Maryland v. Adams-Bey

The Maryland Supreme Court granted the State’s petition for a writ of certiorari in this case to decide whether the Uniform Postconviction Procedure Act (“UPPA”) granted the Court of Special Appeals the authority to reopen a postconviction proceeding if doing so was “in the interests of justice.” The Supreme Court "easily" concluded that the UPPA did not. However, the Court of Special Appeals was statutorily authorized to review a circuit court's denial of a motion to reopen for abuse of discretion, and could remand the matter back to the circuit court with instruction to award appropriate relief if the circuit court abused that discretion. In 1978, Respondent James Leslie Adams-Bey, Jr., was convicted by a jury of first degree rape and related offenses, for which he was sentenced to life plus ten years of incarceration. Respondent petitioned unsuccessfully for postconviction relief in 2010. In 2012, Respondent moved pro se to reopen his postconviction proceedings on the ground that jurors at his criminal trial were given advisory-only instructions in violation of his constitutional rights to due process. Respondent argued that those instructions were unconstitutional because the jury was not instructed to follow the court’s explanation of the law and the court did not inform the jury of the binding nature of its instructions on the State’s burden of proof or the presumption of innocence. The circuit court denied Respondent’s motion without a hearing. On appeal of that denial, Respondent argued the circuit court abused its discretion by denying his motion to reopen. The Court of Special Appeals granted Respondent's application, and addressed the merits of his appeal, and reversed the circuit court's denial. The Supreme Court affirmed the Court of Special Appeals, finding it correctly concluded that the circuit court abused its discretion by denying Respondent's motion to reopen. View "Maryland v. Adams-Bey" on Justia Law