Justia Maryland Supreme Court Opinion Summaries

The State charged Petitioner with various drug-related crimes. Petitioner’s co-defendant filed three proposed voir dire questions asking whether any prospective juror had ever been the victim of a crime or a member of a law enforcement agency. The circuit court declined to ask any of the proposed voir dire questions. The jury ultimately convicted Petitioner of drug-related crimes. The court of special appeals affirmed. The Court of Appeals reversed, holding (1) a trial court need not ask during voir dire whether any prospective juror has ever been the victim of a crime, but, on request, a trial court must ask whether any of the prospective jurors have strong feelings about the crime with which the defendant is charged; and (2) where all of the State’s witnesses are members of law enforcement agencies and/or where the basis for a conviction is reasonably likely to be the testimony of members of law enforcement agencies, on request, a trial court must ask during voir dire whether any of the prospective jurors have ever been a member of a law enforcement agency. View "Pearson v. State" on Justia Law

After a jury trial, Petitioner was convicted of second degree murder, two counts of attempted second degree murder, and related weapons offenses. The court of special appeals affirmed. During the trial, defense counsel informed the trial court that he had trouble communicating with Petitioner, mentioned that there was “something wrong” with Petitioner, and requested that Petitioner be evaluated. The Court of Appeals granted certiorari to answer the question of whether defense counsel triggered the competency statute, requiring the trial court to order a competency evaluation and make a competency determination. The Court of Appeals affirmed, holding that defense counsel did not trigger the trial judge’s duty to make a competency determination under the circumstances. View "Kennedy v. State" on Justia Law

After a jury trial, Petitioner was convicted of distribution of cocaine and conspiracy to distribute cocaine. The sentencing judge imposed a twenty-five-year mandatory enhanced sentence without the possibility of parole based on Petitioner’s prior drug convictions. Petitioner appealed, alleging that his sentence was illegal under Maryland Rule 4-345(a). The Court of Appeals affirmed, holding (1) Petitioner waived any challenge to the imposition of his sentence because he failed to object during the sentencing proceeding; and (2) even if the Court were to determine that the issue was preserved, the trial court did not err in imposing an enhanced sentence where the evidence was sufficient for the sentencing judge to conclude that Petitioner committed the qualifying predicate offenses beyond a reasonable doubt. View "Bryant v. State" on Justia Law

After a jury trial, Petitioner was found guilty of conspiracy to commit first degree burglary and sentenced to ten years’ incarceration. On appeal, Petitioner argued, among other things, that the trial court erred by offering, over objection, an “investigative or scientific techniques” jury instruction. The court of special appeals affirmed the conviction. At issue before the Court of Appeals was whether the trial court violated the standards set forth in Atkins v. State and Stabb v. State that an “anti-CSI effect” instruction, limited only to curative administration, shall not be entertained without proof that a “CSI effect” exists and is only triggered when a material misstatement of the law occurs. The Court of Appeals reversed, holding that the trial court in this case erred by giving the contested instruction, as the instruction was given preemptively and defense counsel did not misstate the law or the State’s burden. Remanded for a new trial. View "Robinson v. State" on Justia Law

After a jury trial, Petitioner was convicted of theft of property valued in excess of $100,000 and related offenses stemming from his unauthorized occupancy of a home for approximately seven months. Defendant appealed the sufficiency of the evidence supporting his convictions for theft, theft of property valued in excess of $100,000, and first-degree burglary. The Court of Appeals affirmed in part and reversed in part, holding (1) the evidence was sufficient to support a conviction for theft; (2) the evidence was insufficient to support a conviction for theft of property valued in excess of $100,000 but was sufficient to support a conviction for theft of property having a value of at least $10,000 but less than $100,000; and (3) the evidence was sufficient to support a conviction for first-degree burglary. View "Hobby v. State" on Justia Law

Petitioner was charged with various offenses, including reckless endangerment. Because the indictment did not set out the elements of the charged offense or the factual basis for that offense, Petitioner requested that the State provide him with a bill of particulars. Rather than answer each question Petitioner asked in his request, the State simply directed Petitioner to discovery. The trial court overruled Petitioner’s exceptions, finding that the State’s responses satisfied the statutory requirement that the State’s response “furnish the particulars sought.” A jury found Petitioner guilty of reckless endangerment. Petitioner appealed, arguing that the trial court abused its discretion by denying his exceptions to the State’s non-specific responses to the questions posed in his request for a bill of particulars. The court of special appeals affirmed. The Court of Appeals reversed, holding (1) the State’s responses to the questions posed in Petitioner’s demand for a bill of particulars were inadequate; and (2) therefore, the trial court abused its discretion when it overruled Petitioner’s exceptions to those responses. View "Dzikowski v. State" on Justia Law

Petitioner was charged in two cases with second-degree burglary, theft, and malicious destruction of property. Petitioner moved to suppress all evidence obtained as the result of law enforcement's global positioning system (GPS) tracking of his vehicle. The motions were denied, and Petitioner was convicted of various charges arising out of the two cases. While Petitioner's appeal of the convictions was pending, the U.S. Supreme Court decided United States v. Jones, which held that GPS tracking of a vehicle constitutes a search under the Fourth Amendment. The court of special appeals affirmed the consolidated appeals. The Court of Appeals affirmed, holding that Petitioner was not entitled to the suppression of evidence where (1) before Jones, binding appellate precedent in Maryland authorized the GPS tracking of a vehicle on public roads; (2) law enforcement officers acted in objectively reasonable reliance on that authority when they conducted their GPS tracking of Petitioner's vehicle; and (3) the Davis v. United States good-faith exception to the exclusionary rule applied in this case. View "Kelly v. State" on Justia Law

After a jury trial, Petitioner was convicted of first-degree murder and sentenced to life imprisonment. The court of special appeals affirmed the conviction. The Supreme Court affirmed, holding that trial court (1) complied with Md. Code Ann. Crim. Proc. 3-104(a) when it allowed Petitioner to withdraw his request for a competency evaluation and afterwards did not make a competency determination on the record, because Petitioner's withdrawal of his request for a competency evaluation, in addition to the slight evidence on the record to support a finding of incompetency, supported the circuit court's acknowledgment that the issue of competency was moot and the presumption that Petitioner's competency was not rebutted; and (2) properly denied Petitioner's request for an instruction on legally adequate provocation because the evidence presented did not generate such a defense. View "Wood v. State" on Justia Law

Petitioner was charged with murder and other related offenses. During defense counsel's opening statement, counsel referenced Petitioner's willingness to take a lie detector test during his interrogation by the police. The trial judge gave a curative instruction to the jury immediately following the improper reference. Two days further into the trial, the prosecutor filed a motion for a mistrial for reason of that improper remark. The trial judge granted the motion. Petitioner subsequently filed a motion to dismiss, arguing that retrial was prohibited under double jeopardy principles. The court of special appeals affirmed, concluding that the trial judge properly determined that manifest necessity existed for a mistrial, and therefore, double jeopardy principles did not prevent a retrial. The Court of Appeals affirmed, holding that the trial judge did not abuse his discretion in making a determination of manifest necessity to declare a mistrial where the judge considered his previously issued curative instruction and found it insufficient to cure the prejudice caused by defense counsel's improper remark. View "Simmons v. State" on Justia Law

After a jury trial, Petitioner was convicted of multiple counts of second degree murder and other crimes. The court of appeals affirmed, concluding that the trial court erred in prohibiting Petitioner's cross-examination of a State's witness regarding the witness' expectation of leniency in a separate pending case should he testify against Petitioner but that the error was harmless. The Court of Appeals reversed, holding (1) the trial court erred in limiting Petitioner's cross-examination of the witness with regard to his expectation of leniency; and (2) contrary to the conclusion of the intermediate appellate court, the effect of that error was not harmless to the result of the trial. View "Dionas v. State" on Justia Law