Justia Maryland Supreme Court Opinion Summaries

Shyquille Griffin was indicted on charges related to the shooting of Andrew Lindsey. Pursuant to a plea agreement with the State, Griffin pleaded guilty to attempted robbery. The agreement did not mention restitution. Upon sentencing, the State advised the court that Lindsey was seeking $9,700 in restitution. The circuit court concluded that it could not order restitution because it would violate the agreement by adding to the penalty. Invoking Md. Code Ann. Crim. Proc. 11-103(e), Lindsey filed a motion for reconsideration of restitution and request for hearing (“CP 11-103(e) motion”), arguing that the hearing court improperly denied his request for restitution. The circuit court denied the CP 11-103(e) motion. Lindsey appealed. The Court of Special Appeals reversed, holding that the circuit court had discretion to order restitution as a condition of Griffin’s probation without violating the agreement or Griffin’s double jeopardy rights. The Court of Appeals reversed, holding that Lindsey’s appeal was untimely because Md. Code Ann. Crim. Proc. 11-103(b) does not permit a crime victim to file an application for leave to appeal the denial of a CP 11-103(e) motion. View "Griffin v. Lindsey" on Justia Law

Petitioner was charged in a five-count indictment with burglary and related crimes. On the morning of trial, the prosecutor asked the court to amend Count Four from theft of less than $1,000 to theft of at least $1,000 but less than $10,000. The amendment of Count Four substituted felony theft for misdemeanor theft. The court allowed the amendment of the indictment. After a trial, the jury found Petitioner guilty of fourth degree burglary, theft of goods having a value of at least $1,000, and theft of good valued under $100. The Court of Appeals reversed the conviction, holding (1) the amendment of Count Four of the indictment changed the character of the offense charged, and therefore, the trial court violated Maryland Rule 4-204 in permitting the State, over Petitioner’s objection, to amend the charging document; and (2) that violation was prejudicial per se, entitling Petitioner to a remand for entry of a judgment of conviction and imposition of sentence on the originally charged misdemeanor of theft of property valued at less than $1,000. View "Counts v. State" on Justia Law

After a jury-waived trial, Petitioner was convicted of possession of oxycodone with intent to distribute. Petitioner appealed, arguing that he was entitled, by application of the rule established in Riley v. California, decided by the Supreme Court, to suppression of the evidence obtained as the result of the search of his cell phone incident to his lawful arrest. The Court of Appeals affirmed, holding that the officer who searched Petitioner’s cell phone acted in good faith on then-controlling authority in Maryland in searching Petitioner’s cell phone, and therefore, Petitioner was not entitled to have the cell phone data excluded at trial. View "Demby v. State" on Justia Law

Petitioner was convicted of possession with intent to distribute marijuana, possession of marijuana, and possession of drug paraphernalia. Petitioner appealed the denial of his motion to suppress text messages that the police obtained during the warrantless search of his cell phone incident to his lawful arrest. The Court of Appeals affirmed, holding that the trial court properly denied Petitioner’s motion to suppress the data obtained from his cell phone, as (1) in light of the U.S. Supreme Court’s decision in Riley v. California, officers must generally secure a warrant before conducting searches of data on cell phones; but (2) the police in this case acted in good faith on then-controlling authority in Maryland in searching Petitioner’s cell phone, and therefore, Petitioner was not entitled to suppression of the data obtained from his cell phone. View "Spence v. State" on Justia Law

After a jury trial, Defendant was convicted of first-degree murder, use of a handgun in the commission of a crime of violence, and wearing, carrying, and transporting a handgun. Defendant was sentenced to life imprisonment for the murder. Defendant appealed, arguing that a witness’s placement in protective housing for several months leading up to the murder trial constituted a “benefit” that would compel the trial judge to give a particularized jury instruction - called the “Witness Promised Benefit” instruction - pertaining to the witness’s credibility. The Court of Special Appeals affirmed, concluding that the trial court did not abuse its discretion in declining to give the jury instruction. The Court of Appeals affirmed, holding that protective housing provided to a witness in a first degree murder case is not the type of “benefit” contemplated by the “Witness Promised Benefit” pattern instruction, and therefore, the trial court did not err in not giving the instruction. View "Preston v. State" on Justia Law

After a jury trial, Defendant was convicted of first degree felony murder and related charges. On appeal, Defendant argued, inter alia, that the trial court erred when it declined, on the basis of attorney-client privilege, to allow defense counsel to call to the stand the Assistant Public Defender, who represented Defendant’s co-defendant, and question that attorney about a proffer session that her client had with the Assistant State’s Attorney and police prior to entering into the plea agreement. The Court of Appeals affirmed, arguing (1) the limitations the trial judge placed on counsel’s cross-examination of two prosecution witnesses were within the discretion of the trial judge and did not violate Defendant’s right under the federal and state constitutions to confront witnesses against him; and (2) while the attorney-client privilege did not apply to the discussion at the proffer session, the proposed testimony was of minimal relevance, cumulative, and the potential for straying into privileged areas outweighed any probative value. View "Peterson v. State" on Justia Law

Defendant was charged with carjacking and related offenses, various firearms offenses, and possession of illicit drugs. The morning of trial, Defendant’s attorney made an oral motion seeking to exclude evidence derived from a flip cell phone that was seized from Defendant incident to his arrest. The primary evidence obtained from the cell phone was a screen saver image that matched the custom wheel rims of the stolen car. The circuit court denied the motion to suppress. After a jury trial, Defendant was found guilty. The court of special appeals affirmed. Before the Court of Appeals, Defendant relied on the U.S. Supreme Court’s intervening decision in Riley v. California to argue that the arresting officer’s review of photos on Defendant’s cell phone without a warrant was an unconstitutional search, and therefore, the evidence derived from the cell phone should have been suppressed. The Supreme Court affirmed, holding (1) Defendant waived his motion to suppress by failing to make his motion within the time period and with the specificity required by the Maryland Rules; and (2) even had the motion been made in a timely manner, the screen saver image was admissible under Riley. View "Sinclair v. State" on Justia Law

Maryland Rule 2-325 provides that a party’s failure to demand a jury trial within fifteen days after service of the last pleading directed to the issue constitutes a waiver of the party's right to a jury trial. If a party files an amended complaint asserting a new substantive issue and demanding a jury trial, the new claim may revive the previously waived jury trial. In this case, Plaintiff sued Defendant, alleging two counts (Counts I and II). Plaintiff failed to timely demand a jury trial. Plaintiff subsequently filed an amended complaint reasserting Counts I and II and adding a third (Count III). Included with his amended complaint was a jury demand. Counts II and III were subsequently dismissed for failure to state a claim. The circuit court then struck the jury demand. On appeal, the Court of Special Appeals ruled that Plaintiff was entitled to a remand for a jury trial. The Court of Appeals reversed, holding that Plaintiff’s amended complaint, in which he timely demanded a jury trial, added only one new count that was dismissed for failure to state a claim, and that count was an insufficient basis to revive the previously waived jury trial. View "Scarfield v. Muntjan" on Justia Law

An inmate brutally murdered another inmate during a ride on a prison transport bus staffed by five correctional officers. At issue in this case was whether the correctional officer who was in charge of the bus was grossly negligent and, if so, whether he was entitled to common law public official immunity. The jury found that the officer at issue (“Cooper”) was grossly negligent and that his gross negligence was a proximate cause of the inmate’s death.The circuit court granted Cooper’s motion for judgment notwithstanding the verdict by striking the jury’s finding of gross negligence and determining that Cooper was immune from liability. The court of special appeals reversed as to Cooper, concluding that Cooper was grossly negligent and consequently not immune from liability. The Court of Appeals affirmed, holding (1) gross negligence is an exception to common law public official immunity; and (2) the court of special appeals was correct in ruling that Cooper was not entitled to common law public immunity because he acted with gross negligence. View "Cooper v. Rodriguez" on Justia Law

Pursuant to a plea agreement, Respondent pleaded guilty to having engaged in a conspiracy to distribute marijuana. Respondent later sought to have the conspiracy conviction vacated, asserting that her guilty plea was not knowing and voluntary because she had not been informed at the time of the plea of the elements or essential nature of the crime of conspiracy. The circuit court denied coram nobis relief. The Court of Special Appeals reversed, concluding that Respondent’s guilty plea was invalid and must be vacated. The Court of Appeals reversed, holding (1) Respondent did not waive her right to pursue coram nobis relief; and (2) Respondent’s guilty plea was knowingly and voluntarily made. View "State v. Smith" on Justia Law