Justia Maryland Supreme Court Opinion Summaries

Articles Posted in Criminal Law
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The Supreme Court of Maryland held that the State's duty to preserve scientific identification evidence, such as DNA, is limited to specific crimes specified in the Criminal Procedure Article ("CP") § 8-201(j)(1)(ii) and does not extend to all crimes for which a person may petition for DNA testing. The Court ruled that the preservation obligation does not apply to the inchoate (or incomplete) offenses of those crimes listed under the same section of the law. The Court also found that the State's duty to preserve evidence does not extend to attempted murder.The case involved Darrell Eugene Matthews who had been convicted of attempted murder and was seeking post-conviction DNA testing of a glove found at the crime scene. The glove had been destroyed according to the police department's evidence retention policy after Matthews's first petition for DNA testing. The Court held that the circuit court correctly denied Matthews's second petition for post-conviction DNA testing because the State was not required to preserve evidence related to Matthews's attempted murder conviction for the duration of his sentence. The Court also found that the evidence Matthews sought to test had been destroyed in line with the police department's evidence retention policy. View "Matthews v. State" on Justia Law

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The Court of Chancery reversed the judgment of the circuit court convicting Defendant of murder and child abuse, holding that the circuit court erred in admitting evidence of Defendant's prior conviction for child abuse resulting in the death of his infant son, and a new trial was required.Defendant was convicted of second-degree murder, first-degree child abuse resulting in death, and other crimes related to the death of a seventeen-month-old. The appellate division affirmed, holding that the evidence of the death of Defendant's son was admissible under the doctrine of chances. The Supreme Court reversed, holding that the State "stretched the doctrine of chances beyond its limits," and therefore, the circuit court abused its discretion in admitting evidence about the death of Defendant's son. The Court remanded the case for a new trial. View "Browne v. State" on Justia Law

Posted in: Criminal Law
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The Supreme Court reversed the judgment of the appellate court reversing the judgment of the circuit court concluding that Defendant could not show that he was prejudiced by his counsel's assistance under Strickland v. Washington, 466 U.S. 668 (1984), holding that the circuit court correctly concluded that trial counsel's performance was deficient.At issue was whether trial counsel's failure to object to an order prohibiting any consultation regarding the case between Petitioner and trial counsel during Petitioner's murder trial resulted in the actual denial of the Sixth Amendment's guarantee of assistance of counsel. The Supreme Court held (1) prejudice was presumed under the circumstances of this case; and (2) the circuit court correctly concluded that trial counsel's failure to object was objectively unreasonable. View "Clark v. State" on Justia Law

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The Supreme Court upheld the judgment of the circuit court on postconviction review ordering a new trial for Petitioner, holding that Petitioner was provided ineffective assistance of counsel due to trial counsel's failure to object to the trial court's order prohibiting any consultation about the case (a no-communication order) between Petitioner and trial counsel under the circumstances of this case.At issue was a no-communication order entered into between Petitioner and trial counsel during an overnight recess prior to the final day of testimony in Petitioner's murder trial and trial counsel's failure to object to the order. The circuit court ruled that the no-communication order, and trial counsel's failure to object, deprived Petitioner of the assistance of counsel, in violation of the Sixth Amendment, and presumed prejudice, thus ordering a new trial. The appellate court reversed, concluding that Petitioner could not show prejudice. The Supreme Court reversed, holding (1) trial counsel's conduct in this case resulted in the actual denial of the assistance of counsel, and prejudice was presumed; and (2) therefore, the circuit court properly ordered a new trial for Petitioner. View "Clark v. State" on Justia Law

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The Supreme Court affirmed the judgment of the post-conviction court denying Petitioner's pro se petition for post-conviction relief, holding that the post-conviction court did not err in denying the petition.Petitioner was convicted of distribution of heroin and sentencing him to eight years in prison. In his post-conviction motion, Petitioner argued that his trial counsel rendered ineffective assistance during trial and that the State had violated its Brady obligations. The post-conviction court denied relief. The appellate court certified questions of law to the Supreme Court. The Supreme Court answered (1) Defendant failed to establish that trial counsel rendered ineffective assistance by failing to move to compel production of Internal Affairs Division files; and (2) assuming, without deciding, that the State was required to disclose impeachment evidence prior to the suppression hearing, Petitioner failed to establish the Brady materiality standard. View "Blake v. State" on Justia Law

Posted in: Criminal Law
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The Supreme Court affirmed the decision of the post-conviction court denying Defendant's petition for post-conviction relief, holding that the post-conviction court did not err in ruling that trial counsel had not rendered ineffective assistance and that the State had not violated its Brady obligations during the underlying proceedings, holding that there was no error.After a jury trial, Defendant was convicted of distribution of heroin and sentenced to eight years' imprisonment. The appellate court affirmed. Defendant later filed a pro se petition for post-conviction relief, which the post-conviction court denied. On appeal, the appellate court certified questions of law to the Supreme Court. The Supreme Court answered (1) the post-conviction court did not err in ruling that trial counsel had not rendered ineffective assistance by failing to move production of certain evidence; and (2) assuming, without deciding, that the State was required to disclose challenged impeachment evidence prior to the hearing on Defendant's motion to suppress, Defendant failed to establish the Brady materiality standard. View "Blake v. State" on Justia Law

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In this case involving the criminal trial of two co-defendants whose cases had been consolidated and was initially scheduled for a date beyond the appropriate date under the "Hicks rule" and the trial court made no finding of "good cause," the Supreme Court held that the dismissal of Defendants' indictments as a remedy for the Hicks violation was inappropriate.The circuit court granted Defendants' motions to dismiss their respective indictments because of the Hicks rule violations. The appellate court affirmed in the case of Garrick Powell on the grounds that Powell's attorney did not expressly consent to a trial date beyond the Hicks date but reversed in the case of Lateekqua Jackson, determining that Jackson expressly consented a trial date beyond the Hicks date. The Supreme Court reversed in part and reversed in part, holding (1) through his conduct, Powell's counsel sought a trial date that exceeded the Hicks date, thus precluding dismissal of the indictment against him due to the Hicks violation; and (2) through her conduct, Jackson's attorney sought a trial date that exceeded the Hicks date, thereby precluding dismissal of the indictment as a remedy for the Hicks violation. View "Jackson v. State" on Justia Law

Posted in: Criminal Law
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The Court of Appeals reversed the judgment of the circuit court convicting Defendant of first-degree murder and related handgun offenses, holding that the circuit court abused its discretion in permitting a firearms examiner to testify, without qualification, that bullets left at a murder scene were filed from a gun Defendant had acknowledged was his, and the error was not harmless.On appeal, Defendant argued that the circuit court abused its discretion in admitting the firearms identification testimony based on testimony, reports, and studies that called into question the reliability of firearms identification analysis. The Court of Appeals agreed and reversed the case for a new trial, holding that the circuit court (1) did not abuse its discretion in ruling that the firearms examiner could testify about firearms identification generally and other information; but (2) erred in permitting the examiner to opine without qualification that the crime scene bullets were fired from Defendant's firearm. View "Abruquah v. State" on Justia Law

Posted in: Criminal Law
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The Supreme Court remanded this case for additional fact-finding, holding that this Court declines to reach the merits of the questions for which the Court granted certiorari because additional fact-finding was required as to the origin of a DNA sample collected pursuant to a search warrant.During an investigation in another homicide case the State collected a DNA sample from Petitioner pursuant to a search warrant and developed a DNA profile of Petitioner. The State later charged Petitioner in connection with the homicide but later nol prossed the charges. A DNA profile developed from evidence collected at the crime scene in the instant case matched Petitioner's DNA profile from previous case, and Petitioner was charged with attempted first-degree murder. Petitioner filed a motion to suppress, arguing that his previously-taken DNA sample should have been expunged under section 2-511 of the Public Safety Article. The circuit court denied the motion, concluding that section 2-511 only applies to "arrestee and convicted-offender DNA samples" and not samples gathered pursuant to a search warrant. The Supreme Court held that remand was required because the record was unclear as to whether the circuit court determined that the DNA sample was recovered pursuant to a search warrant or was a so-called arrestee sample or forensic sample. View "Walker v. State" on Justia Law

Posted in: Criminal Law
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The Supreme Court affirmed the judgment of the appellate court affirming Petitioner's conviction for child sexual abuse and other related sexual offenses, holding that Petitioner was not entitled to relief on his claims of error.At issue on appeal was whether the circuit court erred in granting the State's pre-trial motion to introduce evidence of Petitioner's 2010 conviction for sexual assault against another individual under Md. Cts. & Jud. Proc. Art. (CJP) 10-923, which permits the admission of certain circumstances of prior sexually assaultive behavior in prosecutions for child sexual offenses. The Supreme Court affirmed, holding (1) there is no factor that circuit courts must consider in every case when conducting an analysis under CJP 10-923(e)(4); (2) the motions judge did not abuse his discretion in determining that the probative value of Petitioner's 2010 conviction was not substantially outweighed by the danger of unfair prejudice; and (3) Petitioner waived his remaining argument. View "Woodlin v. State" on Justia Law

Posted in: Criminal Law