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The Court of Appeals vacated all of Petitioner’s sentences and remanded the case for resentencing, holding that, under the circumstances of this case, it was appropriate for the Court to exercise its discretion to vacate all of Petitioner’s sentences. Specifically, the Court held (1) the law of the case doctrine does not bar a trial court from considering under Maryland Rule 4-345(a) an issue as to a sentence’s legality that an appellate court has not resolved, and the Court of Special Appeals erred in concluding that the law of the case doctrine barred the circuit court from considering Defendant’s second challenge to his sentence for conspiracy to commit false imprisonment because the Court of Special Appeals did not resolve that challenge in the first appeal in this case; (2) under CR 1-202, where a defendant is convicted of both a crime and conspiracy to commit that crime, a trial court cannot impose for the conspiracy a sentence that exceeds the maximum sentence that the trial court imposed for the crime that the person conspired to commit; and (3) under CR 12-702(b), an aggregate sentence of a certain number of years of imprisonment is more severe than a sentence of life imprisonment, with all but a lower number of years suspended. View "Nichols v. State" on Justia Law

Posted in: Criminal Law

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The Court of Appeals held that the trial judge abused his discretion in directing the State to reopen its case-in-chief to recall an expert witness after the defense moved for judgment of acquittal, and therefore, Respondent was entitled to a new trial. A jury convicted Respondent of murder. The Court of Special Appeals vacated the trial court’s judgment and remanded the case for a new trial, holding that the trial court abused its discretion when it reopened the State’s case before ruling on Respondent's motion for judgment of acquittal. The Court of Appeals affirmed, holding that Respondent’s right to a fair trial was compromised because the trial judge (1) impermissibly weighed the nature of the charges brought against Respondent; (2) exceeded the bounds of judicial impartiality when he effectively assumed the role of prosecutor in directing the state to fix a perceived defect in its case; and (3) acted in contravention to caselaw when he permitted the State to reopen its case to avoid granting Respondent an acquittal. View "State v. Payton" on Justia Law

Posted in: Criminal Law

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The Court of Appeals reversed the judgment of the Court of Special Appeals and directed the remand of this matter to the circuit court for a hearing on the merits of Petitioner’s motion for a new trial under Maryland Rule 4-331(c) based on newly discovered evidence, holding that because the trial court failed to consider whether Petitioner presented a prima facie case based on the newly discovered evidence, the trial court erred in summarily denying the motion without a hearing. Petitioner was convicted of first degree murder and other offenses. Approximately two weeks after his sentencing, Petitioner filed a motion for a new trial under Rule 4-331(c) based on newly discovered evidence. The circuit court summarily denied the motion. The Court of Appeals upheld the denial of the motion. The Court of Appeals reversed, holding that Petitioner alleged a prima facie basis for newly discovered evidence in his motion for a new trial, and therefore, the trial court erred when it denied Petitioner’s request without holding a hearing. View "Cornish v. State" on Justia Law

Posted in: Criminal Law

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The Court of Appeals affirmed the judgment of the court of appeals affirming the judgment of the circuit court convicting Defendant of second-degree murder, holding that the trial court erred in admitting certain evidence, but the error was harmless, and the court did not err in admitting other evidence. Specifically, the Supreme Court held (1) the trial court erred in concluding that defense counsel had “opened the door” for the State to present evidence of the victim’s trait of peacefulness under Maryland Rule 5-404(a)(2)(C) and in permitting the State to elicit testimony in its case-in-chief from State’s witnesses that the victim was a peaceful person, but the error was harmless beyond a reasonable doubt; and (2) the trial court properly permitted Defendant’s ex-girlfriend to testify about Defendant’s post-crime conduct as evidence of consciousness of guilt. View "Ford v. State" on Justia Law

Posted in: Criminal Law

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The Court of Appeals held that the Public Service Commission (Commission) acted within its authority when it approved the acquisition of Pepco Holdings, Inc. (PHI) and its utility subsidiaries by Exelon Corporation (Exelon). The General Assembly has provided for judicial review of decisions of the Commission assessing and either approving or rejecting an acquisition of a company that supplies electricity in the State, including a merger with another utility. At issue here was the Commission’s approval of the acquisition of PHI and its utility subsidiaries by Exelon. The circuit court and Court of Special Appeals concluded that the Commission acted within its authority when it approved the transaction. The Court of Appeals affirmed, holding (1) the Commission properly considered the factors listed in Md. Code Pub. Util. Cos. 6-105(g)(2) and exercised its discretion as to what weight to accord factors other than those specifically listed in the statute; and (2) the Commission acted neither arbitrarily nor capriciously in evaluating harm to renewable and distributed generation markets. View "Office of People's Counsel v. Maryland Public Service Commission" on Justia Law

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At issue was three crimes that were committed when each of three Petitioners was a juvenile and whether each Petitioner was effectively serving a sentence of life without parole because the laws of Maryland do not provide him with a “meaningful opportunity to obtain release based on demonstrated maturity and rehabilitation.” See Graham v. Florida, 560 U.S. 48 (2010). None of the sentences imposed in these cases was explicitly “life without parole.” In all three cases each Petitioner filed a motion to correct an illegal sentence. The Court of Appeals concluded that one Petitioner was entitled to be resentenced to a legal sentence, holding (1) with respect to the two Petitioners serving life sentences, their sentences are legal under the laws governing parole of inmates serving life sentences in Maryland; but (2) with respect to the Petitioner serving a 100-year sentence, the sentence is effectively a sentence of life without parole in violation of the Eighth Amendment. View "Carter v. State" on Justia Law

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The Court of Appeals affirmed the judgment of the Court of Special Appeals granting Respondent’s motion to dismiss and dismissing the State’s appeal from the circuit court’s grant of Respondent’s motion to correct illegal sentence for want of a final judgment, holding that the circuit court’s grant of Respondent’s motion correct an illegal sentence and vacation of Respondent’s sentence was an interlocutory order that will not become a final judgment triggering the State’s right to appeal until the circuit court imposes a new sentence. The circuit court vacated the sentence imposed in connection with Respondent’s convictions for three counts of first-degree murder and other crimes after granting Respondent’s motion to correct illegal sentence under Maryland Rule 4-345(a) based on recent United States Supreme Court precedent involving life sentences for juvenile offenders. The State appealed. The Court of Appeals granted Respondent’s motion to dismiss, holding that the mere grant of a motion to correct an illegal sentence, without imposition of a new sentence, is not an appealable final judgment from which the State has the right to appeal. View "State v. Clements" on Justia Law

Posted in: Criminal Law

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The Court of Appeals affirmed the judgment of the Court of Special Appeals finding that the trial court did not deny Petitioner due process by permitting the State to question him about his failure to disclose an alibi defense after he invoked Miranda. Petitioner was convicted of first degree murder and other crimes. On appeal, Petitioner argued that the trial court denied him due process by allowing the prosecutor to question him about “what he did not tell the police about his alibi defense, even though the omissions were a result of [Petitioner’s] post-arrest, post-Miranda invocation of silence and were not inconsistencies with his trial testimony.” The State countered that even statements taken in violation of Miranda can be used to impeach a witness’s prior inconsistent statement. The Court of Appeals held that an invocation of Miranda does not preclude the State from impeaching a witness concerning prior inconsistent statements, even after a suspect invokes his right to remain silent. View "Reynolds v. State" on Justia Law

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At issue before the Court of Appeals was the correct interpretation of Md. Code Ann. Pub. Util. (PU) 4-210, known as the STRIDE statute, which allows Maryland gas companies more timely cost recovery if they submit plans that increase the pace of natural gas infrastructure improvements. The Maryland Public Service Commission, the circuit court of Montgomery County, and the court of special appeals each concluded that the STRIDE statute provides accelerated cost recovery only for gas infrastructure projects located in the State. The Court of Appeals affirmed, holding that the STRIDE statute’s legislative history supports this Court’s interpretation that PU 4-210 is unambiguous and requires that “gas infrastructure improvements” be located “in the State” in order promptly to recover investment costs separate from base rate proceedings. View "Washington Gas Light Co. v. Maryland Public Service Commission" on Justia Law

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At issue was whether allowing a child to remain indefinitely in the custody of a third party, without termination of the parents’ parental rights, constitutes a proper exercise of judicial discretion consistent with the pertinent provisions of the Family Law Article. The Court of Appeals held that the Family Law Article allows for such discretionary exercise so long as the decision is grounded in statutory requirements and is supported by the record, and pursuit of the child’s best interest remains the overarching goal involving termination of parental rights. The Court affirmed in part and reversed in part the judgment of the juvenile court in this case, holding (1) the juvenile court did not err in declining to terminate Father’s parental rights because a rational finding existed that a continued relationship with Father served the child’s best interest even where complete custodial reunification was not apparent; and (2) regarding Mother, the juvenile court’s determination that a continued parental relationship served the child’s best interest lack consideration of the relevant statutory considerations found in Md. Code Ann. Fam. Law 5-323. View "In re Adoption/Guardianship of C.E." on Justia Law

Posted in: Family Law