Justia Criminal Law Opinion Summaries

Articles Posted in Maryland Court of Appeals
by
The Court of Appeals reversed the decision of the court of special appeals reversing Defendant's conviction for various crimes related to the murders of two high school seniors, holding that the court of special appeals erred in reversing the convictions.On appeal, Defendant argued that the trial court abused its discretion when it refused to allow Defendant to cross-examine one of the State's witnesses about out-of-court statements allegedly made by one of his co-defendants and by allowing a lay witness to testify that a cellphone user such as himself has the ability to turn off location tracking associated with the user's Google accounts. The court of special appeals agreed and ordered a new trial. The Court of Appeals reversed, holding (1) the trial court did not abuse its discretion by limiting the proposed cross-examination; and (2) a user's ability to adjust the location tracking feature of a smartphone is within the understanding of the average lay person, and therefore, a witness whose testimony referred to that ability was not required to qualify as an expert. View "State v. Galicia" on Justia Law

by
The Court of Appeals reversed the judgment of the court of special appeals reversing Defendant's conviction for murder and related charges on the grounds that the trial court erred in admitting certain expert testimony, holding that the trial court did not abuse its discretion in admitting the expert testimony.At issue was the trial court's admission of expert testimony concerning the reverse projection photogrammetry analysis performed by the Federal Bureau of Investigation and the height estimate of the suspect resulting from that analysis. In reversing Defendant's conviction, the court of special appeals concluded that the height measurement was unreliable and therefore inadmissible under Rochkind v. Stevenson, 471 Md. 1 (2020), and Maryland Rule 5-702. The Court of Appeals reversed, holding that the trial court did not abuse its broad discretion in admitting the expert testimony in question. View "State v. Matthews" on Justia Law

by
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

by
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

by
The Court of Appeals affirmed the judgment of the court of special appeals, which affirmed Defendants' convictions of possessing a firearm, holding that the State provided sufficient evidence to establish that Defendants knew they were prohibited from possessing a firearm.Defendants Mashour Howling and Funiba Abangnelah each possessed a firearm at the time of arrest despite being disqualified to do so. In separate jury trials, both Defendants unsuccessfully requested that the respective circuit courts give a jury instruction incorporating the reasoning of Rehaif v. United States, 139 S. Ct. 2191 (2019), where the United States Supreme Court held that the federal statute required proof of knowledge of possession of a firearm and proof of knowledge of the defendant's status as a person prohibited from possessing a firearm. After Defendants were convicted the court of special appeals affirmed. The Court of Appeals affirmed, holding that the the circuit court did not abuse its discretion in declining to give Defendants' requested jury instructions. View "Howling v. State" on Justia Law

by
The Court of Appeals held that, under Maryland law, an individual cannot be convicted of robbery by means of threatening force against property or threatening to accuse the victim of having committed sodomy.Defendant pleaded guilty to possession of a firearm and ammunition by a convicted felon. The federal district court sentenced Defendant to a term at the top of the U.S. Sentencing Guidelines range after determining that he possessed the firearm after sustaining a felony conviction for a crime of violence, namely his 2007 Maryland conviction for robbery. The court then certified a question concerning Maryland robbery to the Court of Appeals. The Court of Appeals answered the question in the negative, holding that, under Maryland law, an individual cannot be convicted of robbery by means of threatening force against property or threatening to accuse the victim of having committed sodomy. View "Dickson v. United States" on Justia Law

by
The Court of Appeals affirmed Defendant's conviction of second-degree murder and possession of a firearm, holding that Defendant's contentions on appeal were unavailing.After a trial, the jury found Defendant guilty of second-degree murder and possession of a regulated firearm while under the age of twenty-one and not guilty of first-degree assault and use of a firearm in the commission of a crime of violence. On appeal, Defendant argued, among other things, that the guilty verdict as to second-degree murder and the not-guilty verdicts as to first-degree assault and use of a firearm in the commission of a crime of violence were inconsistent. The Court of Appeals affirmed, holding (1) the verdicts were not legally inconsistent; (2) the circuit court did not abuse its discretion in denying Defendant's motion for a new trial based on the jury having allegedly returned inconsistent verdicts; and (3) the evidence was sufficient to support the convictions. View "Williams v. State" on Justia Law

by
The Court of Appeals affirmed the decision of the court of special appeals affirming the judgment of the circuit court convicting Defendant of driving under the influence of alcohol per se and driving while impaired by alcohol, holding that the record supported a finding that police officers complied with the twenty-minute observation period set forth in COMAR 10.35.02.08G.Prior to trial, Defendant filed a motion in limine to exclude the results of a breath test on the ground that the twenty-minute observation period set forth in the COMAR regulation had not been complied with. The circuit court denied the motion. After he was convicted, Defendant appealed, arguing that the circuit court erred in admitting the results of the breath test. The court of special appeals affirmed. The Court of Appeals affirmed, holding (1) the alleged compliance or noncompliance with the twenty-minute observation period goes to the weight to be given to breath test results, not the admissibility; and (2) the circuit court made findings on the record that the officers complied with the twenty-minute observation period set forth in the COMAR regulation. View "Dejarnette v. State" on Justia Law

by
The Court of Appeals affirmed the decision of the court of special appeals finding that Petitioner waived his objections to the trial court's denial of his proposed voir dire questions, holding that Petitioner failed to preserve his claims based on Kazadi v. State, 223 A.3d 554 (2020).In Kazadi, the Court of Appeals held that, upon request, a court is required to ask potential jurors voir dire questions directed at a defendant's fundamental rights related to the burden of proof, the presumption of innocence, and the right not to testify and held that this ruling applied retroactively to cases pending on appeal so long as the relevant question was preserved for appellate review. In the instant case, which was pending when Kazadi was decided and in which the trial court declined Defendant's request to ask Kazadi voir dire questions, was whether Petitioner's claim based on the trial court's failure to ask questions required by Kazadi was properly reserved for appellate review. The Court of Appeals affirmed, holding that Petitioner's claims were not preserved for appellate review under Md. Rule 4-323(c). View "Lopez-Villa v. State" on Justia Law

by
The Court of Appeals held that a defendant's right to a unanimous jury verdict is violated when the State presents evidence of multiple incidents at trial to prove a single charged count in the absence of an election between the incidents or a special jury instruction.The court of special appeals affirmed the circuit court's judgment convicting Defendant of first-degree burglary, first-degree assault, and other crimes. At issue on appeal was whether the circuit court abused its discretion in failing to provide a supplemental instruction after the State argued in closing arguments that "the jury could rely on either of two distinct incidents to find [Defendant] guilty of the crimes that were charged as single counts." The court of special appeals determined that Defendant's encounters with the victim were part of a single continuous incident, and therefore, that a special unanimity instruction or election between incidents was not required. The Court of Appeals reversed, holding that Defendant's convictions did not meet this Court's constitutional standards for unanimity and must be vacated. View "Johnson v. State" on Justia Law