Justia Maryland Court of Appeals Opinion Summaries

Articles 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
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The Court of Appeals affirmed the judgment of circuit court judge upholding the order of the administrative law judge (ALJ) ordering Gregory Johnson's involuntary medication, holding that there was no error in the order authorizing Johnson's involuntary medication.Johnson was charged with attempted first-degree murder and related offenses. The circuit court found Johnson incompetent to stand trial and dangerous and committed him for treatment to a state-run forensic psychiatric hospital. After Johnson repeatedly refused to take prescribed antipsychotic medication the Maryland Department of Health began the process to administer the medication to Johnson involuntarily. An ALJ ordered Johnson's involuntary medication to restore him to competency, and the circuit court upheld the order. The Court of Appeals affirmed, holding (1) Maryland law authorizes involuntary medication to restore an individual's competence to stand trial and does not violate separation of powers by entrusting an ALJ with the power to order such medication subject to judicial review; and (2) because the Department and the ALJ met due process requirements, there was no error in the order authorizing Johnson's involuntary medication. View "Johnson v. Department of Health" on Justia Law

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The Court of Appeals answered four questions of law concerning the application of the Justice Reinvestment Act (JRA), Chapter 515, Laws of Maryland 2016, specifically, a provision codified in Md. Code Ann. Crim. Law (CR) 5-609.1.The JRA eliminated mandatory minimum sentences of imprisonment without the possibility of parole required by existing law for defendants who were convicted of certain drug offenses and who were repeat offenders. CR 5-609.1 provides that a defendant who had received a mandatory minimum sentence prior to the elimination of such sentences can ask the court to reduce that sentence. A number of inmates currently serving mandatory minimum sentences invoked CR 5-609.1 and filed motions to modify or reduce their sentences. The Court of Special Appeals certified questions of law concerning CR 5-609.1 that pertained to pending appeals in that court. The Court of Appeals answered the certified questions as to the application of CR 5-609.1 when the mandatory minimum sentence relates to a conviction based on a court-approved plea agreement under which the parties agreed that the mandatory minimum sentence would be imposed and when the defendant waived the right to seek modification of that sentence as part of the plea agreement. View "Brown, Bottini & Wilson v. State" on Justia Law

Posted in: Criminal Law
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The Court of Appeals affirmed Defendant's convictions for sexually abusing several female students while he was their elementary school teacher, holding that any error by the trial court in excluding character evidence of appropriateness with children in Defendant's custody or care was harmless beyond a reasonable doubt.On appeal, Defendant argued that the trial judge erred by excluding evidence from parents of students and from professional colleagues that, in their opinion, Defendant was the type of person who behaved appropriately with children in his custody or care. The Court of Special Appeals affirmed. The Court of Appeals also affirmed, holding (1) character evidence of appropriateness with children in one's custody or care may be admissible in a criminal case where a defendant is accused of sexually abusing a child; (2) any error in excluding Defendant's proffered character evidence was harmless beyond a reasonable doubt; and (3) Defendant's constitutional arguments were not preserved for appellate review or abandoned and, in any event, lacked merit. View "Vigna v. State" on Justia Law

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The Court of Appeals reversed the decision of the court of special appeals reversing the decision of the post-conviction court granting Petitioner post-conviction relief based on the court's finding that Petitioner received ineffective assistance of counsel, holding that Petitioner's counsel rendered ineffective assistance based on a conflict of interest.Petitioner pleaded guilty to possession with intent to distribute a controlled dangerous substance. Petitioner subsequently filed a petition for post-conviction relief, alleging that he received ineffective assistance of counsel because he was misadvised of the immigration consequences of his plea agreement and because his counsel failed to disclose a personal conflict of interest. The post-conviction court granted Petitioner relief based on the court's finding of an actual conflict of interest. The court of special appeals reversed. The Court of Appeals reversed, holding that defense counsel's conflict of interest rendered his representation of Petitioner constitutionally deficient under the Sixth Amendment to the United States Constitution and Article 21 of the Maryland Declaration of Rights. View "Podieh v. State" on Justia Law

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The Court of Appeals affirmed the judgment of the court of special appeals affirming the judgment of the coram nobis court ruling that Defendant failed to prove that his attorney performed below constitutional standards and was therefore not entitled to coram nobis relief, holding that the coram nobis court did not err.Defendant was convicted of reckless endangerment and illegally transporting a handgun in a vehicle. The court sentenced Defendant to fourteen days of jail time and three years of probation. Defendant's attorney later filed a motion for modification of sentence, asking that the court consider changing the sentence to probation before judgment. However, the attorney asked the court to defer consideration of the motion until after the conclusion of Defendant's probation. A hearing on the motion was never held. Defendant subsequently sought to expunge the records of his criminal charges but was not successful because he had not received probation before judgment. Defendant sought a writ of error coram nobis asking that the sentencing court belatedly hold a hearing and decide his motion for modification of sentence. The coram nobis court and the court of special appeals denied relief. The Court of Appeals affirmed, holding that Defendant's attorney did not provide ineffective assistance of counsel. View "Franklin 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 reversing in part Defendant's convictions for involuntary manslaughter, reckless endangerment, and neglect of a minor stemming from the death of her infant, holding that the evidence was insufficient to support Defendant's convictions for involuntary manslaughter and reckless endangerment.Defendant's four-month-old infant died as a result from asphyxia after Defendant slept on top of her infant after a virtual "Moms' night out" drinking beer with her friends via Facebook livestream. Defendant as convicted of involuntary manslaughter, reckless endangerment, and neglect of a minor. The Court of Special Appeals concluded that Defendant's conduct was insufficient to support a finding of "gross negligence," which was required for the involuntary manslaughter conviction and that the evidence was insufficient to support the reckless endangerment conviction. The Supreme Judicial Court affirmed, holding that the evidence was insufficient to support Defendant's convictions for involuntary manslaughter and reckless endangerment because the conduct neither rose to the level of gross negligence more constituted a "gross departure from the conduct of a reasonably prudent person" such that it could be deemed reckless. View "State v. Morrison" on Justia Law

Posted in: Criminal Law