Justia Maryland Supreme Court Opinion Summaries

After a jury trial, Petitioner was convicted of first-degree assault and aggravated cruelty to animals. The court of special appeals affirmed the convictions. Petitioner petition for writ of certiorari, arguing (1) the evidence was insufficient to support his felony animal cruelty conviction, and (2) his attorney's failure, after the close of all evidence, to renew the motion for judgment of acquittal constituted ineffective assistance. The Court of Appeals affirmed, holding (1) the evidence presented at trial was sufficient to support Petitioner's conviction of felony animal cruelty; and (2) it was unnecessary to address Petitioner's claim of ineffective assistance since it rested solely on his assertion that the evidence presented against him was insufficient to sustain his felony animal cruelty conviction. View "Haile v. State" on Justia Law

Tiffany Alston, a former member of the Maryland House of Delegates, was removed as a delegate after she was convicted and sentenced for misconduct in office. Before Alston fulfilled the conditions of her sentence, the assistant attorney general declared her removed from her House seat by operation of law. Gregory Hall was nominated to fill Alston's seat. While Hall's nomination was before the Governor, the Governor requested that the Democratic Central Committee of Prince George's County (Central Committee) withdraw the nomination. Hall filed a complaint seeking to prevent the withdrawal of his nomination. Alston filed, as an intervener and third-party plaintiff in the same case, a separate complaint seeking a declaration that she had been merely suspended, rather than removed, from her House seat because her conviction and sentence had been converted into probation before judgment. The circuit court ruled (1) Alston had been removed by operation of law on the date she was sentenced for her misconduct in office conviction; and (2) the Central Committee had the power to rescind Hall's nomination at any time before the Governor made the appointment. The Supreme Court affirmed, finding no error in the circuit court's judgment. View "Hall v. Prince George's County Democratic Cent. Comm." on Justia Law

After a jury trial, Defendant was convicted of two counts of first-degree murder and use of a handgun in the commission of a crime. Defendant appealed, arguing that the trial court's replacement of a juror with an alternate juror without the knowledge or acquiescence of defense counsel was a violation of Maryland Rule 4-326(d) and, therefore, reversible error. The court of special appeals affirmed, holding that no prejudice occurred by the removal of the juror. The Court of Appeals reversed and remanded, holding (1) the trial court's unilateral action in discharging the juror and replacing her with an alternate without first notifying defense counsel was error; and (2) the State did not carry its burden of establishing that Defendant was not prejudiced by the rule violation. View "Grade v. State" on Justia Law

On March 30, 2009, Petitioner committed a theft of property. After a trial held on December 11, 2009, Petitioner was convicted of the theft of property having a value of $615. Petitioner was sentenced to ten years in prison. On October 1, 2009, amendments to the Maryland theft statute took effect that would have made Petitioner's crime a misdemeanor punishable by imprisonment not exceeding eighteen months, a $500 fine, or both. The Court of Appeals granted a petition for a writ of certiorari to decide whether the penalty provisions of the 2009 theft statute amendments were applicable to Petitioner's sentencing. The Court reversed, holding that the sentence imposed upon Petitioner was illegal because it was not authorized by the statute in effect at the time of his trial and sentencing. Remanded. View "Waker v. State" on Justia Law

After a jury trial, Defendant was convicted of second-degree assault in connection with an attack on his girlfriend. The court of special appeals affirmed. At issue before the Court of Appeals was whether the trial court acted within its discretion in responding to a jury question concerning evidence that was not presented at trial. The Supreme Court affirmed, holding that the trial court acted within its discretion in crafting the jury response it did, as (1) trial courts have a duty to answer, as directly as possible, the questions posed by jurors; (2) the circuit court's response in this case closely tracked a pattern jury instruction given earlier; (3) the court's answer did not contradict the trial judge's earlier instructions; and (4) the answer given allowed the jury to draw what inferences it might from the evidence without the court impermissibly suggesting what inferences to draw. View "Appraicio v. State" on Justia Law

In 2006, Petitioner was convicted of child sexual abuse. Petitioner's conviction was based on his inappropriate contact with a minor during the 1983-84 school year when Petitioner was employed as a school teacher. Petitioner was sentenced to ten years incarceration with three years supervised probation upon release. In 2008, Petitioner was released early from prison. In 2009, the General Assembly passed a new law changing the sex offender registration requirements. The new statute retroactively required a child sex offender who committed a sex offense prior to October 1, 2005, but was convicted on or after October 1, 1995, and had not previously been required to register under Maryland law, to now register as a child sex offender. In October 2009, Petitioner unsuccessfully sought a declaration that he not be required to register as a sex offender under the statute. The Supreme Court reversed, holding that the imposition of the registration requirement upon Petitioner violated the ex post facto prohibition contained in the Maryland Declaration of Rights. View "Doe v. Dep't Of Pub. Safety & Corr. Servs." on Justia Law

In 1998, Appellant pleaded guilty to child sexual abuse and third degree sexual offense. Upon conviction, Appellant was required to register as a sex offender for ten years. Since his conviction, however, the statutes changed to require lifetime registration for certain classes of sex offenders. Appellant sought declaratory relief in 2010, claiming he had satisfied the ten-year registration requirement and that he was not subject to lifetime registration. The circuit court declared that Appellant was subject to lifetime registration. The Supreme Court affirmed, holding that Appellant was required to register for life as a sex offender under Md. Code Ann. Crim. Proc. 11-707(a)(4)(iii) because his 1998 convictions made him a tier III sex offender under the current statutory scheme, and he was subject to lifetime registration on September 30, 2010, making retroactive application of the statute proper by its own terms. View "Ochoa v. Dep't of Pub. Safety & Corr. Servs." on Justia Law

Petitioner, a Mexican immigrant who did not speak or comprehend English, was convicted of first degree murder and related offenses. Before trial, Petitioner sought suppression of a statement he made connecting him to the murder. On appeal, Petitioner argued that the State failed to prove that he was properly advised of, and validly waived, his Miranda rights. The court of special appeals concluded that the record developed at the suppression hearing sufficed to permit the court to rule that the Miranda warnings and Petitioner's waiver complied with constitutional dictates. The Supreme Court affirmed, holding that the suppression court reasonably could find, from the totality of the evidence offered by the State, that the State proved both that proper Miranda warnings were adequately conveyed to Petitioner and that he knowingly and voluntarily waived those rights before he was interrogated and made the statement he sought to suppress. View "Gonzalez v. State" on Justia Law

Defendant entered a plea of not criminally responsible to charges of first-degree attempted murder and was found incompetent to stand trial. Defendant was committed to the Perkins Hospital for several years waiting to become competent to stand trial. The charges against him were eventually dismissed pursuant to Md. Code Crim. Proc. 3-107(a), which requires dismissal of charges upon passage of certain time period. The State subsequently re-indicted Defendant, who was again found incompetent and placed at Perkins for another round of incompetency-to-stand-trial (IST) treatment. Defendant challenged his re-indictment, arguing that the State could not continue to confine him by re-indicting him on the same charges that were required to be dismissed. The appellate court reversed. The Supreme Court vacated the appellate court's ruling and remanded, holding (1) section 3-107 expressly provides that a dismissal of charges is without prejudice; but (2) nevertheless, Defendant's IST committment was improper, as (i) the passage of five years without Defendant's becoming competent and the resulting dismissal of his original charges under section 3-107 created the presumption that Defendant could not be restored to competency, and (ii) ordering Defendant in IST commitment, while the presumption that he was unrestorable was in place, was error. View "State v. Ray" on Justia Law

Petitioner was convicted of transporting a handgun in a motor vehicle. A police officer found the handgun in a vehicle he suspected Petitioner had been using a short time earlier for "hacking," which is the provision of taxi services without a license. The police officer located the vehicle by pressing a car remote he had seized, along with a set of car keys, while frisking Petitioner. Before trial, Petitioner moved to suppress the car keys and remote on the ground that the officer seized those items from Petitioner's pants pocket by exceeding the proper scope of a lawful Terry frisk. Petitioner then argued the handgun must be suppressed as the tainted fruit of the earlier seizure of the keys and remote. The circuit court denied Petitioner's motion to suppress the physical evidence. Petitioner appealed, arguing that the officer violated Minnesota v. Dickerson by seizing the keys and car remote without the incriminating character of those items being "immediately apparent." The court of special appeals affirmed. The Supreme Court also affirmed, holding that, by application of the plain feel doctrine, the officer lawfully seized the keys and remote he touched while frisking Petitioner, and therefore, the seizure of the items in dispute was lawful. View "McCracken v. State" on Justia Law