Justia Maryland Supreme Court Opinion Summaries

The Court of Appeals affirmed the judgment of the court of special appeals affirming Defendant's conviction for gross negligence involuntary manslaughter but reversing his conviction for depraved heart murder, holding that the evidence was insufficient to support the conviction for second-degree depraved heart murder.Specifically, the Court of Appeals held (1) the evidence was sufficient to support Defendant's conviction for involuntary manslaughter under both a gross negligence and failure to perform a legal duty theory of the offense; (2) legal duty involuntary manslaughter is not a lesser-included offense of depraved heart murder; and (3) Defendant's conduct did not constitute conduct that demonstrated an extreme indifference to the value of human life, and therefore, the evidence was not sufficient to support Defendant's conviction for second-degree depraved heart murder. View "Beckwitt v. State" on Justia Law

The Court of Appeals held that this Court's holding in Kazadi v. State, 223 A.3d 554 (2020), applies to cases in which a defendant had not yet noted an appeal when the opinion was issued in Kazadi but had preserved a Kazadi issue at trial and that the Kazadi issue in this case was preserved for appellate review.In Kazadi, the Court of Appeals held that, on request and during voir dire, a trial court must ask whether any prospective jurors are unwilling or unable to comply with the jury instructions on the fundamental principles of presumption of innocence, the defendant's right not to testify, and the State's burden of proof. The Court of Appeals in this case held that, in light of case law from the United States Supreme Court and this Court and considerations of fairness, the holding in Kazadi applies to cases in which there had not yet been a final disposition, regardless of whether a notice of appeal had been filed at the time the opinion in Kazadi was issued and in which the issue had been preserved for appellate review. View "Kumar v. State" on Justia Law

The Court of Appeals affirmed the judgment of the court of special appeals reversing the circuit court's judgment in favor of Plaintiff in this personal injury case, holding that the court of special appeals did not err or abuse its discretion.Plaintiff, who was injured while shopping at a supermarket owned and operated by Defendant, brought this suit alleging negligence and negligent hiring, training, and supervision. A jury returned a verdict in favor of Plaintiff. The intermediate appellate court reversed, concluding that the circuit court erred in denying Defendant's motion for judgment made at the close of evidence and in giving a jury instruction on spoliation. The Court of Appeals affirmed, holding that the court of appeals (1) applied the correct standard of review when reviewing the circuit court's denial of Defendant's motion for judgment; (2) did not err in reversing the circuit court's denial of Defendant's motion for judgment; and (3) did not err in holding that the circuit court's spoliation instruction was prejudicial. View "Webb v. Giant of Maryland, LLC" on Justia Law

The Court of Appeals affirmed the judgment of the court of special appeals affirming Defendant's conviction of illegal possession of a firearm, holding that there was no error.Specifically, the Court of Appeals held (1) the scope of the State's mandatory disclosure obligations pursuant to Md. Rule 4-263(c)(2) does not include jail call recordings held by a state correctional facility that has not reported to the State in a particular case; (2) under the circumstances of this case, the State exercised due diligence in disclosing the jail call recordings; and (3) even if the State violated its discovery obligations through its late disclosure, the error was harmless. View "Alarcon-Ozoria v. State" on Justia Law

The Court of Appeals reversed the judgment of the court of appeals affirming Defendant's conviction of first-degree murder, holding that this Court's holding in Kazadi v. State, 223 A.3d 554 (Md. 2020), applies to cases in which a defendant had not yet noted an appeal when the opinion was issued in Kazadi but had preserved a Kazadi issue at trial.In Kazadi, the Court of Appeals held that, on request and during voir dire, a trial court must asking whether prospective jurors are unwilling or unable to comply with the jury instructions on the fundamental principles of presumption of innocence, the State's burden of proof, and the defendant's right not to testify. The Court later stated that that the holding would apply to any cases pending on direct appeal when the opinion was filed and the relevant question had been preserved for review. In the instant case, the court of special appeals affirmed Defendant's first-degree murder conviction, concluding that the circuit court did not err in declining to ask Defendant's proposed voir dire questions. The Court of Appeals reversed, holding that the circumstances were satisfied for Kazadi to apply to this case. View "Kumar v. State" on Justia Law

The Court of Appeals affirmed Petitioner's convictions of perjury and misconduct in office, holding that this Court declines to abrogate the two-witness rule for "oath-against-oath" perjury cases and that there was sufficient evidence to support the convictions.Petitioner, a veteran officer in the Baltimore Police Department, was charged with perjury and misconduct in office based on allegedly false testimony he gave at a criminal trial. The circuit court found Defendant guilty, and the court of special appeals affirmed. Petitioner filed a petition for certiorari, arguing that the lower courts' bases for affirmance were erroneous, and the State filed a cross-petition for certiorari asking the Court to abrogate the two-witness rule prospectively. The Supreme Court affirmed, holding (1) the State met its burden of production under the two-witness rule in this case; and (2) the evidence was sufficient to sustain Petitioner's convictions for perjury and misconduct in office. View "O'Sullivan v. State" on Justia Law

The Court of Appeals affirmed the judgment of the court of special appeals reversing the order of the post-conviction court awarding Petitioner a new trial on all counts and instead remanding the case for a new trial solely on an attempted second-degree murder charge, holding that the court of special appeals did not err.Petitioner was convicted of attempted second-degree murder, first- and second-degree assault, use of a handgun in the commission of a crime of violence, and other charges. Petitioner later petitioned for post-conviction relief, asserting ineffective assistance of counsel. The post-conviction court granted the petition and awarded a new trial on all counts based on the cumulative effect of trial counsel's errors. The court of special appeals remanded for a new trial on the attempted second-degree murder charge only, concluding that the limited cumulative effect theory did not warrant a reversal of all of Petitioner's convictions. The Court of Appeals affirmed, holding that the deficient performance of Petitioner's counsel warranted a new trial on the attempted second-degree murder charge only. View "Wallace v. State" on Justia Law

The Court of Appeals reversed the judgment of the court of special appeals affirming Defendant's convictions and sentences for home invasion, first-degree assault and reckless endangerment, holding that the trial judge abused his discretion by denying Defendant's request to postpone sentencing.Following the jury's verdict, Defendant requested a postponement of the trial court's move to sentencing in order to prepare mitigating information for the court's consideration. Defendant specifically requested an order for a long-form presentencing investigation report, indicating that additional time would allow his mother to testify on his behalf. The trial court denied Defendant's request and imposed a sentence in his mother's absence. The court of criminal appeals affirmed. The Court of Appeals reversed and remanded the case with directions to vacate Defendant's sentence, holding that, under the circumstances of this case, the trial judge abused his discretion by refusing to postpone Defendant's sentencing process. View "Mainor v. State" on Justia Law

The Court of Appeals held that the holding in Lee v. State, 311 Md. 642 (1988), in which the Court held that the predecessor statute to Md. Code Crim. Law (CR) 4-203(a)(1)(I) imposed strict liability for wearing, carrying, or transporting a handgun on or about the person, was still good law and that CR 4-203(a)(1)(I) sets forth a strict liability offense.Defendant was convicted of wearing, carrying, or transporting a handgun on or about the person. Defendant moved for a new trial, arguing that the trial court improperly ignored the mens rea element of wearing, carrying, or transporting a handgun. The court of special appeals affirmed, holding that "knowledge" was not an element of wearing, carrying, or transporting a handgun on or about the person. The Court of Appeals affirmed, holding that "knowledge" is not an element of the crime charged. View "Lawrence v. State" on Justia Law

The Court of Appeals reversed the judgment of the court of special appeals affirming Defendant's convictions, holding that, under article 21 of the Maryland Declaration of Rights, a statement contained in a scientific report is testimonial if a reasonable declarant would have understood the primary purpose for the creation of the report to be to establish or prove past events potentially relevant to later criminal prosecution.Defendant was indicted on charges of first-, third-, and fourth-degree burglary, theft, and malicious destruction of property. At the scene of the reported burglary, a police officer swabbed the burglar's suspected blood from the window frame and a curtain. Thereafter, Molly Rollo, a forensic scientist, conducted a DNA analysis of the samples and produced a report providing a DNA profile for a male contributor. A subsequent DNA records database search identified Defendant as a possible match. At trial, the court admitted Rollo's report into evidence and allowed a different forensic scientist, Tiffany Keener, to convey the report's results to the jury without requiring that Rollo be available for cross-examination. The Court of Appeals reversed the convictions, holding that the trial court violated Defendant's rights to confrontation and cross-examination under Article 21 of the Maryland Declaration of Rights. View "Leidig v. State" on Justia Law