Justia Maryland Court of Appeals Opinion Summaries

Articles Posted in Civil Rights
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The Court of Appeals vacated the judgment of the court of special appeals concluding that Appellant had waived his right to appeal the denial of his motion to suppress, holding that Appellant did not waive his right to appeal the suppression ruling.After he had been convicted of a crime of violence Appellant was indicted on charges of possessing a regulated firearm. Appellant filed a motion to suppress the gun and the loaded magazine recovered by law enforcement officers while conducting a warrantless search of his hotel room. Thereafter, the State filed a superseding indictment under a new case number to add additional charges. Appellant subsequently renewed his motion to suppress in the new case. The trial court denied the motion, and Appellant was convicted of first-degree assault and other crimes. The court of appeals affirmed, ruling that Appellant waived his challenge to the denial o this motion to suppress. The Court of Appeals remanded the case for further consideration, holding that defense counsel did not waive Appellant's right to appellate review of the denial of his motion to suppress. View "Huggins v. State" on Justia Law

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The Court of Appeals affirmed the judgment of the court of special appeals affirming the decision of the circuit court denying Defendant's motion to suppress the fruits of the warrantless search of his backpack and the warranted search of his cell phone, holding that Defendant was not entitled to relief on appeal.After a school resource officer broke up a fight in which Defendant was involved, Defendant's backpack dropped to the ground. When the officer picked up the backpack Defendant ran from the scene. The officer subsequently searched the backpack and discovered a stolen firearm and three cell phones. The officers obtained a warrant to search one cell phone. Thereafter, Defendant was charged with robbery and other offenses. After the trial court denied Defendant's suppression motion as to both searches Defendant pleaded guilty to conspiracy to commit robbery and wearing, carrying, and transporting a handgun. The court of special appeals affirmed. The Supreme Court affirmed, holding (1) because Defendant abandoned his backpack the warrantless search of his backpack was constitutionally permissible; and (2) the warrant authorizing the search of the cell phone did not comply with the particularity requirement of the Fourth Amendment, but the good faith exception to the exclusionary rule applied to the fruits of the cell phone search. View "Richardson v. State" on Justia Law

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The Court of Appeals vacated Defendant's convictions for second-degree assault and second-degree child abuse by a custodian, holding that Defendant, an Afrian American man, was prejudiced by the fact that the Sheriff's deputies who served as courtroom bailiffs during his trial wore thin blue line face masks, as required by the Sheriff.On appeal, Defendant argued that the bailiffs' display of the thin blue line flag on their face masks violated his Sixth Amendment right to a fair trial. The court of special appeals affirmed the convictions, concluding that the display of the thin blue line flag did not violate Defendant's right to a fair trial. The Court of Appeals vacated Defendant's convictions, holding that the bailiffs' display of the thin blue line flag and the pro-law enforcement message that it conveyed was inherently prejudicial to Defendant's constitutional right to a fair trial. View "Smith v. State" on Justia Law

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The Court of Appeals reversed the judgment of the court of special appeals affirming the decision of the circuit court granting summary judgment in favor of Defendants in this case involving violent peer conflicts between adolescents in middle school, holding that the circuit court erred.Plaintiffs filed a five-count complaint against several school defendants and the Board of Education for Dorchester County, alleging violations of their daughter's state constitutional right to due process and other causes of action stemming from their daughter's bullying by other students. The circuit court granted summary judgment for Defendants, and the court of special appeals affirmed. The Court of Appeals reversed, holding (1) the Act does not preempt CJ § 5-518, and Plaintiffs' negligence claims against the individual school employees were not preempted by federal law; (2) the educational malpractice doctrine does not apply to Plaintiffs' negligent supervision claims; and (3) material disputes of fact precluded the entry of summary judgment. View "Gambrill v. Bd. of Education of Dorchester County" on Justia Law

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The Court of Appeals affirmed the decision of the court of special appeals affirming the judgment of the circuit court denying Appellant's motion to correct an illegal sentence, holding that Appellant's sentencing proceeding complied with the constitutional protections recognized in recent decisions of the Supreme Court.In 2010, Petitioner was convicted of first-degree felony murder and other crimes for his involvement in a burglary at the age of sixteen that resulted in a murder. Petitioner was sentenced to life in prison with all but sixty years suspended for the murder conviction and will be eligible for parole at the time he is forty-two years old. In 2017, Petitioner filed a motion to correct an illegal sentence, arguing that his sentence violated the Eighth Amendment, as interpreted in recent decisions of this Court and the Supreme Court. The circuit court denied the motion, and the court of special appeals affirmed. The Supreme Court affirmed, holding that Petitioner's sentence did not amount to a de facto sentence of life without parole, and his sentence was not grossly disproportionate. View "Jedlicka v. State" on Justia Law

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The Court of Appeals held that ambiguity in a sentencing court's remarks about a juvenile offender's post-offense conduct and character, when made before the Supreme Court issued its decisions governing the sentencing of a juvenile offender to life without the possibility of parole, requires that the offender receive a new sentencing hearing for purposes of the Eighth Amendment.Petitioner was seventeen years old when he committed a series of murders. In Maryland, Petitioner pled guilty to six counts of first-degree murder. The sentencing court sentenced him to the maximum sentence of six terms of life in prison without the possibility of parole. After the Supreme Court decided Miller v. Alabama, 567 U.S. 460 (2012), Petitioner filed a motion to correct an illegal sentence. The circuit court denied the motion. The Supreme Court remanded the case, holding that because opposing inferences could be drawn as to whether the sentencing judge determined that Petitioner was not "the rare juvenile offender whose crimes reflects irreparable corruption" for whom the Eighth Amendment allows a sentence of life without parole. View "Malvo v. State" on Justia Law

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The Court of Appeals reversed the decision of the court of special appeals reversing Defendant's conviction of one count of second-degree assault, holding that it was harmless error to fail to propound a voir dire question regarding Defendant's right to remain silent and not testify where Defendant actually testified.During trial, Defendant requested a voir dire question on her right not to testify, but the trial court declined to ask the question. During trial, Defendant testified in her defense. In reversing, the court of special appeals determined that the trial court erred under Kazadi v. State, 467 Md. 1 (2020), and that the error was not harmless. The Court of Appeals reversed, holding (1) the Kazadi error in this case was subject to the harmless error doctrine; and (2) the Kazadi error was harmless. View "State v. Jordan" on Justia Law

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The Court of Appeals vacated the judgment of the court of special appeals concluding that Defendant had waived his right to appeal the denial of his suppression motion, holding that Defendant did not waive his right to appeal the suppression ruling.Defendant, who was indicted on charges of possessing a regulated firearm after having been convicted of a crime of violence and other crimes, moved to suppress the gun and loaded magazine that police recovered inside a closed overnight bag during a warrantless search of Defendant's hotel room. The trial judge denied the motion to suppress. Thereafter, the State filed a superseding indictment under a new case number to add additional charges. When Defendant renewed his motion to suppress the transcript and all exhibits from the motion filed in the first case were admitted and incorporated into the record. The handgun and magazine were admitted into evidence during Defendant's ensuing trial. The court of special appeals denied Defendant's appeal, concluding that Defendant waived his right to appeal the suppression ruling by making no objection to the introduction of the challenged evidence at trial. The Court of Appeals vacated the decision below, holding that Defendant did not waive his right to appeal the suppression ruling. View "Huggins v. State" on Justia Law

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The Court of Appeals reversed the decision of the court of special appeals reversing the judgment of the circuit court, sitting as the juvenile court, denying D.D.'s motion to suppress evidence of a loaded gun found by law enforcement officers in D.D.'s waistband, holding that there was no constitutional violation in this case.At issue in this case was whether this Court should extend the holding in Lewis v. State, 470 Md. 1 (2020), that the odor of marijuana alone does not provide probable cause to believe that the person is in possession of a criminal amount of the drug, to an investigatory detention. In reversing the juvenile court's denial of D.D.'s suppression motion, the court of special appeals held that the investigatory detention of D.D., which was based solely on the order of marijuana, violated the Fourth Amendment. The Court of Appeals reversed, holding (1) the odor of marijauna provides reasonable suspicion of criminal activity sufficient to conduct a brief investigatory detention; and (2) the officers in the instant case had reasonable suspicion to detain D.D., and therefore, the pat-down that led to the discovery of the gun on D.D. was also reasonable. View "In re D.D." on Justia Law

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The Court of Appeals affirmed the decision of the court of special appeals affirming Defendant's convictions for first-degree felony murder, first-degree burglary, and the theft of a Jeep, holding that Defendant was not entitled to relief on his allegations of error.Specifically, the Court of Appeals held (1) Defendant's felony murder conviction was not preempted by the manslaughter by motor vehicle statute; (2) Defendant's sentence of life in prison with the possibility of parole was not unconstitutional under either the Eighth Amendment or Article 25 of the Maryland Declaration of Rights; and (3) Defendant was not entitled to an individualized sentencing proceeding under Miller v. Alabama, 567 U.S. 460 (2012). View "Harris v. State" on Justia Law