Justia Maryland Supreme Court Opinion Summaries

Petitioner was charged in a five-count indictment with burglary and related crimes. On the morning of trial, the prosecutor asked the court to amend Count Four from theft of less than $1,000 to theft of at least $1,000 but less than $10,000. The amendment of Count Four substituted felony theft for misdemeanor theft. The court allowed the amendment of the indictment. After a trial, the jury found Petitioner guilty of fourth degree burglary, theft of goods having a value of at least $1,000, and theft of good valued under $100. The Court of Appeals reversed the conviction, holding (1) the amendment of Count Four of the indictment changed the character of the offense charged, and therefore, the trial court violated Maryland Rule 4-204 in permitting the State, over Petitioner’s objection, to amend the charging document; and (2) that violation was prejudicial per se, entitling Petitioner to a remand for entry of a judgment of conviction and imposition of sentence on the originally charged misdemeanor of theft of property valued at less than $1,000. View "Counts v. State" on Justia Law

After a jury-waived trial, Petitioner was convicted of possession of oxycodone with intent to distribute. Petitioner appealed, arguing that he was entitled, by application of the rule established in Riley v. California, decided by the Supreme Court, to suppression of the evidence obtained as the result of the search of his cell phone incident to his lawful arrest. The Court of Appeals affirmed, holding that the officer who searched Petitioner’s cell phone acted in good faith on then-controlling authority in Maryland in searching Petitioner’s cell phone, and therefore, Petitioner was not entitled to have the cell phone data excluded at trial. View "Demby v. State" on Justia Law

Petitioner was convicted of possession with intent to distribute marijuana, possession of marijuana, and possession of drug paraphernalia. Petitioner appealed the denial of his motion to suppress text messages that the police obtained during the warrantless search of his cell phone incident to his lawful arrest. The Court of Appeals affirmed, holding that the trial court properly denied Petitioner’s motion to suppress the data obtained from his cell phone, as (1) in light of the U.S. Supreme Court’s decision in Riley v. California, officers must generally secure a warrant before conducting searches of data on cell phones; but (2) the police in this case acted in good faith on then-controlling authority in Maryland in searching Petitioner’s cell phone, and therefore, Petitioner was not entitled to suppression of the data obtained from his cell phone. View "Spence v. State" on Justia Law

After a jury trial, Defendant was convicted of first-degree murder, use of a handgun in the commission of a crime of violence, and wearing, carrying, and transporting a handgun. Defendant was sentenced to life imprisonment for the murder. Defendant appealed, arguing that a witness’s placement in protective housing for several months leading up to the murder trial constituted a “benefit” that would compel the trial judge to give a particularized jury instruction - called the “Witness Promised Benefit” instruction - pertaining to the witness’s credibility. The Court of Special Appeals affirmed, concluding that the trial court did not abuse its discretion in declining to give the jury instruction. The Court of Appeals affirmed, holding that protective housing provided to a witness in a first degree murder case is not the type of “benefit” contemplated by the “Witness Promised Benefit” pattern instruction, and therefore, the trial court did not err in not giving the instruction. View "Preston v. State" on Justia Law

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