Justia Maryland Supreme Court Opinion Summaries

A jury convicted Petitioner Robert Thomas of carrying a handgun. Petitioner appealed, contending that the trial court erred in not allowing him to impeach a State's witness's testimony with evidence of either the witness's prior conviction or the conduct underlying that conviction. The court of special appeals affirmed the judgment of conviction, concluding that the trial court did not abuse its discretion in disallowing either form of impeachment evidence. The Court of Appeals reversed in part and affirmed in part, holding the trial court (1) did not err or abuse its discretion in refusing to allow Petitioner to make impeachment use of the witness's prior conviction, but (2) committed reversible error in denying Petitioner's request to make impeachment use of the conduct underlying the prior conviction. Remanded for a new trial. View "Thomas v. State" on Justia Law

In 1974, Appellant Douglas Arey was convicted of first-degree murder and use of a handgun in the commission of a felony. In 2002, Arey filed a petition for postconviction DNA testing of evidence related to his conviction. The circuit court dismissed the petition, concluding that the evidence related to Arey's conviction no longer existed. The Court of Appeals reversed the dismissal of Arey's petition, holding (1) the circuit court's ruling that the State had performed a reasonable search for biological evidence relating to Arey's conviction was premature; and (2) the circuit court erred in ruling on Arey's petition for testing only two days after the State submitted an affidavit from a key witness because the court's ruling did not give Arey a reasonable opportunity to respond to the factual allegations contained in that affidavit prior to dismissal. Remanded. View "Arey v. State" on Justia Law

Petitioner Enrique Silva was convicted by a jury of two counts of first-degree premeditated murder. At trial, the State called three witnesses who were present at the crime scene, one of whom was an admitted accomplice to the murders. The other two witnesses denied involvement in the crime. The trial court denied Petitioners' request to instruct the jury that the two witnesses denying involvement were accomplices as a matter of law and, consequently, their testimony linking Petitioner to the murders required corroboration in order to be credited. The court of appeals affirmed the convictions, holding that the trial court correctly denied Petitioners' requested jury instruction. The Court of Appeals granted certiorari and affirmed, holding that Petitioner was not entitled to the requested instruction. View "Silva v. State" on Justia Law

A jury convicted Petitioners Cyrus Beads and Joseph Smith of several crimes against the person of three victims as well as several related offenses, including use of a handgun in the commission of a crime of violence. The court of special appeals consolidated Petitioners' appeals and affirmed their convictions. The Supreme Court reversed, holding (1) the trial court erroneously overruled objections to unfairly prejudicial comments made by the prosecutor, (2) the trial court erroneously concluded that the cross-examination of Smith's trial counsel "opened" the door to testimony that Smith had previously been incarcerated, and (3) because the trial court failed to take any corrective actions in response to the improper arguments and inadmissible evidence, these erroneous rulings were not harmless. Remanded for a new trial. View "Beads v. State" on Justia Law

A jury convicted Petitioner Anthony Miller of two counts of second degree murder. The court of special appeals affirmed. Petitioner then filed a petition for writ of certiorari. The question Petitioner presented was whether the lower courts erred by ruling admissible a handwriting expert's testimony that Petitioner might have written the victim's signature on an important questioned document and that fact prevented Petitioner's elimination as a suspect in the case. The Court of Appeals granted the writ and affirmed, holding that the lower courts did not err in their conclusions that the handwriting expert's testimony was admissible as (1) because an expert opinion regarding handwriting need not be based on absolute certainty in order to be admissible, Petitioner was not unfairly prejudiced by the testimony even though the expert was unable to express the definite opinion that petitioner had forged the victim' signature on the document; and (2) Petitioner was not unfairly prejudiced by what occurred during the expert's redirect examination as the questions the expert was asked on cross-examination "opened the door" to the opinion that was elicited on redirect examination. View "Miller v. State" on Justia Law

A jury convicted Appellant Jody Miles of first-degree felony murder and related offenses, including robbery with a deadly weapon and use of a handgun in the commission of a crime of violence. Miles was sentenced to death. The Court of Appeals affirmed Appellant's convictions and sentence. Miles subsequently filed a motion to correct an illegal sentence, arguing that he was entitled to a new sentencing hearing on the ground that the jury should have been instructed that a death sentence cannot be imposed unless every juror is persuaded beyond a reasonable doubt that the aggravating circumstances outweigh the mitigating circumstances. The circuit court denied the motion. The Court of Appeals affirmed, holding that Appellant was not entitled to a new sentencing hearing as Maryland's capital sentencing procedure did not violate the Sixth Amendment. View "Miles v. State" on Justia Law

After a jury trial, Ronald Cox was convicted of multiple offenses related to a murder. The court of special appeals affirmed his convictions. The Court of Appeals granted Cox's petition for certiorari and affirmed, holding (1) the court of special appeals did not err in upholding the admission of hearsay testimony of a fellow inmate as (a) because the out-of-court statements were made voluntarily and were unprompted in casual conversation, they were not made with the primary purpose of creating an out-of-court substitute for trial testimony, and thus the statements were not testimonial and the Confrontation Clause did not bar their exclusion, and (b) the testimony was sufficiently attenuated from the taint of an earlier illegal search and arrest under the attenuation analysis set forth in Miles v. State, and (2) the evidence presented at trial was sufficient to allow a reasonable jury to find that Cox was guilty beyond a reasonable doubt. View "Cox v. State" on Justia Law

After a jury trial, William Langley was convicted of first-degree murder, use of a handgun in the commission of a crime of violence, and wearing or carrying a handgun. The court of special appeals affirmed. At issue on appeal was whether the admission into evidence of a recording of a 911 call violated Langley's confrontation rights where the call was placed after the offense had been completed and the alleged perpetrator had left the scene and where the caller indicated that she was aware that the police had been notified and were in the process of responding. Upon applying the U.S. Supreme Court's recent Michigan v. Bryant to the facts of the case, the Court of Appeals affirmed, holding that the statements in the 911 tape were non-testimonial for Confrontation Clause purposes, and thus, Langley's right to confrontation was not infringed by the admission of the statements. View "Langley v. State" on Justia Law

Armardo Atkins was convicted of second degree assault in circuit court. On appeal, Atkins argued that the trial judge abused her discretion by instructing the jury that the State was not required to shoulder its burden of persuasion by the use of certain categories of demonstrative evidence. The court of appeals affirmed the convictions. The Supreme Court reversed, holding that the instruction that the State need not use certain investigative and scientific techniques violated Atkins's constitutional rights to due process and a fair trial because it resulted in a non-neutral commentary on the evidence, or lack thereof, invaded the province of the jury, and relieved the State of its burden to prove guilt beyond a reasonable doubt. Remanded for a new trial. View "Atkins v. State" on Justia Law

Roger Greenberg was indicted and tried before a jury on five counts related to the care of Evelyn Zucker, to whom Greenberg had been married. During the proceeding against Greenberg, the trial judge permitted Greenberg's former lawyer, Mark Hessel, to testify as part of the State's case-in-chief. After Greenberg was convicted, he sought reversal on the grounds that the trial court allowed Hessel to testify without conducting a preliminary inquiry regarding the surrounding facts and circumstances of Hessel's representation of Greenberg, the complete circumstances related to Greenberg's possible waiver of privilege, and the scope of the prosecution's proposed use of the evidence at trial. The Court of Appeals granted certiorari and reversed, holding that the trial court erred in determining that Greenberg waived the attorney-client privilege and that the error was not harmless. Remanded for a new trial. View "Greenberg v. State" on Justia Law