Justia Maryland Supreme Court Opinion Summaries

After a jury trial, Petitioner was convicted of first-degree murder and sentenced to life imprisonment. The Court of Special Appeals affirmed. Petitioner appealed, inter alia, the denial of his motion to suppress the statements he made to police officers during his interrogation, arguing that they were obtained in violation of his Miranda right to counsel. The Court of Appeals affirmed, holding (1) the trial judge violated Maryland Rule 4-326(D)(2) by communicating an ex parte answer to a juror’s question without disclosing it to the defendant or any lawyer, but the error was harmless beyond a reasonable doubt; and (2) Petitioner did not invoke his Miranda right to counsel by demanding to see a lawyer from his holding cell before being interrogated, and therefore, the circuit court did not err in denying Petitioner’s motion to suppress the statements he made to detectives during his interrogation. View "Gupta v. State" on Justia Law

A family magistrate of the circuit court for Baltimore County found that Cody H. had committed the delinquent act of assault by punching a sixteen-year-old victim in the face and breaking his jaw. The magistrate judgment made a recommendation for a restitution award of $1,489 to the victim for medical expenses but did not award restitution for lost earnings. The State filed exceptions to the recommendation. A juvenile court judge sustained the State’s exception and imposed an additional restitution amount of $5,000 for loss of earnings. The Court of Appeals affirmed, holding that the loss of earnings restitution award in this case was proper under the restitution statute, Md. Code Ann., Crim. Proc. 11-603. View "In re Cody H." on Justia Law

Respondent was acquitted in a jury trial of first-degree murder premeditated murder, second-degree specific intent murder, and other charges. Thereafter, the State sought to prosecute Respondent for second-degree felony murder predicated on first-degree assault. Respondent interposed a plea of double jeopardy, which was denied. The Court of Special Appeals reversed, concluding that a subsequent trial for felony murder based upon first-degree assault was barred by the Double Jeopardy Clause. The Court of Appeals affirmed but on different grounds, holding that first-degree assault may not serve as a predicate for second-degree felony murder when that assault is not collateral to the lethal act. In so holding, the Court overruled Roary v. State, which was the foundation and predicate for the State’s charge for second-degree felony murder based on first-degree assault. View "State v. Jones" on Justia Law

Petitioner was fifteen years old when he committed murder. Petitioner was charged as an adult, and the circuit court denied Petitioner’s request to transfer the case back to juvenile court. Twenty-six years later, the psychiatrist who originally examined Petitioner concluded that her original diagnosis that Petitioner was not legally insane at the time of the crime was incorrect and that Petitioner should have been deemed not criminally responsible (NCR) at the time of his criminal proceedings. Thereafter, Petitioner filed a petition for writ of actual innocence under Md. Code. Ann. Crim. Proc. 8-301, arguing that this revised expert opinion constituted newly discovered evidence that created a substantial possibility that the result of his 1985 prosecution may have been different. The circuit court denied the petition. The Court of Appeals affirmed, holding that, even if Petitioner was found NCR at the time of the 1985 proceeding, he was still guilty of killing the victim and was therefore not actually innocent of the crime for which he was convicted. View "Smallwood v. State" on Justia Law

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