioner was convicted of two counts of first degree assault. The trial court instructed the jury on two different variations of second degree assault, but the jury was not instructed to reach a unanimous decision about which version occurred. The Court of Special Appeals upheld Petitioner’s convictions. The Court of Appeals affirmed, holding that the assault statute contemplates different modalities of committing the singular crime of second degree assault, as opposed to different crimes. Therefore, Petitioner was not entitled to have the trial judge instruct the jury to unanimously agree to which modality of assault Petitioner had committed. View "Watts v. State" on Justia Law

At issue was the manner in which Md. Const. art. IV, 22, which provides for an in banc appeal from a “decision of determination of any point or question” by a circuit court judge, is intended to operate.The State in this criminal case filed a request for an in banc review of an order of the circuit court judge granting Defendant’s motion in limine to exclude certain documents and testimony under Reed v. State, 283 Md. 374 (1978). The State sought in banc review, but the request was untimely filed. After a hearing, an in banc court reversed the trial judge’s ruling. The Court of Special Appeals reversed, concluding that “a litigant may not appeal to an in banc panel when the litigant could not note an appeal to [the Court of Special Appeals] successfully.” The Court of Appeals affirmed after analyzing relevant case law and the current version of section 22 in conjunction with Maryland Rule 2-551. The court further outlined the proper procedures a party must follow to reserve the point, question, or judgment for review and held that a decision by the in banc court constitutes a final judgment of that court. View "State v. Phillips" on Justia Law

The Court of Appeals reversed the judgment of the Court of Special Appeals and remanded this criminal case with instructions to vacate the judgment of the circuit court convicting Defendant of second-degree murder and related charges and to remand the case to that court for a new trial. The court held that the trial court committed reversible error by refusing to permit Defendant to cross-examine a State’s witness, pursuant to Maryland Rule 5-616(a)(4), as to whether, in return for his testimony, he expected or hoped for a benefit from the State in connection with pending criminal charges he was facing. View "Manchame-Guerra v. State" on Justia Law

The Court of Appeals affirmed the judgment of the Court of Special Appeals affirming Defendant’s conviction of second-degree assault. On appeal, Defendant argued that the trial court improperly admitted evidence of his 1990 battery conviction. The Court of Special Appeals held that the trial court did not abuse its discretion in allowing the State to impeach character witnesses with evidence of Defendant’s twenty-five-year-old battery conviction. The Supreme Court affirmed, holding that the trial court did not err in admitting evidence of Defendant’s 1990 battery conviction because (1) the 1990 conviction was not irrelevant as a matter of law because the conviction had some bearing on Defendant’s character for peacefulness; and (2) Maryland Rule 5-404 unambiguously does not provide a fifteen-year limitation for rebuttal evidence. View "Williams v. State" on Justia Law

Because the State’s authority to nol pros applies only to charges, the State may not use its nol pros authority to alter a final judgment such as a conviction and sentence.At issue before the Supreme Court was whether the State had the authority to enter a nol pros of a charge that resulted in a conviction and sentence. Defendant was convicted and sentenced for conspiracy to violate the controlled dangerous substance laws. Defendant appealed. Before the court of special appeals heard oral arguments, the State nol prossed the charge underlying Defendant’s conviction and sentence. The court of appeals ruled that the State lacked the authority to nol pros a charge underlying a conviction and sentence and ultimately reversed the judgment based on insufficient evidence. The Supreme Court affirmed, holding (1) after a defendant has received a final judgment in the form of a conviction and sentence, the State may not enter a nolle prosequi to alter the final judgment; and (2) the State lacked the authority in this case to nol pros in order to alter the final judgment or to eliminate the appellate process initiated by Defendant. View "State v. Simms" on Justia Law

The law enforcement officers that stopped Defendant in this case had reasonable suspicion to conduct an investigatory stop when they witnessed what appeared to be criminal activity immediately before the stop. Alternatively, even assuming the stop was unlawful, the evidence recovered from Defendant would be admissible because the attenuation doctrine would apply.The Court of Appeals affirmed the judgment of the Court of Special Appeals to the extent that it held that the officers had reasonable suspicion to stop Defendant. Alternatively, the court affirmed the judgment of the intermediate appellate court and adopted the reasoning of the concurring opinion with respect to the application of the attenuation doctrine. Accordingly, Defendant’s motion to suppress should have been denied. View "Sizer v. State" on Justia Law

In this criminal case concerning the State’s obligation to disclose to a defendant’s counsel information regarding a State’s witness’s pretrial identification of a co-defendant and whether the State was required to make such a disclosure under the circumstances of this case, the Court of Appeals held (1) Maryland Rule 4-263(d)(7)(B), by its plain language and history, does not require disclosure of pretrial identifications of co-defendants; and (2) a pretrial identification of a co-defendant is relevant information regarding pretrial identification of the defendant under Maryland Rule 4-263(d)(7)(B) where the pretrial identification of the co-defendant is the equivalent of a pretrial identification of the defendant as the person responsible for the crime. Accordingly, in this case, the State was obligated to disclose during discovery a witness’s pretrial identification of Defendant’s co-defendant as the person who was not the shooter. View "Green v. State" on Justia Law