Justia Maryland Supreme Court Opinion Summaries

Defendant was charged with two counts of first-degree murder. The police obtained DNA samples from the crime scene. The DNA analysis was conducted in accordance with the FBI’s Quality Assurance Standards. Prior to trial, Defendant filed a motion in limine to exclude the State’s DNA evidence and related expert testimony, arguing that the evidence was not admissible because the analysis was not performed in accordance with standards established by one of the two entities named in Md. Code Ann. Cts. & Jud. Proc. (CJP) 10-915 and because the methods of analysis that were used are not generally accepted as reliable under Frye-Reed. The trial court and Court of Special Appeals held (1) the DNA evidence did not qualify for automatic admissibility under section 10-915; but (2) the evidence was nonetheless admissible under Frye-Reed. The Court of Appeals affirmed, holding (1) the DNA evidence was automatically admissible under CJP 10-915; and (2) therefore, the trial court should not have conducted a Frye-Reed hearing to determine its admissibility, but the error was harmless because the trial court ultimately reached the correct conclusion that the DNA evidence was admissible. View "Phillips v. State" on Justia Law

Before October 1, 2014, under Maryland law, possession of less than ten grams of marijuana was a misdemeanor that carried a maximum penalty of ninety days of incarceration and a fine of $500. As of that date, possession of less than ten grams of marijuana became a civil offense punishable by participation in a drug education program, an assessment for substance abuse disorder, possible substance abuse treatment, and a fine. In separate cases, each of three petitioners moved to suppress evidence that had been found in a vehicle that he had been driving or had possession of, arguing that, due to decriminalization of possession of less than ten grams of marijuana, a law enforcement officer no longer has probable cause to search a vehicle when the officer detects an order of marijuana emanating from the vehicle. The circuit court denied the motion to suppress in each case. The Court of Special Appeals affirmed. The Court of Appeals affirmed, holding (1) notwithstanding the decriminalization of less than ten grams of marijuana, marijuana remains contraband, and the order of marijuana gives rise to probable cause to believe that the vehicle contains contraband or evidence of a crime; and (2) there was probable cause to search the vehicles in question in this case. View "Robinson, Williams & Spriggs v. State" on Justia Law

After a jury trial, Roderick Colvin was convicted of felony murder and other crimes. Colvin later filed a motion to correct an illegal sentence pursuant to Maryland Rule 4-345(a). In this motion Colvin argued, for the first time, that the verdicts supporting his convictions were not unanimous, in violation of Maryland Rule 4-327(a), because the jury foreperson was not polled individually after she announced the jury’s verdicts. The circuit court denied the motion, determining, as a preliminary matter, that the alleged defect in the polling process was not a cognizable claim under Maryland Rule 4-345(a). The court of special appeals affirmed, ruling that the claim was cognizable but failed on its merits. The Court of Appeals vacated the judgment of the court of special appeals, holding that the procedural error alleged in this case did not come within the narrow meaning of Rule 4-345(a) and, therefore, was not a cognizable claim under the rule. View "Colvin v. State" on Justia Law

After a jury trial, Defendant was convicted of attempted second-degree murder and other offenses. Defendant appealed his conviction of attempted second-degree murder, challenging the trial judge’s finding that defense counsel’s explanations for striking jurors were a pretext for racial discrimination. The Court of Special Appeals affirmed. The Court of Appeals reversed, holding (1) the trial judge’s finding that defense counsel’s peremptory challenges were a pretext for racial discrimination was clearly erroneous; and (2) the evidence was insufficient for a rational trier of fact to find beyond a reasonable doubt specific intent for the crime of attempted second-degree murder. Remanded for a new trial as to all remaining counts except for the count charging attempted second-degree murder. View "Spencer v. State" on Justia Law

In 1990, Petitioner was indicted on fifteen charges related to a sexual assault. Petitioner entered an Alford plea to first degree rape and kidnapping and was sentenced to life imprisonment plus thirty years. In 2008, Petitioner filed a petition for DNA testing alleging that newly discovered slides containing cellular material from swabs taken from the victim needed to be tested. The circuit court granted the motion, and the testing was conducted. Thereafter, Petitioner filed a motion to vacate conviction and contemporaneously filed a petition for writ of actual innocence. The circuit court denied the motions after a hearing. The Court of Appeals affirmed, holding that Petitioner could not avail himself of a petition for DNA testing because he entered a plea rather than going to trial. View "Jamison v. State" on Justia Law

This case involved a joint criminal trial of two codefendants - Dorrien Allen and Tevin Hines. Hines appealed the trial court’s denial of his motion for a severance, arguing that he was prejudiced by the admission into evidence of a statement made by Allen, which was inadmissible against Hines. The Court of Special Appeals reversed, holding that Hines was prejudiced by having to defend himself against evidence that would not have been admissible had he been tried separately. The Court of Appeals reversed, holding that the trial court committed reversible error in denying Hines’s motion for severance because the statement that was inadmissible against Hines implicated him and therefore caused him to suffer prejudice from the joinder. View "State v. Hines" on Justia Law

Appellant was convicted of conspiracy to commit murder and sentenced to life imprisonment. Appellant filed a pro se petition for postconviction DNA testing of a broom and dust pan pursuant to Md. Code Ann. Crim. Proc. (CP) 8-201. The postconviction court dismissed the petition, concluding that Appellant did not have standing to file a petition under CP 8-201(b) because he was not convicted of a crime of violence. The Court of Appeals affirmed, holding (1) a defendant convicted of conspiracy to commit murder is not eligible to file a petition for postconviction DNA testing under CP 8-201(b); and (2) the postconviction DNA testing statute does not violate due process or equal protection rights under the United States Constitution or the Maryland Declaration of Rights. View "Washington v. State" on Justia Law

Following his arrest for illegal drug activity, Petitioner was released on bond and withdrew all of the money contained in two bank accounts. Law enforcement traced the money to Petitioner’s sister’s bank account and seized the bank account. Less than ninety days after the conclusion of Petitioner’s criminal proceedings, the Department of Finance of Montgomery County filed a complaint petition for currency forfeiture as to the sister’s bank account. Petitioner’s sister argued that her bank account was not “money” under Maryland's forfeiture statute and that the complaint for forfeiture was untimely filed. The circuit court rejected that argument and ultimately found that the funds in the bank account constituted illegal drug proceeds. The court, therefore, granted forfeiture of the entire amount. The Court of Special Appeals affirmed. The Court of Appeals affirmed, holding (1) the funds contained in a bank account are “money” for purposes of the forfeiture statute; and (2) the forfeiting authority timely filed the complaint for forfeiture of the bank account within the deadline applicable to the filing of a complaint for forfeiture of money. View "Bottini v. Dep’t of Finance, Montgomery County" on Justia Law

The Maryland Supreme Court granted the State’s petition for a writ of certiorari in this case to decide whether the Uniform Postconviction Procedure Act (“UPPA”) granted the Court of Special Appeals the authority to reopen a postconviction proceeding if doing so was “in the interests of justice.” The Supreme Court "easily" concluded that the UPPA did not. However, the Court of Special Appeals was statutorily authorized to review a circuit court's denial of a motion to reopen for abuse of discretion, and could remand the matter back to the circuit court with instruction to award appropriate relief if the circuit court abused that discretion. In 1978, Respondent James Leslie Adams-Bey, Jr., was convicted by a jury of first degree rape and related offenses, for which he was sentenced to life plus ten years of incarceration. Respondent petitioned unsuccessfully for postconviction relief in 2010. In 2012, Respondent moved pro se to reopen his postconviction proceedings on the ground that jurors at his criminal trial were given advisory-only instructions in violation of his constitutional rights to due process. Respondent argued that those instructions were unconstitutional because the jury was not instructed to follow the court’s explanation of the law and the court did not inform the jury of the binding nature of its instructions on the State’s burden of proof or the presumption of innocence. The circuit court denied Respondent’s motion without a hearing. On appeal of that denial, Respondent argued the circuit court abused its discretion by denying his motion to reopen. The Court of Special Appeals granted Respondent's application, and addressed the merits of his appeal, and reversed the circuit court's denial. The Supreme Court affirmed the Court of Special Appeals, finding it correctly concluded that the circuit court abused its discretion by denying Respondent's motion to reopen. View "Maryland v. Adams-Bey" on Justia Law

Petitioner was convicted of murder and related offenses arising from a failed armed robbery in 1994. Petitioner was sentenced to life imprisonment. In 2013, Petitioner filed a petition for writ of actual innocence under Md. Code Ann. Crim. Proc. 8-301, claiming newly discovered evidence in that the State’s ballistics expert falsely testified about his academic credentials at Petitioner’s trial. The circuit court concluded that Petitioner was not entitled to relief under section 8-301. The Court of Special Appeals affirmed. The Court of Appeals affirmed, holding that the hearing judge did not abuse his discretion in ruling that, under the circumstances of this case, Petitioner was unable to prove that the expert's lies about his academic credentials created a substantial or significant possibility that the outcome at trial may have been different. View "McGhie v. State" on Justia Law