Justia Maryland Supreme Court Opinion Summaries

The Supreme Court upheld the judgment of the circuit court on postconviction review ordering a new trial for Petitioner, holding that Petitioner was provided ineffective assistance of counsel due to trial counsel's failure to object to the trial court's order prohibiting any consultation about the case (a no-communication order) between Petitioner and trial counsel under the circumstances of this case.At issue was a no-communication order entered into between Petitioner and trial counsel during an overnight recess prior to the final day of testimony in Petitioner's murder trial and trial counsel's failure to object to the order. The circuit court ruled that the no-communication order, and trial counsel's failure to object, deprived Petitioner of the assistance of counsel, in violation of the Sixth Amendment, and presumed prejudice, thus ordering a new trial. The appellate court reversed, concluding that Petitioner could not show prejudice. The Supreme Court reversed, holding (1) trial counsel's conduct in this case resulted in the actual denial of the assistance of counsel, and prejudice was presumed; and (2) therefore, the circuit court properly ordered a new trial for Petitioner. View "Clark v. State" on Justia Law

The Supreme Court affirmed the judgment of the post-conviction court denying Petitioner's pro se petition for post-conviction relief, holding that the post-conviction court did not err in denying the petition.Petitioner was convicted of distribution of heroin and sentencing him to eight years in prison. In his post-conviction motion, Petitioner argued that his trial counsel rendered ineffective assistance during trial and that the State had violated its Brady obligations. The post-conviction court denied relief. The appellate court certified questions of law to the Supreme Court. The Supreme Court answered (1) Defendant failed to establish that trial counsel rendered ineffective assistance by failing to move to compel production of Internal Affairs Division files; and (2) assuming, without deciding, that the State was required to disclose impeachment evidence prior to the suppression hearing, Petitioner failed to establish the Brady materiality standard. View "Blake v. State" on Justia Law

The Supreme Court affirmed the decision of the post-conviction court denying Defendant's petition for post-conviction relief, holding that the post-conviction court did not err in ruling that trial counsel had not rendered ineffective assistance and that the State had not violated its Brady obligations during the underlying proceedings, holding that there was no error.After a jury trial, Defendant was convicted of distribution of heroin and sentenced to eight years' imprisonment. The appellate court affirmed. Defendant later filed a pro se petition for post-conviction relief, which the post-conviction court denied. On appeal, the appellate court certified questions of law to the Supreme Court. The Supreme Court answered (1) the post-conviction court did not err in ruling that trial counsel had not rendered ineffective assistance by failing to move production of certain evidence; and (2) assuming, without deciding, that the State was required to disclose challenged impeachment evidence prior to the hearing on Defendant's motion to suppress, Defendant failed to establish the Brady materiality standard. View "Blake v. State" on Justia Law

In this case involving the criminal trial of two co-defendants whose cases had been consolidated and was initially scheduled for a date beyond the appropriate date under the "Hicks rule" and the trial court made no finding of "good cause," the Supreme Court held that the dismissal of Defendants' indictments as a remedy for the Hicks violation was inappropriate.The circuit court granted Defendants' motions to dismiss their respective indictments because of the Hicks rule violations. The appellate court affirmed in the case of Garrick Powell on the grounds that Powell's attorney did not expressly consent to a trial date beyond the Hicks date but reversed in the case of Lateekqua Jackson, determining that Jackson expressly consented a trial date beyond the Hicks date. The Supreme Court reversed in part and reversed in part, holding (1) through his conduct, Powell's counsel sought a trial date that exceeded the Hicks date, thus precluding dismissal of the indictment against him due to the Hicks violation; and (2) through her conduct, Jackson's attorney sought a trial date that exceeded the Hicks date, thereby precluding dismissal of the indictment as a remedy for the Hicks violation. View "Jackson v. State" on Justia Law

The Court of Appeals reversed the judgment of the circuit court convicting Defendant of first-degree murder and related handgun offenses, holding that the circuit court abused its discretion in permitting a firearms examiner to testify, without qualification, that bullets left at a murder scene were filed from a gun Defendant had acknowledged was his, and the error was not harmless.On appeal, Defendant argued that the circuit court abused its discretion in admitting the firearms identification testimony based on testimony, reports, and studies that called into question the reliability of firearms identification analysis. The Court of Appeals agreed and reversed the case for a new trial, holding that the circuit court (1) did not abuse its discretion in ruling that the firearms examiner could testify about firearms identification generally and other information; but (2) erred in permitting the examiner to opine without qualification that the crime scene bullets were fired from Defendant's firearm. View "Abruquah v. State" on Justia Law

The Supreme Court remanded this case for additional fact-finding, holding that this Court declines to reach the merits of the questions for which the Court granted certiorari because additional fact-finding was required as to the origin of a DNA sample collected pursuant to a search warrant.During an investigation in another homicide case the State collected a DNA sample from Petitioner pursuant to a search warrant and developed a DNA profile of Petitioner. The State later charged Petitioner in connection with the homicide but later nol prossed the charges. A DNA profile developed from evidence collected at the crime scene in the instant case matched Petitioner's DNA profile from previous case, and Petitioner was charged with attempted first-degree murder. Petitioner filed a motion to suppress, arguing that his previously-taken DNA sample should have been expunged under section 2-511 of the Public Safety Article. The circuit court denied the motion, concluding that section 2-511 only applies to "arrestee and convicted-offender DNA samples" and not samples gathered pursuant to a search warrant. The Supreme Court held that remand was required because the record was unclear as to whether the circuit court determined that the DNA sample was recovered pursuant to a search warrant or was a so-called arrestee sample or forensic sample. View "Walker v. State" on Justia Law

The Supreme Court affirmed the judgment of the appellate court affirming Petitioner's conviction for child sexual abuse and other related sexual offenses, holding that Petitioner was not entitled to relief on his claims of error.At issue on appeal was whether the circuit court erred in granting the State's pre-trial motion to introduce evidence of Petitioner's 2010 conviction for sexual assault against another individual under Md. Cts. & Jud. Proc. Art. (CJP) 10-923, which permits the admission of certain circumstances of prior sexually assaultive behavior in prosecutions for child sexual offenses. The Supreme Court affirmed, holding (1) there is no factor that circuit courts must consider in every case when conducting an analysis under CJP 10-923(e)(4); (2) the motions judge did not abuse his discretion in determining that the probative value of Petitioner's 2010 conviction was not substantially outweighed by the danger of unfair prejudice; and (3) Petitioner waived his remaining argument. View "Woodlin v. State" on Justia Law

The Court of Appeals held that Defendant had a reasonable expectation of privacy in data contained on his hard drive and that the government conducted an unreasonable search by examining data without any authority to do so either by a warrant or an exception to the warrant requirement.At issue was whether the consensual creation of a copy of the hard drive of Defendant's seized laptop computer permanently eliminated Defendant's privacy interest in the hard drive. The circuit court denied Defendant's motion to suppress and ultimately convicted him of three counts of distribution of child pornography. The appellate court reversed, concluding that individuals have a legitimate expectation of privacy in the digital data within their computer and that Defendant's revocation of his consent to examine the data from his laptop precluded a forensic examination of the mirror-image copy of its hard drive without a warrant. The Court of Appeals affirmed, holding that the search in this case was unreasonable after Defendant withdrew his consent. View "State v. McDonnell" on Justia Law

The Court of Appeals affirmed the judgment of the appellate court reversing the decision of the circuit circuit court that examination of data contained on Defendant's hard drive was not a search in violation of the Fourth Amendment, holding that the government violated Defendant's Fourth Amendment rights in this case.Defendant voluntarily consented to government agents seizing his laptop computer, creating a copy of its hard drive, and searching the data on it. After the copy was made but before the government examined the data Defendant withdrew his consent. Defendant moved to suppress the evidence from the forensic examination of the copy of his laptop's hard drive. The circuit court denied the motion. On appeal, Defendant asserted that he had a legitimate expectation of privacy in the mirror-image copy of his laptop hard drive. The appellate court agreed and reversed. The Court of Appeals affirmed, holding (1) Defendant had a reasonable expectation of privacy in the data contained on his hard drive; (2) because the government did not examine the data before Defendant withdrew his consent Defendant did not lose his reasonable expectation of privacy in the data; and (3) the government conducted an unreasonable search by examining the data without any authority to do so. View "State v. McDonnell" on Justia Law

The Court of Appeals reversed Petitioner's conviction for first-degree murder and use of a handgun in the commission of a crime, holding that the circuit court erred in permitting a firearms examiner to testify, without qualification, that bullets left at a murder scene were fired from a gun that Petitioner had acknowledged was his, and the error was not harmless.In arguing that the circuit court abused its discretion in permitting the firearms examiner's testimony Petitioner cited reports, studies, and testimony calling into question the reliability of firearms identification analysis. The Court of Appeals agreed with Petitioner and reversed and remanded the case for a new trial, holding (1) the reports, studies, and testimony presented to the circuit court demonstrated that the firearms identification methodology employed in this case could not reliably support an unqualified conclusion that the bullets were fired from a particular firearm; and (2) this Court was not convicted, beyond a reasonable doubt, that the error in no way influenced the verdict. View "Abruquah v. State" on Justia Law