Justia Maryland Court of Appeals Opinion Summaries

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After a jury trial, Petitioner was acquitted of murder in the first degree but convicted of murder in the second degree. The circuit court granted Petitioner’s motion for a new trial. After the State rested its case during the second trial, the trial judge declared a mistrial and discharged the jury. The case was rescheduled. Petitioner then filed a motion to dismiss the indictment on grounds of double jeopardy. After hearing arguments, the judge struck his previous grant of a mistrial and granted Petitioner’s previously-filed motion for judgment of acquittal, thus dismissing the second-degree murder charge against Petitioner based on insufficiency of the evidence. The State subsequently reindicted Petitioner for second-degree murder. Upon Petitioner’s motion, the trial judge dismissed the indictment. The Court of Appeals reversed, concluding that principles of double jeopardy did not bar Petitioner’s retrial because the trial court could not acquit Petitioner after declaring a mistrial and discharging the jury. The Court of Appeals affirmed, holding that the trial judge acted without authority in acquitting Petitioner weeks after he had declared a mistrial and discharged the jury. View "Johnson v. State" on Justia Law
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In 1993, Respondent was convicted of two counts of felony murder and other crimes. Respondent was sentenced to life without parole for the murders. Twenty-one years later, a trial witness alleged that he “lied” during Respondent’s trial when he identified Respondent as the individual who shot the victims. Thereafter, Respondent filed a pro se petition for writ of actual innocence under Md. Code Ann. Crim. Proc. 8-301, alleging that the recantation constituted “newly discovered evidence.” The circuit court denied the petition. The Court of Special Appeals reversed. The Court of Appeals vacated the judgment of the Court of Special Appeals and remanded the case to the circuit court for further proceedings, holding (1) a petition that fails to include an averment of innocence but otherwise complies with the pleading requirements contained in Maryland Rule 4-332(d) may be amended if the circuit court determines that allowing an amendment would do substantial justice; and (2) Petitioner alleged sufficient “newly discovered evidence” that could create a “substantial of significant possibility” that his original trial may have been different and was therefore entitled to a hearing under Md. Code Ann. Crim. Proc. 8-301(e)(1). View "State v. Ebb" on Justia Law
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Petitioner, a Colorado resident, entered Maryland pursuant to a summons to testify at a murder trial. Petitioner was subsequently arrested in Maryland, and the State charged him with crimes related to the murder. A jury found Petitioner guilty of first-degree murder and conspiracy to commit first-degree murder. Petitioner did not allege, either pretrial or during trial, that his arrest violated the Maryland Uniform Act to Secure the Attendance of Witnesses from Without State in Criminal Proceedings. For the first time on appeal, Petitioner argued that the State’s prosecution of him violated Md. Code Ann. Cts. & Jud. Proc. (CJ) 9-304(a), and therefore, the circuit court improperly exercised personal jurisdiction over him. The Court of Special Appeals affirmed, concluding that petitioner’s challenge to the exercise of personal jurisdiction was waived. The Court of Appeals affirmed, holding that Petitioner waived the issue of a violation of CJ 9-304(a) by failing to raise it pretrial as required by Maryland Rule 4-252. View "Lewis v. State" on Justia Law
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After a jury trial, Petitioner was convicted of armed robbery, robbery, and related offenses. The trial court sentenced Petitioner to twenty years’ imprisonment for armed robbery and merged the remaining offenses. Petitioner appealed, arguing that the trial judge abused his discretion in conducting the voir dire of the prospective jurors. The Court of Special Appeals affirmed the judgment of conviction. The Court of Appeals affirmed, holding that the voir dire process in this case reasonably assured that Petitioner was tried before an impartial jury. The Court, however, used the opportunity of this case to encourage trial judges to adopt certain best practices to help achieve the constitutionally requirement of an impartial jury. View "Collins v. State" on Justia Law

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After a jury trial in 2000, Appellant was convicted of first- and second-degree murder, first-degree assault, and the unlawful taking of a motor vehicle. In 2013, Appellant filed a Public Information Act request requesting the results of any testing performed on the hair fibers from the black t-shirt he was wearing when he was arrested in 1997. The State admitted that the black t-shirt was destroyed in 2003, after the appellate process was exhausted. In 2014, Appellant filed a petition in the circuit court requesting a hearing under Mc. Code Ann. Crim. Proc. 8-201(j)(3)(i) to determine whether the State’s failure to produce the requested evidence was the result of intentional and willful destruction. The circuit court denied the petition, concluding that the evidence did not constitute “scientific identification evidence” under the statute, and therefore, the State did not have a duty to preserve it. The Court of Appeals affirmed, holding that the circuit court did not err in denying appellant’s petition because the black t-shirt did not satisfy the statutory definition of “scientific identification evidence,” and therefore, the State did not have a duty to preserve it. View "Wallace v. State" on Justia Law
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These two cases concerned administrative hearings in cases where an individual suspected to have been driving (or attempting to drive) while impaired refuses to take a breath test for blood alcohol concentration. In each case, an administrative law judge (ALJ) overturned the suspension on the ground that it was not established by a preponderance of the evidence that the individual had actually been driving (or attempting to drive) at the time the individual was detained by a law enforcement officer. The Supreme Court vacated the judgment in one case and reversed the judgment in the other case, holding (1) in a test refusal case, there is no requirement that the Motor Vehicle Administration prove that the individual was actually driving (or attempting to drive) while under the influence of alcohol; rather, the relevant question is whether the officer had reasonable grounds to believe that the individual was driving (or attempting to drive) while under the influence of alcohol; (2) in one case, the ALJ found that the officer had reasonable grounds, and thus the suspension should have been upheld; and (3) in the other case, the ALJ’s finding on the issue of reasonable grounds was ambiguous, and the case is remanded for clarification. View "Motor Vehicle Administration v. Krafft" on Justia Law

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After a jury trial, Defendant was convicted of four counts of first-degree murder, among other crimes. Defendant was sentenced to four consecutive sentences of life imprisonment without the possibility of parole, one for each conviction of first-degree murder. The Court of Special Appeals affirmed the murder convictions and sentences, holding that CR 2-304 does not give a defendant the right to have a jury determine whether the defendant should be sentenced to life imprisonment with the possibility of parole or life imprisonment without the possibility of parole. The Court of Appeals affirmed, holding (1) under CR 2-304(a), where a defendant is convicted of first-degree murder and the State has given notice of an intent to seek life imprisonment without the possibility of parole, the trial court, not the jury, determines whether to sentence the defendant to life imprisonment or life imprisonment without the possibility of parole; and (2) both the United States Constitution and the Maryland Declaration of Rights permit a sentence of life imprisonment without the possibility of parole to be imposed in the same manner as every other sentence except the death penalty, which has been abolished in Maryland. View "Bellard v. State" on Justia Law

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Petitioner, a former researcher employed by Johns Hopkins University School of Medicine (JHU), filed suit against JHU alleging (1) he was wrongfully terminated in retaliation for his repeated protests of research misconduct in violation of 42 U.S.C. 289b and 42 C.F.R. 93; and (2) conversion because after the termination of his employment, he was denied access to stored research materials he had collected. The circuit court granted JHU’s motion to dismiss because Petitioner failed to identify a public policy exception to the at-will employment doctrine and because JHU “could not have converted what it in fact had ownership of.” The Court of Special Appeals affirmed. The Court of Appeals affirmed, holding (1) Plaintiff was not wrongfully terminated, and his at-will employment came to an end due to the expiration of his employment contract; and (2) Plaintiff’s claim of conversion must fail because JHU owned the research materials pursuant to its stated policies. View "Yuan v. Johns Hopkins University" on Justia Law

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Under Md. Code Ann. Pub. Safety, 3-103(b), Maryland law enforcement agencies may not prohibit law enforcement officers from working secondary employment. Petitioner, a former employee of the Maryland State Police Department (MSP), began working overtime in a law enforcement capacity securing National Security Agency (NSA) facilities pursuant to an agreement between MSP and NSA. The next year, MSP informed Petitioner that she could no longer work overtime at NSA. Petitioner brought a show cause action, alleging a violation of section 3-103(b)(1). MSP argued, in response, that troopers who work overtime at NSA are not engaged in “secondary employment” as that term is used in the statute but, rather, “on duty overtime.” The circuit court dismissed the action. The Court of Special Appeals affirmed. The Court of Appeals affirmed, holding that the Court of Special Appeals did not err in ruling (1) that Petitioner’s work at NSA was on-duty overtime work rather than secondary employment protected by section 3-103(b); and (2) that MSP did not take punitive action in prohibiting Petitioner from working at NSA. View "Breck v. Maryland State Police" on Justia Law

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Petitioner, a Delaware limited liability company, owned and managed an apartment building in the City of Annapolis, Maryland that was within the designated historic district under the City’s zoning ordinance. The Annapolis Historic Preservation Commission issued two historic preservation municipal infraction citations to Petitioner. Petitioner requested a trial, and the district court found in favor of the City. In a de novo appeal, the circuit court entered summary judgment in favor the City after Petitioner admitted to replacing historic wood windows with vinyl windows without the Commission’s approval. Thereafter, Petitioner filed a petition for a writ of certiorari, alleging several claims of error. The Court of Appeals affirmed, holding (1) historic preservation municipal citations are civil and, in this case, were not barred by laches or the relevant statute of limitations; (2) the citations in this case were sufficient to give Petitioner adequate notice of its violations, and the circuit court’s judgment was not clearly erroneous; and (3) the circuit court did not abuse its discretion by denying Petitioner’s motion for a new trial or, in the alternative, to amend the judgment. View "Spaw, LLC v. City of Annapolis" on Justia Law