Justia Maryland Court of Appeals Opinion Summaries

Articles Posted in Criminal 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 finding Appellant in violation of his probation and sentencing him to serve ten years, holding that there was no error.Appellant pled guilty in five cases involving theft charges and violations of probation. As a condition of probation, the circuit court ordered Appellant to enroll in, comply with the conditions of, and successfully complete the Drug Court program. The State later alleged that Appellant violated his probation by failing to comply with the requirements of Drug Court. Appellant was found in violation of his probation. The Court of Appeals affirmed, holding that a trial judge assigned to a drug court program is not required to recuse him or herself from presiding over a violation of probation proceeding for a current drug court participant. View "Conner v. State" on Justia Law

Posted in: Criminal Law
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The Court of Appeals affirmed the judgment of the court of special appeals affirming the denial of Defendant's motion for new trial on the grounds that certain newly discovered evidence was immaterial, holding that there was no Brady violation in this case.Defendant was convicted of two counts of first-degree murder. Following the trial but prior to sentencing, the State informed Defendant's counsel of an interview that took place between two detectives and the family members of one of the State's witnesses. Defendant moved for a new trial, arguing that the nondisclosure of the interview violated Brady v. Maryland, 373 U.S. 83 (1963). The circuit court denied the motion, finding that the evidence of the interview was not material. The Court of Appeals affirmed, holding that the nondisclosure of the interview did not constitute a Brady violation. View "Canales-Yanez v. State" on Justia Law

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The Court of Appeals affirmed the judgment of the court of special appeals reversing Defendant's convictions on the grounds that the circuit court should have granted Defendant's motion to suppress, holding that the State failed to meet its burden of establishing the constitutionality of Defendant's seizure at the suppression hearing.When Maryland Transit Administration (MTA) police officers conducted a fare sweep aboard a Light Rail train Defendant confessed that he did not have a ticket. An officer obtained identifying information from Defendant and ran a warrant check on him revealing the existence of a warrant for Defendant's arrest. In attempting to arrest Defendant, officers saw that Defendant had a gun. Defendant moved to suppress the gun, arguing that the fare sweep constituted a warrantless seizure not based on reasonable suspicion. The circuit court denied the motion to suppress. The court of special appeals reversed, concluding that the circuit court erred in denying Defendant's suppression motion. The Court of Appeals affirmed, holding (1) police officers effected a seizure of Defendant without reasonable suspicion by announcing the fare sweep, and Defendant did not impliedly consent to the seizure by riding the train; and (2) the record was insufficiently developed to conclude whether Light Rail sweeps are constitutional under the special needs doctrine. View "State v. Carter" on Justia Law

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The Court of Appeals affirmed the judgment of the court of special appeals reversing Defendant's conviction of voluntary manslaughter and ordering a new trial, holding that the trial court erred in its formulation of the jury instruction on Battered Spouse Syndrome, and this error was not harmless beyond a reasonable doubt.Defendant killed her boyfriend but claimed that she did so in self-defense. To support her theory of self-defense, Defendant introduced expert testimony concerning Battered Spouse Syndrome (the Syndrome). The jury acquitted Defendant of murder but convicted her of voluntary manslaughter. The court of special appeals ordered a new trial, concluding that the trial judge's instruction to the jury concerning the Syndrome was erroneous and that the error was not harmless beyond a reasonable doubt. The Court of Appeals affirmed, holding that the trial court erred in instructing the jury regarding the Syndrome and that the error was not harmless. View "State v. Elzey" on Justia Law

Posted in: Criminal Law
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The Court of Appeals reversed the judgment of the court of special appeals reversing Defendant's conviction of perjury and making a false statement to a police officer, holding that the State presented sufficient evidence to prove the elements of perjury and false statement beyond a reasonable doubt.Specifically, the Court of Appeals held (1) the court of special appeals erred when it applied a non-deferential, de novo standard of review to the legal sufficiency of the evidence; (2) the court of special appeals erred in finding that the evidence was insufficient to show willful and knowing falsity and in finding that one witness's testimony corroborated by surveillance video was insufficient to satisfy the two-witness rule for perjury; and (3) the evidence was legally sufficient to support Defendant's convictions. View "State v. McGagh" on Justia Law

Posted in: Criminal Law
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The Court of Appeals reversed the judgment of the court of special appeals reversing the circuit court's judgment entering judgment on the jury's verdict finding Defendants guilty of home invasion and other crimes, holding that the court of special appeals erred in concluding that jury nullification is authorized in Maryland.Three defendants were charged with multiple offenses related to a home invasion, kidnapping, and armed robbery. During jury deliberations, the jury sent three notes to the court inquiring about jury nullification. The court of special appeals reversed the convictions, concluding that the power of jury nullification exists in Maryland and that the circuit court's instructions in response to two of the jury notes at issue were legally incorrect and prejudicial. The Court of Appeals reversed, holding (1) jury nullification is not authorized in Maryland; and (2) the circuit court's instructions were neither legally incorrect nor prejudicial. View "State v. Sayles" on Justia Law

Posted in: Criminal Law
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In this case concerning the admissibility of jailhouse rap lyrics composed by Defendant as substantive evidence that he shot and killed George Forrester the Court of Appeals held that the rap lyrics were relevant and admissible and that the trial judge did not abuse his discretion in admitting the lyrics.The State sought to introduce a recorded telephone call containing the rap lyrics as substantive evidence of Defendant's guilt. Defendant moved in limine to exclude the recording. The circuit court denied the motion and admitted the rap lyrics. The Court of Special Appeals affirmed, concluding that the lyrics were admissible under Maryland Rules 5-401, 5-402, and 5-403. The Court of Appeals affirmed, holding (1) the rap lyrics were relevant under Rule 5-401, and therefore were admissible under Rule 5-402; (2) the rap lyrics bore a close factual and temporal nexus to the details of the murder; and (3) therefore, the circuit court did not abuse its discretion in admitting the rap lyrics under Rule 5-403. View "Montague v. State" on Justia Law

Posted in: Criminal Law
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The Court of Appeals affirmed the judgment of the Court of Special Appeals affirming the judgment of the circuit court convicting Defendant of assault in the first degree, use of a firearm in the commission of a crime of violence, and wearing, carrying or transporting a handgun, holding that the Court of Special Appeals did not err.Specifically, the Court of Appeals held that the Court of Special Appeals (1) correctly affirmed the admission of a statement by a witness with memory loss as a prior inconsistent statement given the witness's contradictory testimony at trial; and (2) did not err in expanding the circumstances rule which hearsay is admissible under Md. Rule 5-802.1(a) to include statements containing a "material" inconsistency with the witness's testimony. View "Wise v. State" on Justia Law

Posted in: Criminal Law
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The Court of Appeals affirmed the judgment of the Court of Special Appeals upholding the circuit court's denial of coram nobis relief, holding that the nondisclosure of evidence relating to the alleged misconduct of several of the officers that prompted the charges and pleas in this case was not sufficient to render Petitioner's pleas involuntary.Petitioner pled guilty to have committed, in two separate cases, the crime of possession of heroin with intent to distribute. Upon completion of his sentences and probation, Petitioner filed a petition for a writ of error coram nobis, arguing that prior to the entry of his guilty pleas, the State failed to disclose to him evidence of misconduct on the part of some officers involved in the arrests that prompted the criminal charges and pleas. The circuit court denied the petition, and the court of appeals affirmed. The Supreme Court reversed, holding that the State was under no obligation to disclose the potential evidence of misconduct prior to trial and that the nondisclosure did not constitute a misrepresentation in violation of Brady v. United States, 397 U.S. 742 (1970). View "Byrd v. State" on Justia Law

Posted in: Criminal Law
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The Court of Appeals held that the evidence in this case was sufficient to support Defendant's convictions for witness tampering and obstruction of justice where Defendant married a witness for the State with the corrupt intent of having her invoke the spousal testimonial privilege at his upcoming murder trial.The evidence indicated that Defendant married a potential witness for the State in order to have the witness invoke the spousal testimonial privilege at his murder trial. Before trial, the circuit court granted the State's motion to preclude the witness from invoking the spousal testimonial privilege. A jury subsequently found Defendant guilty of witness tampering and obstruction of justice. The Court of Special Appeals reversed, concluding that the evidence was insufficient to support the convictions because State failed to prove the "corrupt means" element of the convictions. The Court of Appeals reversed, holding (1) when a person marries a potential State witness with the intent to enable the witness to invoke the spousal testimonial privilege at a criminal proceeding the evidence is sufficient to support convictions for witness tampering and obstruction of justice; and (2) Defendant's conviction for witness tampering did not merge for sentencing purposes with his obstruction of justice conviction. View "State v. Wilson" on Justia Law

Posted in: Criminal Law