Justia Maryland Supreme Court Opinion Summaries

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

In 1996, Appellant was convicted of two counts of first degree murder and related offenses. In 2008, Appellant filed a petition for post-conviction DNA testing pursuant to Md. Code Ann. Crim. Proc. (CP) 8-201, alleging that socks he had allegedly worn at the time of the murders that the State introduced into evidence at trial lacked his DNA. The State responded with documentation that the socks were destroyed along with other items seized in the case after Appellant’s conviction had been affirmed on direct appeal. In 2011, the circuit court closed the case. In 2013, Appellant sought to reopen the proceedings pursuant to CP 8-201, alleging that the State had improperly destroyed the socks. The pro bono counsel that had assisted Appellant in the earlier proceedings under CP 8-201 moved to strike their appearance. The circuit court granted counsels’ motion, denied Appellant’s request for new court-appointed counsel, and denied Appellant’s request to conduct further proceedings under CP 8-201. The Court of Appeals affirmed, holding that the circuit court did not abuse its discretion when it (1) granted the motion of Appellant’s pro bono counsel to strike their appearance; (2) declined to appoint new counsel for Appellant; and (3) declined to order relief under CP 8-201. View "Simms v. State" on Justia Law

At issue in this case was the constitutionality of a conviction based on a guilty verdict by a jury that was given an advisory only instruction. After a jury trial in 1976, Respondent was found guilty of two counts of first degree murder and a related larceny. In 1997, Respondent sought postconviction relief, alleging several claims. The postconviction court denied relief. In 2007, Respondent filed a motion to reopen the petition for postconviction relief, alleging that the trial court gave an erroneous jury instruction advising the jury that they were the judges of the law and the facts. The circuit court, citing the Court of Appeals’ recently filed opinion in Unger v. State, ultimately granted the motion. After a hearing the postconviction court granted Respondent postconviction relief and ordered that Respondent was entitled to a new trial. The Court of Appeals affirmed, thus upholding Unger as the law regarding advisory only jury instructions, holding that the postconviction court properly granted Respondent relief in the form of a new trial. View "State v. Waine" on Justia Law

Defendant, who was indigent and whose mental competency was questioned by the court and counsel at several junctures, appeared before a series of judges concerning his dissatisfaction with appointed counsel, an assistant public defender. The circuit court advised Defendant about his right to, and the merits of, having counsel, but, upon finding that good cause existed to discharge the assistant public defender, the court treated Defendant’s decision to discharge that counsel as a waiver of counsel, despite Defendant’s clear requests for counsel. Defendant represented himself at trial and was convicted. The Court of Appeals reversed Defendant’s conviction, holding that the trial court erred in failing to appoint counsel for Defendant and in stating that it lacked the authority to appoint counsel for Defendant after finding a meritorious reason to discharge Defendant’s assistant public defender. Remanded for appointment of counsel and a new trial. View "Dykes v. State" on Justia Law

Defendant was indicted on multiple counts of burglary, theft, and related offenses. Defendant was found to be indigent, and an assistant public defender was assigned to represent him. Before trial, Defendant discharged his attorney. Defendant then filed a motion asking the circuit court to help him obtain “pro bono counsel.” The circuit court denied the motion. Defendant represented himself at trial and was found guilty on twenty-one counts. The Court of Special Appeals reversed, holding that the circuit court erred by failing to determine and announce on the record that Defendant was knowingly and voluntarily waiving the right to counsel. The Court of Appeals reversed, holding (1) to the extent Defendant asserts that the court’s “waiver inquiry” was deficient because the court did not make an explicit finding on the record that Defendant was acting knowingly and voluntarily by waiving counsel, Defendant failed to preserve the issue by making a contemporaneous objection; and (2) the trial court did not abuse its discretion in declining to appoint counsel for Defendant when Defendant lacked good cause for discharging his assigned assistant public defender. View "State v. Westray" on Justia Law

In 2012, Petitioner voluntarily consented to a search of his person in the form of saliva and penile swabs for the purpose of furnishing DNA evidence to the police department to use in the investigation of a rape allegation. The DNA profile created from the extraction of Petitioner’s DNA excluded Defendant as a suspect of the alleged rape. Defendant’s DNA profile was subsequently uploaded to the local DNA database. Later, an automatic search resulted in a match between Defendant’s DNA profile and a DNA profile associated with an unsolved burglary committed in 2008. Based on that DNA evidence, Defendant was charged with burglary and related charges. Defendant moved to suppress the State’s DNA match evidence on the grounds that the subsequent use of his DNA to conduct a comparison search of the DNA databank exceeded the scope of his consent and therefore constituted an unlawful search under the Fourth Amendment. The suppression hearing judge denied the motion. The Court of Appeals affirmed, holding that, where Defendant’s consent to search was not expressly limited by him, the State, or the law, the Fourth Amendment did not preclude the police from retaining and using Defendant’s DNA profile created from his voluntarily provided DNA sample for additional, unrelated criminal investigations. View "Varriale v. State" on Justia Law

Shyquille Griffin was indicted on charges related to the shooting of Andrew Lindsey. Pursuant to a plea agreement with the State, Griffin pleaded guilty to attempted robbery. The agreement did not mention restitution. Upon sentencing, the State advised the court that Lindsey was seeking $9,700 in restitution. The circuit court concluded that it could not order restitution because it would violate the agreement by adding to the penalty. Invoking Md. Code Ann. Crim. Proc. 11-103(e), Lindsey filed a motion for reconsideration of restitution and request for hearing (“CP 11-103(e) motion”), arguing that the hearing court improperly denied his request for restitution. The circuit court denied the CP 11-103(e) motion. Lindsey appealed. The Court of Special Appeals reversed, holding that the circuit court had discretion to order restitution as a condition of Griffin’s probation without violating the agreement or Griffin’s double jeopardy rights. The Court of Appeals reversed, holding that Lindsey’s appeal was untimely because Md. Code Ann. Crim. Proc. 11-103(b) does not permit a crime victim to file an application for leave to appeal the denial of a CP 11-103(e) motion. View "Griffin v. Lindsey" on Justia Law