Justia Maryland Supreme Court Opinion Summaries

Defendants were indicted for possession of a controlled dangerous substance, intent to distribute a controlled dangerous substance, and possession of a firearm with a nexus to drug trafficking. Defendants moved for judgment of acquittal, arguing that the evidence did not sufficiently connect them to the drugs and firearm because there were multiple people in the apartment where the incriminating evidence was discovered. The trial court denied the motions, and the jury returned a verdict of guilty on all four counts with respect to both Defendants. The Court of Special Appeals reversed, concluding that the State failed to prove that Defendants had possession of the cocaine and handgun. The Court of Appeals reversed, holding that the evidence adduced at trial was sufficient to establish that Defendants had joint constructive possession of the drugs and handgun found in the apartment. View "State v. Gutierrez" on Justia Law

At issue in this case was whether an order granting a petition for writ of actual innocence constitutes a final judgment such that the State can appeal it directly. Petitioner here filed a petition for writ of actual innocence in the circuit court. The circuit court granted Petitioner a new trial on the basis of newly discovered evidence. The State filed a notice of appeal. Petitioner moved to dismiss, citing the State’s limited statutory authority to appeal. The Court of Special Appeals denied Petitioner’s motion to dismiss, ruling that the State can appeal an order granting a petition for writ of actual innocence. The Supreme Court reversed, holding that the State does not have the right to appeal a circuit court decision granting a writ of actual innocence under Md. Code Ann. Crim. Proc. 8-301. View "Seward v. State" on Justia Law

Defendant pleaded guilty to a third degree sexual offense. Defendant was sentenced to one year incarceration and was required to register as a sex offender. Six years later, Defendant petitioned for a writ of actual innocence, alleging newly discovered evidence. The circuit court denied the petition on the merits. The intermediate appellate court affirmed, holding that a writ of actual innocence does not apply to a guilty plea. The Court of Appeals affirmed, holding that a person who has pled guilty may not later avail himself or herself of the relief afforded by a petition for a writ of actual innocence. View "Yonga v. State" on Justia Law

American Sedan Services, Inc. is a commercial transportation service that has a permit from Maryland Aviation Administration (MAA) to provide ground transportation services at the Baltimore Washington International Thurgood Marshall Airport (BWI). Vadim Roshchin, who was employed as a driver by American Sedan, was picking up passengers at BWI without displaying the permit as required by an MAA regulation when Maryland Transportation Authority (MdTA) police arrested him and impounded the American Sedan. Roshchin and American Sedan sued MAA, MdTA, the MdTA police, and the State, alleging, among other claims, false arrest and false imprisonment. The circuit court granted summary judgment for the State on all counts. The Court of Special Appeals reversed, concluding that there was no legal justification for the arrest of Roshchin. The Court of Appeals reversed, holding (1) the regulation requiring commercial transportation services to display permits was not required to be posted at the airport as a prerequisite to its enforcement; and (2) there was legal justification for the arrest, as nothing in the MAA regulation or the Transportation Article deprives a police officer of the general authority to arrest an individual who commits a misdemeanor in the presence of the officer. View "State v. Roshchin" on Justia Law

Mother took her child to health providers on several occasions after complained that her father had hurt her. The child also exhibited vaginal redness. The Department of Human Resources notified Mother that it found her responsible for indicated child abuse mental injury. An Administrative Law Judge (ALJ) affirmed the Department’s finding of indicated child abuse mental injury and found that Mother could be placed on the central registry maintained by the Department. The circuit court affirmed the ALJ’s decision. The Court of Special Appeals affirmed, concluding, in relevant part, that the ALJ did not err by failing to include scienter as an element of indicated child abuse mental injury. The Court of Appeals reversed and remanded, holding that a parent can only be identified on a central registry as responsible for child abuse if the parent intended to injure the child or acted with reckless disregard of the child’s welfare. View "McClanahan v. Washington County Dep’t of Soc. Servs." on Justia Law

Defendants Matthew Meyer and Helen Rivera were placed on probationary terms and, as a special condition of probation, prohibited from operating a motor vehicle. The circuit court denied Meyer’s motion to correct and illegal sentence, concluding that Meyer’s sentence was not illegal. In Rivera’s case, the court of special appeals held that Rivera’s no-driving condition of probation violated the separation of powers doctrine. The State filed a petition for writ of certiorari with the Court of Appeals in both cases. The Court consolidated the cases to address the common questions of law and fact and held (1) Sheppard v. State, which prohibits a court from restricting a defendant’s driving privileges as a condition of probation under certain circumstances, was wrongly decided and is thus overruled; and (2) in Meyer, the circuit court properly denied the defendant’s motion to correct an illegal sentence, and in Rivera, the court of appeals’ judgment holding that the no-driving condition of probation violated the separation of powers doctrine is reversed. View "Meyer v. State" on Justia Law

Petitioner was convicted of first degree murder and sentenced to life imprisonment. The Court of Special Appeals affirmed. Two issues were presented in this appeal, first, whether Petitioner’s statement, “I don’t want to say nothing. I don’t know” was an ambiguous or clear invocation of his right to remain silent under Miranda, and second, whether Petitioner’s confession, given after he waived his Miranda rights, was voluntary or the product of inducement. The Court of Appeals affirmed, holding (1) Petitioner’s statement, “I don’t want to say nothing. I don’t know” was an ambiguous invocation of his right to remain silent; and (2) Petitioner’s confession was voluntary. View "Williams v. State" on Justia Law

Petitioner was charged with theft of property with a value of at least $500 and embezzlement. The charges arose from Petitioner’s removal of funds from a multiple-party bank account, to which Petitioner and her father were parties, to use for her own benefit without her father’s permission. After a bench trial, the circuit court found Petitioner guilty. The Court of Special Appeals affirmed. The Court of Appeals affirmed, holding (1) the evidence was sufficient to support a conviction for theft, as an individual can commit theft from a joint or multiple-party bank account to which the individual is a party under certain circumstances; and (2) the evidence was sufficient to support a conviction for embezzlement. View "Wagner v. State" on Justia Law

In 1999, Petitioner pleaded guilty to a drug offense. In 2012, after being subject to sentencing as an armed career criminal, Petitioner filed a petition for coram nobis relief, contending that he pleaded guilty to an offense other than possession of heroin with intent to distribute, which was one of the predicate offenses to be used for his enhanced sentence. The State filed a response to the coram nobis petition, asserting that the doctrine of laches barred Petitioner from seeking coram nobis relief. After a hearing, the circuit court granted the coram nobis petition. The Court of Special Appeals reversed, concluding that the doctrine of laches barred the coram nobis petition. The Court of Appeals affirmed, holding (1) the doctrine of laches may bar the right to seek coram nobis relief; and (2) the doctrine of laches barred Petitioner’s right to seek coram nobis relief in this case. View "Jones v. State" on Justia Law

In 1999, Petitioner was charged with, among other crimes, three counts of first degree assault. In 2000, the circuit court determined that Petitioner was incompetent and ordered that he be committed. In 2004, Petitioner was found competent to stand trial. Petitioner pled not guilty to the charges of second degree assault. Petitioner was found guilty. The circuit court determined vacated Petitioner’s sentence and ordered a new trial, concluding that Petitioner’s counsel provided ineffective assistance because he had not advised Petitioner of the immigration consequences of his assault conviction. After a retrial, the jury found Petitioner guilty of two counts of first-degree assault and two counts of second-degree assault, among related crimes. Petitioner was sentenced to ten years’ imprisonment. Petitioner appealed, arguing that the trial court erred in failing to determine, prior to trial, that he was competent to stand trial and erred in finding at sentencing that he was competent to stand trial. The court of special appeals affirmed. The Court of Appeals reversed, holding that, pursuant to Md. Code Ann. Crim. Proc.. 3-104, the trial court was required to make a determination upon retrial whether Petitioner was competent to stand trial and therefore clearly erred in determining at sentencing that Petitioner was competent. View "Sibug v. State" on Justia Law