Justia Criminal Law Opinion Summaries

Articles Posted in Maryland Court of Appeals
by
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

by
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

by
The Court of Appeals held that Defendant had a reasonable expectation of privacy in data contained on his hard drive and that the government conducted an unreasonable search by examining data without any authority to do so either by a warrant or an exception to the warrant requirement.At issue was whether the consensual creation of a copy of the hard drive of Defendant's seized laptop computer permanently eliminated Defendant's privacy interest in the hard drive. The circuit court denied Defendant's motion to suppress and ultimately convicted him of three counts of distribution of child pornography. The appellate court reversed, concluding that individuals have a legitimate expectation of privacy in the digital data within their computer and that Defendant's revocation of his consent to examine the data from his laptop precluded a forensic examination of the mirror-image copy of its hard drive without a warrant. The Court of Appeals affirmed, holding that the search in this case was unreasonable after Defendant withdrew his consent. View "State v. McDonnell" on Justia Law

by
The Court of Appeals affirmed the judgment of the appellate court reversing the decision of the circuit circuit court that examination of data contained on Defendant's hard drive was not a search in violation of the Fourth Amendment, holding that the government violated Defendant's Fourth Amendment rights in this case.Defendant voluntarily consented to government agents seizing his laptop computer, creating a copy of its hard drive, and searching the data on it. After the copy was made but before the government examined the data Defendant withdrew his consent. Defendant moved to suppress the evidence from the forensic examination of the copy of his laptop's hard drive. The circuit court denied the motion. On appeal, Defendant asserted that he had a legitimate expectation of privacy in the mirror-image copy of his laptop hard drive. The appellate court agreed and reversed. The Court of Appeals affirmed, holding (1) Defendant had a reasonable expectation of privacy in the data contained on his hard drive; (2) because the government did not examine the data before Defendant withdrew his consent Defendant did not lose his reasonable expectation of privacy in the data; and (3) the government conducted an unreasonable search by examining the data without any authority to do so. View "State v. McDonnell" on Justia Law

by
The Court of Appeals reversed Petitioner's conviction for first-degree murder and use of a handgun in the commission of a crime, holding that the circuit court erred in permitting a firearms examiner to testify, without qualification, that bullets left at a murder scene were fired from a gun that Petitioner had acknowledged was his, and the error was not harmless.In arguing that the circuit court abused its discretion in permitting the firearms examiner's testimony Petitioner cited reports, studies, and testimony calling into question the reliability of firearms identification analysis. The Court of Appeals agreed with Petitioner and reversed and remanded the case for a new trial, holding (1) the reports, studies, and testimony presented to the circuit court demonstrated that the firearms identification methodology employed in this case could not reliably support an unqualified conclusion that the bullets were fired from a particular firearm; and (2) this Court was not convicted, beyond a reasonable doubt, that the error in no way influenced the verdict. View "Abruquah v. State" on Justia Law

by
The Court of Appeals vacated the judgment of the appellate court affirming the decision of the circuit court denying Appellant's motion to dismiss the charges against him after this Court remanded his case to the circuit court with instructions to grant his petition for writ of actual innocence and to conduct a new trial, holding that it was not possible for the Court to meaningfully evaluate whether Appellant suffered irreparable prejudice for which dismissal of the charges was the only feasible remedy.Appellant was convicted of first-degree murder. After Appellant's petition for writ of actual innocence was denied, the Court of Appeals concluded that the circuit court erred in denying the petition. Before his retrial, Appellant moved to dismiss the charges based on due process and double jeopardy violations. The circuit court denied the motion, after which Appellant and the State entered into a plea agreement. The appellate court affirmed the denial of Appellant's motion to dismiss. The Court of Appeals vacated the judgment and remanded the case, holding that, given that the new trial ordered by the Court did not take place, it was not possible for this Court to assess beyond mere speculation what the evidence might have consisted of at retrial. View "Smith v. State" on Justia Law

by
The Court of Appeals affirmed in part and reversed in part the judgment of the appellate court deciding the merits of Defendant's appeal and affirming Defendant's conviction for voluntary manslaughter and related offenses, holding that the constitutional right to a fair trial extends to appellate proceedings, that the appellate court erred in deciding the merits of Defendant's appeal, and that a new trial was required.During Defendant's appeal, the appellate court compared Defendant, an African American man, to the mythical monster Grendel in Beowulf. On appeal to the Court of Appeals Defendant argued that this reference evoked racist tropes of African Americans and that other passages in the appellate court's dicta deprived him of his constitutional right to a fair and impartial appellate process. The Court of Appeals remanded the case for a new trial, holding (1) the right to fair and impartial judges extends to appellate proceedings; and (2) the appellate court erred in concluded that the exclusion of certain evidence was harmless because its exclusion was harmful, reversible error. View "Belton v. State" on Justia Law

by
The Court of Appeals affirmed the judgment of the circuit court denying Petitioner's petition for post-conviction DNA testing pursuant to Md. Code Ann. Crim. Proc. 8-201(b)(1), holding that Petitioner was not entitled to relief on his allegations of error.Petitioner was convicted of first-degree murder and other offenses and sentenced to life imprisonment plus a term of 150 years' imprisonment. In his post-conviction petition, Petitioner asserted that there was a reasonable probability that DNA testing of certain evidence had the scientific potential to produce exculpatory or mitigating evidence. The circuit court denied the petition. The Court of Appeals affirmed, holding that the circuit court properly denied the petition because the record and testimony reflected that any results of testing the subject evidence would not produce exculpatory or mitigating evidence. View "Satterfield v. State" on Justia Law

by
The Court of Appeals affirmed Defendant's conviction of sexual abuse of a minor under Md. Code Ann., Crim. Law (CR) 3-602, holding that, under the applicable standard of review, the evidence was sufficient for a rational juror to find that, with his in-classroom conduct, Defendant, a thirty-year-old substitute teacher, engaged in an act that involved sexual exploitation of a minor.Defendant indulged in a sexually exploitative relationship with A.G., a twelve-year-old student, during out-of-school hours. The appellate court reversed Defendant's conviction for sexual abuse of a minor on the grounds that he had not "said or implied anything sexual" in his conversation with A.G. in school. The Court of Appeals reversed, holding (1) the occurrence of sexual exploitation outside of the perpetrator's time of responsibility for supervision of the minor may be used to establish child sexual abuse under CR 3-602, but there must be a showing that the perpetrator engaged in an act relating to, affecting or that was a part of the sexual exploitation while the perpetrator was responsible for the care, custody, or supervision of the minor; and (2) the evidence demonstrated that Defendant's in-school conduct fell within the meaning of the language of the statute. View "State v. Krikstan" on Justia Law

by
The Court of Appeals affirmed the judgment of the appellate court affirming the circuit court's denial of Petitioner's petition for writ of actual innocence, holding that there was no abuse of discretion.After a jury trial, Petitioner was convicted of first-degree murder, use of a handgun in a crime of violence, and wearing or carrying a handgun. Petitioner was sentenced to life imprisonment without parole for the murder charge and an additional twenty years' imprisonment for the handgun offenses. In his petition for writ of actual innocence, Petitioner claimed that three categories of new evidence created a substantial possibility of a different outcome at trial. The circuit court denied the petition, and the appellate court affirmed. The Court of Appeals affirmed, holding that Petitioner failed to show that the circuit court abused it discretion in denying his petition for actual innocence. View "Carver v. State" on Justia Law