Justia Maryland Supreme Court Opinion Summaries

The Court of Appeals vacated the judgment of the appellate court affirming the decision of the circuit court denying Appellant's motion to dismiss the charges against him after this Court remanded his case to the circuit court with instructions to grant his petition for writ of actual innocence and to conduct a new trial, holding that it was not possible for the Court to meaningfully evaluate whether Appellant suffered irreparable prejudice for which dismissal of the charges was the only feasible remedy.Appellant was convicted of first-degree murder. After Appellant's petition for writ of actual innocence was denied, the Court of Appeals concluded that the circuit court erred in denying the petition. Before his retrial, Appellant moved to dismiss the charges based on due process and double jeopardy violations. The circuit court denied the motion, after which Appellant and the State entered into a plea agreement. The appellate court affirmed the denial of Appellant's motion to dismiss. The Court of Appeals vacated the judgment and remanded the case, holding that, given that the new trial ordered by the Court did not take place, it was not possible for this Court to assess beyond mere speculation what the evidence might have consisted of at retrial. View "Smith v. State" on Justia Law

The Court of Appeals affirmed in part and reversed in part the judgment of the appellate court deciding the merits of Defendant's appeal and affirming Defendant's conviction for voluntary manslaughter and related offenses, holding that the constitutional right to a fair trial extends to appellate proceedings, that the appellate court erred in deciding the merits of Defendant's appeal, and that a new trial was required.During Defendant's appeal, the appellate court compared Defendant, an African American man, to the mythical monster Grendel in Beowulf. On appeal to the Court of Appeals Defendant argued that this reference evoked racist tropes of African Americans and that other passages in the appellate court's dicta deprived him of his constitutional right to a fair and impartial appellate process. The Court of Appeals remanded the case for a new trial, holding (1) the right to fair and impartial judges extends to appellate proceedings; and (2) the appellate court erred in concluded that the exclusion of certain evidence was harmless because its exclusion was harmful, reversible error. View "Belton v. State" on Justia Law

The Court of Appeals affirmed the judgment of the circuit court denying Petitioner's petition for post-conviction DNA testing pursuant to Md. Code Ann. Crim. Proc. 8-201(b)(1), holding that Petitioner was not entitled to relief on his allegations of error.Petitioner was convicted of first-degree murder and other offenses and sentenced to life imprisonment plus a term of 150 years' imprisonment. In his post-conviction petition, Petitioner asserted that there was a reasonable probability that DNA testing of certain evidence had the scientific potential to produce exculpatory or mitigating evidence. The circuit court denied the petition. The Court of Appeals affirmed, holding that the circuit court properly denied the petition because the record and testimony reflected that any results of testing the subject evidence would not produce exculpatory or mitigating evidence. View "Satterfield v. State" on Justia Law

The Court of Appeals affirmed Defendant's conviction of sexual abuse of a minor under Md. Code Ann., Crim. Law (CR) 3-602, holding that, under the applicable standard of review, the evidence was sufficient for a rational juror to find that, with his in-classroom conduct, Defendant, a thirty-year-old substitute teacher, engaged in an act that involved sexual exploitation of a minor.Defendant indulged in a sexually exploitative relationship with A.G., a twelve-year-old student, during out-of-school hours. The appellate court reversed Defendant's conviction for sexual abuse of a minor on the grounds that he had not "said or implied anything sexual" in his conversation with A.G. in school. The Court of Appeals reversed, holding (1) the occurrence of sexual exploitation outside of the perpetrator's time of responsibility for supervision of the minor may be used to establish child sexual abuse under CR 3-602, but there must be a showing that the perpetrator engaged in an act relating to, affecting or that was a part of the sexual exploitation while the perpetrator was responsible for the care, custody, or supervision of the minor; and (2) the evidence demonstrated that Defendant's in-school conduct fell within the meaning of the language of the statute. View "State v. Krikstan" on Justia Law

The Court of Appeals affirmed the judgment of the appellate court affirming the circuit court's denial of Petitioner's petition for writ of actual innocence, holding that there was no abuse of discretion.After a jury trial, Petitioner was convicted of first-degree murder, use of a handgun in a crime of violence, and wearing or carrying a handgun. Petitioner was sentenced to life imprisonment without parole for the murder charge and an additional twenty years' imprisonment for the handgun offenses. In his petition for writ of actual innocence, Petitioner claimed that three categories of new evidence created a substantial possibility of a different outcome at trial. The circuit court denied the petition, and the appellate court affirmed. The Court of Appeals affirmed, holding that Petitioner failed to show that the circuit court abused it discretion in denying his petition for actual innocence. View "Carver v. State" on Justia Law

In this case considering whether unprovoked flight in a high-crime area should no longer be considered a factor that gives rise to rebate articulable suspicion for a Terry stop, the Court of Appeals held that, under the totality of the circumstances, Defendant's rights under either the Fourth Amendment or Article 26 of the Maryland Declaration of Rights were not violated.Defendant, who was standing in an high-crime area in Baltimore City, fled when he saw an unmarked vehicle. Ultimately, detectives stopped Defendant and found a gun in his waistband. Defendant filed a motion to suppress, arguing that the detectives lacked reasonable suspicion to stop him based solely on his unprovoked flight in a high-crime area. The Supreme Court affirmed the denial of the motion, holding that, under under the totality of the circumstances analysis, a court may consider whether unprovoked flight is an indication of criminal activity that, together with evidence of a high-crime area and any other relevant factors, establishes reasonable suspicion for a stop, or whether unprovoked flight, under the circumstances of the case, is a factor consistent with innocence that adds little or nothing to the reasonable suspicion analysis. View "Washington v. State" on Justia Law

The Court of Appeals affirmed the judgment of the court of special appeals reversing the decision of the post-conviction court determining that Appellant's trial counsel provided ineffective assistance by failing to object to certain incomplete or missing jury instructions, holding that defense counsel's failure to object to a "CSI effect" voir dire question did not render her performance constitutionally deficient.In 2007, Appellant was convicted by a jury of murder. In 2010 and 2011, the Court of Appeals held in three cases that a CSI effect message from the bench constituted reversible error. In 2014, Appellant filed a pro se petition for post-conviction relief arguing that he received ineffective assistance of counsel based on his counsel's failure to object to the trial court's CSI effect voir dire question. In 2020, the post-conviction court granted the petition for post-conviction relief and ordered a new trial. The court of special appeals reversed. The Court of Appeals affirmed, holding that under the professional norms that existed at the time of Appellant's trial, defense counsel's failure to object to a CSI-effect voir dire question did not render her performance constitutionally deficient. View "McGhee v. State" on Justia Law

The Court of Appeals vacated the judgment of the court of special appeals concluding that Appellant had waived his right to appeal the denial of his motion to suppress, holding that Appellant did not waive his right to appeal the suppression ruling.After he had been convicted of a crime of violence Appellant was indicted on charges of possessing a regulated firearm. Appellant filed a motion to suppress the gun and the loaded magazine recovered by law enforcement officers while conducting a warrantless search of his hotel room. Thereafter, the State filed a superseding indictment under a new case number to add additional charges. Appellant subsequently renewed his motion to suppress in the new case. The trial court denied the motion, and Appellant was convicted of first-degree assault and other crimes. The court of appeals affirmed, ruling that Appellant waived his challenge to the denial o this motion to suppress. The Court of Appeals remanded the case for further consideration, holding that defense counsel did not waive Appellant's right to appellate review of the denial of his motion to suppress. View "Huggins v. State" on Justia Law

The Court of Appeals affirmed the judgment of the court of special appeals affirming the decision of the circuit court denying Defendant's motion to suppress the fruits of the warrantless search of his backpack and the warranted search of his cell phone, holding that Defendant was not entitled to relief on appeal.After a school resource officer broke up a fight in which Defendant was involved, Defendant's backpack dropped to the ground. When the officer picked up the backpack Defendant ran from the scene. The officer subsequently searched the backpack and discovered a stolen firearm and three cell phones. The officers obtained a warrant to search one cell phone. Thereafter, Defendant was charged with robbery and other offenses. After the trial court denied Defendant's suppression motion as to both searches Defendant pleaded guilty to conspiracy to commit robbery and wearing, carrying, and transporting a handgun. The court of special appeals affirmed. The Supreme Court affirmed, holding (1) because Defendant abandoned his backpack the warrantless search of his backpack was constitutionally permissible; and (2) the warrant authorizing the search of the cell phone did not comply with the particularity requirement of the Fourth Amendment, but the good faith exception to the exclusionary rule applied to the fruits of the cell phone search. View "Richardson v. State" on Justia Law

The Court of Appeals affirmed the judgment of the court of special appeals ruling that it was error to admit a video recording in the underlying criminal trial but the error was harmless beyond a reasonable doubt, holding that the admission of the challenged video was harmless beyond a reasonable doubt.After a jury trial, Defendant was convicted of two counts of second-degree sexual offense and one count of sexual abuse of a minor by a household or family member. On appeal, Defendant argued that the trial court erred by admitting a video recording of a conversation the victim had with her biological grandmother repeating allegations of abuse. The court of appeals concluded that the admission of the video recording was error but that the error was harmless. The Court of Appeals affirmed, holding that, beyond a reasonable doubt, the error in no way influenced the jury's verdict. View "Gross v. State" on Justia Law