Justia Maryland Supreme Court Opinion Summaries

A jury convicted Petitioner Antajuan Wilson of first-degree murder and related offenses, including use of a handgun in the commission of a crime of violence. Petitioner appealed, arguing that he was entitled to a new trial on the ground that the circuit court erroneously refused to instruct the jury on the partial defenses of imperfect self defense and the rule of provocation. The court of special appeals affirmed. The Court of Appeals reversed, holding (1) because the evidence was sufficient to generate the issue of whether there was a reasonable doubt that Defendant did not kill in self defense, the trial court erred by refusing to instruct the jury on the mitigation defense of imperfect self defense; but (2) the circuit court correctly rejected the request for a rule of provocation instruction. View "Wilson v. State" on Justia Law

After a jury trial, Petitioner Arthur White was convicted of first-degree murder, conspiracy to commit murder, armed robbery, and related offenses. The court of special appeals (1) affirmed the majority of Petitioner's convictions, but (2) reversed his convictions for first-degree murder and use of a handgun in the commission of a crime of violence after determining that the jury instructions and the prosecutor's argument to the jury were plain error. The Court of Appeals reversed the judgment of the court of special appeals and directed that Petitioner's convictions of murder and use of a handgun be reinstated, holding that the circuit court did not commit plain error during the jury instructions or during the prosecutor's rebuttal argument. View "White v. State" on Justia Law

After a jury trial, Petitioner James Sweetney was convicted of robbery and related offenses, including use of a handgun in the commission of a crime of violence. At issue on appeal was whether Petitioner's constitutional right of confrontation was violated when the trial court curtailed Petitioner's cross-examination of the State's detective regarding the contents of a search warrant return that directly contradicted the detective's direct testimony about recovering a key piece of evidence. The court of special appeals affirmed. The Court of Appeals affirmed, holding that the trial court did not abuse its discretion in curtailing the cross-examination of the State's detective about ambiguous language in the out-of-court statement prepared by another law enforcement officer who did not testify at trial. View "Sweetney v. State" on Justia Law

Petitioner Erick Spencer was convicted of robbery, theft over $500, and second degree assault. On appeal, Spencer challenged the sufficiency of the evidence to sustain his robbery conviction. The Court of Appeals reversed the robbery conviction, holding that the State failed to prove an essential element of the crime of robbery. Although the State in this case presented evidence showing that Spencer entered an automobile service center and stated to the cashier, "Don't say nothing," there was no evidence that Spencer conducted himself in a manner that could cause apprehension in a reasonable person that Spencer was about to apply force. Remanded. View "Spencer v. State" on Justia Law

After a jury trial, Petitioner Khiry Montay was convicted of first-degree felony murder and related offenses, including use of a handgun in the commission of a crime of violence. The court of special appeals affirmed. The Court of Appeals reversed, holding (1) Petitioner's confession, which was obtained when he was one month past his sixteenth birthday, should have been suppressed as involuntary for several reasons, including the fact that the police unnecessarily delayed presenting Petitioner to a district court commissioner in order to interrogate him and the fact that the police ignored thirteen requests by Petitioner to speak to his mother; and (2) Petitioner was entitled to a new trial at which the State was prohibited from introducing evidence of Petitioner's inculpatory statement. Remanded. View "Moore v. State" on Justia Law

In a guardianship proceeding, the juvenile court granted guardianship of Child to the Department of Social Services (DSS). Mother was deemed to have consented to the guardianship because neither she nor her appointed attorney filed a timely notice of objection on her behalf. The court of special appeals reversed. At issue on appeal was whether Mother had a statutory right to effective assistance of counsel despite her failure to file a timely notice of objection and request for counsel. Mother asserted that because DSS alleged that Mother was disabled, she had a right to counsel in the guardianship proceeding. The Court of Appeals affirmed, holding (1) once counsel for Mother had entered her appearance, at the request of DSS and after DSS alleged that Mother may have been disabled, Mother thereafter had a right to effective assistance of counsel as an allegedly disabled parent in a guardianship proceeding; (2) counsel rendered ineffective assistance because, after entering her appearance on behalf of Mother, counsel failed to preserve Mother's right to challenge the guardianship proceedings by failing to file a timely notice of objection; and (3) Mother was entitled to file a belated notice of objection. View "In re Adoption of Chaden M." on Justia Law

Petitioner Mark Denisyuk, a noncitizen, pleaded guilty to a deportable offense. Petitioner later filed a petition for postconviction relief, asserting that defense counsel was constitutionally ineffective by failing to notify him of the deportation risks of his guilty plea. The postconviction court held that Petitioner was prejudiced by defense counsel's failure to provide proper advice concerning immigration consequences. The court of special appeals reversed, holding that deportation was a collateral consequence of a criminal conviction and therefore did not fall within the scope of the Sixth Amendment's guarantee of effective assistance of counsel. Two days later, the U.S. Supreme Court decided Padilla v. Kentucky, which held that it is ineffective assistance to disadvise, or fail to advise, a client that deportation is a likely consequence of the guilty plea. On review, the Court of Appeals vacated the court of special appeals, holding (1) Padilla applies to postconviction claims arising from guilty pleas obtained after the enactment of the Illegal Immigration Reform and Immigrant Responsibility Act of 1996; and (2) in this case, defense counsel's failure to advise Petitioner of the deportation consequence of his guilty plea was constitutionally deficient, and counsel's deficient performance prejudiced Petitioner. Remanded for a new trial. View "Denisyuk v. State" on Justia Law

After a jury trial, Petitioner William Briscoe was convicted of possessing a regulated firearm after having been convicted of, inter alia, possessing cocaine and wearing, carrying, or transporting a handgun in a vehicle. The convictions were based on evidence law enforcement officers recovered while searching Petitioner's vehicle and glove compartment at the time of his arrest. Petitioner sought suppression of the handgun, claiming it was the fruit of an illegal search. The circuit court denied the motion. While Defendant's appeal was pending, the Supreme Court decided Arizona v. Gant. The State conceded that, under Gant, the search violated the Fourth Amendment but argued that Petitioner was not entitled to suppression by application of the good-faith exception to the Fourth Amendment's exclusionary rule. The court of special appeals did not reach the Gant issue, holding instead that the handgun was recovered during a valid inventory search. The Court of Appeals affirmed but on different grounds, holding (1) the search of the glove compartment was not a valid inventory search, but (2) the good-faith exception to the exclusionary rule applied to what, at the time, was a lawful search of the glove compartment. View "Briscoe v. State" on Justia Law

Petitioner Christopher Mansfield was tried in a bench trial at the circuit court on five counts charging statutory sex-related offenses. At the close of the evidence, the trial judge, sua sponte and over Petitioner's objection, declared a mistrial, explaining that her knowledge of Petitioner's prior convictions and the partiality it engendered made a mistrial manifestly necessary. Petitioner moved to dismiss the indictment on double jeopardy grounds, arguing that there was not manifest necessity for the granting of the mistrial where the trial judge had knowing of Petitioner's prior convictions well before the trial began. The motions judge and the court of special appeals upheld the decision. The Court of Appeals reversed, holding that under these circumstances, when it is the court that is the trier of facts, and the court's impartiality, whether due to a personal bias or prejudice toward a criminal defendant or an inability to resolve disputed factual allegations, is impaired, manifest necessity does not exist when the reasonable alternative of recusal existed prior to jeopardy attaching. Remanded. View "Mansfield v. State" on Justia Law

Appellant Norman Derr was convicted of multiple sexual offenses in circuit court. On appeal, Derr challenged the admission of forensic evidence introduced at trial through the testimony of an expert witness who did not take part in or observe the physical testing of the evidence or independently determine the test results. At issue on appeal was whether the admission of the evidence and the testimony of the expert witness violated Derr's constitutional right to confrontation. The Court of Appeals reversed, holding (1) a testimonial statement may not be introduced into evidence without the in-court testimony of the declarant, unless the declarant is unavailable and the defendant had a prior opportunity to cross-examine the witness; and (2) the trial judge in this case erred in admitting the results of scientific testing through a surrogate analyst who did not, on the basis of the record, perform or observe the actual testing. View "Derr v. State" on Justia Law