Justia Maryland Supreme Court Opinion Summaries

Petitioner Dwayne Peaks was convicted of multiple offenses following a jury trial in circuit court. Petitioner argued that the trial judge did not make an adequate determination of Petitionerâs competency to stand trial under state law. Defense counsel first raised the issue of Petitionerâs competency following his arraignment. The court then ordered an evaluation. The court found that Petitioner was competent to stand trial, but elected to reconsider the matter. A second evaluation was never completed because the case was transferred to another trial judge. Neither party raised the competency issue with the new judge. After advising Petitioner of his rights and plea negotiations, voir dire began. During this process, Petitioner requested to discharge his attorney because he believed the attorney was not adequately representing him. Petitioner sought to continue pro se. The trial judge allowed Petitioner to discharge his attorney. Petitioner became unruly during the remainder of voir dire, and was escorted from the courtroom several times. Voir dire was concluded without Petitioner or defense counsel. The court proceeded with trial, and eventually convicted Petitioner in absentia. Petitioner appealed his conviction through counsel from the Office of the Public Defender, alleging the trial court erred by not performing the second competency evaluation. The Supreme Court held that in light of the circumstances, even though Petitionerâs trial had already commenced, the trial judge did not violate state law by not conducting the second evaluation. The Court affirmed the lower courtâs decision.

Respondent James Goldsberry, Jr. was tried before a jury in Prince Georgeâs County Circuit Court and convicted of second degree felony murder, conspiracy, attempted robbery and weapons charges. He appealed the judgments of conviction to the Court of Special Appeals, where he raised a number of claims. The appellate court found merit in some claims, and reversed some of the convictions. The court remanded the case for a new trial on the attempted robbery and weapons charges, but affirmed the conviction of second degree felony murder and conspiracy to commit felony murder. Both parties sought Supreme Court review of the case. The issues presented to the Court for consideration were: (1) whether the trial court violated Respondentâs Sixth Amendment rights to representation by his counsel of choice when it dismissed one of Respondentâs three privately retained attorneys; (2) whether the trial court erred in giving the jury an instruction on an unanimous verdict; and (3) whether the appellate court erred by holding Respondent was convicted of a ânon-existentâ crime of second degree felony murder predicated on attempted robbery with a dangerous weapon. The Supreme Court found that the trial court did violate Respondentâs Sixth Amendment right to counsel of his choosing, and that the appellate court erred in its holding regarding the felony murder violation. The Courtâs decision entitled Respondent to a new trial, and accordingly it did not address the propriety of the trial courtâs jury instruction.

At issue on review by the Supreme Court is the extent to which the Local Government Tort Claims Act limits the recovery of a man whose constitutional rights were violated by acts of a local police force. Respondent Keith Longtin was arrested, interrogated for over 36 hours, and charged with the rape and murder of his wife. He was held in prison for over eight months. During his stay, the police department obtained exculpatory evidence, but failed to inform Respondent or to release him. Only when the police confirmed through a DNA match that the crime was committed by the another suspect did it release Respondent from prison. Respondent sued the police, the County and individual officers, and obtained a jury verdict of $6.2 million. The County appealed and the Court of Special Appeals affirmed the verdict. The Supreme Court granted certiorari to address, among other issues, the Countyâs primary argument on appeal: whether Respondentâs claim and verdict complied with the state Local Government Tort Claims Act (LGTCA). On review, the Supreme Court upheld the lower courtsâ decisions, finding that neither the notice provisions nor the damages cap of the LGTCA apply to limit the claim or the jury award in this case.

In January, 2006, Appellee-Defendant Demetrius Daughtry was indicted with murder, robbery, robbery with a deadly weapon and use of a handgun in the commission of a violent felony stemming from the botched robbery and shooting death of Anthony Brown. Defendant negotiated with the State to plead guilty to first-degree murder and use of a handgun in the commission of a violent felony. The circuit court agreed with the terms of the plea agreement, and sentenced Defendant to a term of life imprisonment. On appeal of the sentence, Defendant argued that the guilty plea should be vacated because the circuit court judge did not determine "on the record that defense counsel had advised [Defendant] of the elements of first degree murder." The appellate court vacated the convictions, explaining that "all [Defendant] said [on the record] was that he had 'talked over his plea' with counsel. â¦[The court] did not, in any way, assure that he understood the elements of the charge of first-degree murder. â¦Consequently, the voir dire conducted in this case failed to show that the plea met the required knowing, voluntary and intelligent standard [of Maryland Rule 4-242 and relevant caselaw]." On appeal, the Supreme Court affirmed the appellate decision vacating Defendant's convictions, finding no indicia that Defendant made a "knowing and voluntary" plea.