Justia Maryland Supreme Court Opinion Summaries

After a jury trial, Defendant was convicted of first degree felony murder and related charges. On appeal, Defendant argued, inter alia, that the trial court erred when it declined, on the basis of attorney-client privilege, to allow defense counsel to call to the stand the Assistant Public Defender, who represented Defendant’s co-defendant, and question that attorney about a proffer session that her client had with the Assistant State’s Attorney and police prior to entering into the plea agreement. The Court of Appeals affirmed, arguing (1) the limitations the trial judge placed on counsel’s cross-examination of two prosecution witnesses were within the discretion of the trial judge and did not violate Defendant’s right under the federal and state constitutions to confront witnesses against him; and (2) while the attorney-client privilege did not apply to the discussion at the proffer session, the proposed testimony was of minimal relevance, cumulative, and the potential for straying into privileged areas outweighed any probative value. View "Peterson v. State" on Justia Law

Defendant was charged with carjacking and related offenses, various firearms offenses, and possession of illicit drugs. The morning of trial, Defendant’s attorney made an oral motion seeking to exclude evidence derived from a flip cell phone that was seized from Defendant incident to his arrest. The primary evidence obtained from the cell phone was a screen saver image that matched the custom wheel rims of the stolen car. The circuit court denied the motion to suppress. After a jury trial, Defendant was found guilty. The court of special appeals affirmed. Before the Court of Appeals, Defendant relied on the U.S. Supreme Court’s intervening decision in Riley v. California to argue that the arresting officer’s review of photos on Defendant’s cell phone without a warrant was an unconstitutional search, and therefore, the evidence derived from the cell phone should have been suppressed. The Supreme Court affirmed, holding (1) Defendant waived his motion to suppress by failing to make his motion within the time period and with the specificity required by the Maryland Rules; and (2) even had the motion been made in a timely manner, the screen saver image was admissible under Riley. View "Sinclair v. State" on Justia Law

Pursuant to a plea agreement, Respondent pleaded guilty to having engaged in a conspiracy to distribute marijuana. Respondent later sought to have the conspiracy conviction vacated, asserting that her guilty plea was not knowing and voluntary because she had not been informed at the time of the plea of the elements or essential nature of the crime of conspiracy. The circuit court denied coram nobis relief. The Court of Special Appeals reversed, concluding that Respondent’s guilty plea was invalid and must be vacated. The Court of Appeals reversed, holding (1) Respondent did not waive her right to pursue coram nobis relief; and (2) Respondent’s guilty plea was knowingly and voluntarily made. View "State v. Smith" on Justia Law

Defendant was charged with armed robbery. During trial, a DNA expert testified regarding the work of another DNA analyst. The expert was a supervisor in the same lab, reviewed the work of the other analyst, and came to his own conclusion that was consistent with the conclusion of the other analyst. The analyst herself, however, did not testify. The Court of Special Appeals concluded that the admission of the DNA case report without the analyst’s testimony violated Defendant’s ability to confront his accuser. The Court of Appeals affirmed, holding that the language “within a reasonable degree of scientific certainty” in the DNA report rendered the report testimonial within Williams v. Illinois. View "State v. Norton" on Justia Law

At the center of this case was the report of a Baltimore Sun reporter that a high-ranking Maryland law enforcement ballistic expert named Joseph Kopera had lied, as an expert witness for the prosecution, about his credentials and qualifications in Maryland trials for more than twenty years. Kopera testified in the trials of Ronnie Hunt and Kevin Hardy (together, Respondents). Respondents, both incarcerated, filed petitions for writ of actual innocence in their related cases, alleging that the questions about Kopera’s qualifications were newly discovered evidence that created a substantial or significant possibility that the outcomes in their trials may have been different had Kopera not lied. Respondents also asserted that the newly discovered evidence could not have been discovered in time to move for a new trial under Maryland Rule 4-331. The circuit court denied the petitions without a hearing. The Court of Special Appeals reversed in both instances and remanded for further proceedings. The Court of Appeals affirmed, holding that because the petitions filed by Respondents satisfied the pleading standards established by Md. Code Ann. Crim. Proc. 8-301 and evaluated in Douglas v. State, Respondents were entitled to hearings on their petitions. View "State v. Hunt" on Justia Law

Pursuant to a binding plea agreement, Defendant pleaded guilty to two counts of first degree murder. Two decades after he was sentenced, Defendant filed a motion to correct illegal sentence and motion for credit against time spent in custody, arguing that his sentence on Count I was illegal because it exceeded the sentence agreed upon by the parties under the terms of the plea agreement. The State responded by moving to correct the entire sentence, contending that the sentences on both Count I and Count III were illegal. The circuit court concluded that the sentences on both counts were illegal and ordered a resentencing in accordance with the original plea agreement. The Court of Special Appeals affirmed, agreeing that Defendant’s original sentence on Count III was illegal because it was below the binding plea agreement. The Court of Appeals affirmed, holding that a sentence below a binding plea agreement constitutes an illegal sentence within the meaning of Maryland Rule 4-345(a). View "Bonilla v. State" on Justia Law

These three cases, consolidated for the purposes of this opinion, involved the same legal issues arising out of the Court of Appeals’ opinion in Griffin v. State, in which the Court addressed the admissibility of a screenshot of a MySpace page. This appeal addressed Griffin’s application to the authentication of screenshots of messages allegedly sent through social networking websites. In the three cases, the messages were sent via a Facebook timeline, on Twitter through direct messages and public tweets, and through Facebook messages. The Court of Appeals held that, “in order to authenticate evidence derived from a social networking website, the trial judge must determine that there is proof from which a reasonable juror could find that the evidence is what the proponent claims it to be.” Accordingly, the Court held that, in each of the cases, the trial court did not err in (1) excluding the admission of the four pages of the Facebook conversation; (2) admitting the “direct messages” and “tweets” in evidence; and (3) admitting the Facebook messages authored by the defendant. View "Sublet v. State" on Justia Law

Defendant was charged with robbery with a dangerous weapon, conspiracy to commit robbery and first degree assault. During voir dire, the trial judge failed to accede to Defendant’s request that he be brought to the bench for conferences during voir dire. During one of those conferences, a juror who was questioned at the bench without Defendant’s presence was selected to serve on the jury. The Court of Special Appeals reversed Defendant’s conviction, concluding that his exclusion from bench conferences during voir dire was not harmless beyond a reasonable doubt. The Court of Appeals affirmed, holding that the judge’s error in failing to bring Defendant to the bench for conferences during voir dire was not harmless where the juror who was questioned at the bench without Defendant’s presence was selected to serve. View "State v. Yancey" on Justia Law

The State charged Petitioner with first-degree murder and other crimes. Petitioner moved to suppress a pretrial identification on the grounds that the identification was hearsay and inadmissible under the Confrontation Clause. The identification was made by the victim (“declarant”) two years before his death. The circuit court granted the motion to suppress, determining that the declarant’s identification of Defendant fell under the “dying declaration” exception to the rule against hearsay but was testimonial and inadmissible under the Confrontation Clause. The Court of Special Appeals reversed, concluding that the declarant made a dying declaration and that the Confrontation Clause does not apply to dying declarations. The Court of Appeals affirmed, holding (1) the State may appeal from a trial court’s exclusion of intangible evidence based on a determination that the evidence’s admission would be a constitutional violation; (2) the circuit court was correct in determining that the declarant’s identification of Defendant was a dying declaration; and (3) the Confrontation Clause is not applicable to dying declarations, and therefore, the Court need not address whether the declarant’s identification of Defendant was testimonial or non-testimonial. View "Hailes v. State" on Justia Law

After a retrial, Petitioner was found guilty of attempted second degree arson. Petitioner appealed, arguing that the prosecutor’s opening statement violated his privilege against self-incrimination guaranteed by the Fifth Amendment, Article 22 of the Maryland Declaration of Rights, and Md. Code Ann. Cts. & Jud. Proc. 9-107. Specifically, Petitioner asserted that the prosecutor violated his right to protection from adverse comment on his decision not to testify at trial by referring in opening statement to what Petitioner “will tell” the jury. The Court of Special Appeals affirmed. The Court of Appeals reversed, holding that the prosecutor’s remarks ran afoul of the prohibition against making an adverse comment upon a defendant’s failure to testify, and the error was not harmless. Remanded for a new trial. View "Simpson v. State" on Justia Law