Justia Criminal Law Opinion Summaries

Evidence of a medical diagnosis is not required to establish that a victim is mentally defective as defined by Md. Crim. Law 3-301(b).Petitioner challenged his convictions of second-degree rape and third-degree sexual offense, arguing, in part, that the evidence was insufficient to support his convictions where the convictions were contingent on the victim’s status as a mentally defective individual and the State failed to establish that she had been diagnosed with either mental retardation or a mental disorder. The Supreme Court affirmed, holding (1) the jury was able reasonably to infer that the victim suffered from a mental defect that rendered her incapable of consenting to sexual intercourse and sexual contact under Md. Crim. Law 3-304(a)(2) and 3-307(a)(2); (2) the prosecutor erred by informing the jury during closing argument that Petitioner had admitted to taking advantage of the victim’s mental diminished capacity in an interview that was never introduced at trial, but the error did not influence the verdict; and (3) the trial court’s exclusion of the victim’s employment records was legally correct. View "Fuentes v. State" on Justia Law

Scott was convicted of attempted robbery with a dangerous weapon, use of a handgun in the commission of a crime of violence, and conspiracy to commit robbery with a dangerous weapon. Md. Code, Crim. Law 14-101(d) provides for an enhanced sentence for a defendant who was convicted of a third crime of violence. The prosecutor offered cited Scott's first-degree assault conviction in Maryland and an aggravated assault conviction in the District of Columbia. The court imposed an enhanced sentence of 25 years for attempted robbery; a consecutive sentence of 10 years for use of a handgun; and a consecutive sentence of 10 years for conspiracy. The Court of Special Appeals vacated the 25-year sentence, concluding that the evidence was insufficient to establish that the D.C. conviction constituted a crime of violence. On remand, Scott argued that the imposition of an enhanced sentence would constitute double jeopardy. The court reimposed the enhanced sentence, with the other sentences to be served consecutively. The Maryland Court of Appeals affirmed. An appellate court's determination that the evidence was insufficient to establish a requisite prior conviction as a basis for an enhanced sentence does not preclude a trial court from determining at resentencing that the prior conviction satisfies the requirement for an enhanced sentence. Where an appellate court vacates a sentence and remands without vacating a consecutive sentence, the trial court may not make the new sentence concurrent with the non-vacated consecutive sentence. View "Scott v. State" on Justia Law

The Court of Special Appeals did not err in concluding that Defendant’s sentence was imposed in violation of Maryland Rule 4-243(c) because, pursuant to a plea agreement, the State did not receive what it bargained for when the judge imposed a sentence below the terms of the plea agreement. Defendant pleaded guilty to theft scheme greater than $10,000 but less than $100,000. The plea agreement provided that Defendant would be found guilty of a crime and serve jail time, but, instead, the sentence imposed did not include a finding of guilt or incarceration. The Court of Special Appeals reversed, concluding that the sentence was illegal because it was below the floor of the terms. The Court of Appeals affirmed, holding that the Court of Special Appeals did not err in holding that Defendant’s sentence was imposed in violation of Rule 4-243(c). View "Smith v. State" on Justia Law

Appellant, who was convicted of four counts of first-degree murder and sentenced to four consecutive terms of life without the possibility of parole, appealed the circuit court’s denial of his pro se petition for DNA testing of scientific evidence, arguing that in reaching its conclusion, the circuit court applied the incorrect standard of law. The Court of Appeals affirmed, holding that Appellant was not entitled to testing under Md. Code Ann. Crim. Proc. 8-201, as (1) the hearing court erred in applying the incorrect standard of law when denying the petition; but (2) analyzed under the correct standard of law, the arguments presented by Appellant in his petition utterly failed to satisfy the requirements of section 8-201. View "Beaman v. State" on Justia Law

Appellant was convicted of attempted first-degree rape, third-degree sexual offense, and second-degree sexual offense. Appellant was sentenced to life imprisonment for the rape offense. Appellant later filed a petition for post-conviction DNA testing, asserting that there was a reasonable probability that DNA testing of the requested items had the scientific potential to produce exculpatory evidence relevant to his claim of wrongful conviction. The post-conviction court denied Appellant’s petition for DNA testing after conducting a hearing. The Court of Appeals reversed, holding (1) the hearing judge erred in applying a more stringent standard that would require Appellant to show that the DNA testing he sought would exonerate him; and (2) Appellant established that DNA testing was warranted in light of the proper standard. View "Edwards v. State" on Justia Law

Darrell Ellis filed criminal charges against Andrew Baker for an incident involving a shoot-out. Baker then filed criminal charges against Ellis for an alleged assault that occurred two days later. At Baker’s trial for allegedy assaulting Ellis, it was discovered that Ellis’ defense counsel for the charges related to the second incident was related to the assistant state’s attorney who was prosecuting Baker for the charges stemming from the first incident. Upon learning this information, the trial court declared a mistrial over Baker’s objection. Baker filed a motion to dismiss his indictments on grounds of double jeopardy. The trial court denied the motion. The Court of Special Appeals reversed and ordered the indictments be dismissed. The Court of Appeals affirmed, holding that retrial of Baker was barred by double jeopardy principles because the trial court’s declaration of a mistrial over Baker’s objection was not supported by manifest necessity. View "State v. Baker" on Justia Law

After a jury trial, Petitioner was acquitted of murder in the first degree but convicted of murder in the second degree. The circuit court granted Petitioner’s motion for a new trial. After the State rested its case during the second trial, the trial judge declared a mistrial and discharged the jury. The case was rescheduled. Petitioner then filed a motion to dismiss the indictment on grounds of double jeopardy. After hearing arguments, the judge struck his previous grant of a mistrial and granted Petitioner’s previously-filed motion for judgment of acquittal, thus dismissing the second-degree murder charge against Petitioner based on insufficiency of the evidence. The State subsequently reindicted Petitioner for second-degree murder. Upon Petitioner’s motion, the trial judge dismissed the indictment. The Court of Appeals reversed, concluding that principles of double jeopardy did not bar Petitioner’s retrial because the trial court could not acquit Petitioner after declaring a mistrial and discharging the jury. The Court of Appeals affirmed, holding that the trial judge acted without authority in acquitting Petitioner weeks after he had declared a mistrial and discharged the jury. View "Johnson v. State" on Justia Law

In 1993, Respondent was convicted of two counts of felony murder and other crimes. Respondent was sentenced to life without parole for the murders. Twenty-one years later, a trial witness alleged that he “lied” during Respondent’s trial when he identified Respondent as the individual who shot the victims. Thereafter, Respondent filed a pro se petition for writ of actual innocence under Md. Code Ann. Crim. Proc. 8-301, alleging that the recantation constituted “newly discovered evidence.” The circuit court denied the petition. The Court of Special Appeals reversed. The Court of Appeals vacated the judgment of the Court of Special Appeals and remanded the case to the circuit court for further proceedings, holding (1) a petition that fails to include an averment of innocence but otherwise complies with the pleading requirements contained in Maryland Rule 4-332(d) may be amended if the circuit court determines that allowing an amendment would do substantial justice; and (2) Petitioner alleged sufficient “newly discovered evidence” that could create a “substantial of significant possibility” that his original trial may have been different and was therefore entitled to a hearing under Md. Code Ann. Crim. Proc. 8-301(e)(1). View "State v. Ebb" on Justia Law

Petitioner, a Colorado resident, entered Maryland pursuant to a summons to testify at a murder trial. Petitioner was subsequently arrested in Maryland, and the State charged him with crimes related to the murder. A jury found Petitioner guilty of first-degree murder and conspiracy to commit first-degree murder. Petitioner did not allege, either pretrial or during trial, that his arrest violated the Maryland Uniform Act to Secure the Attendance of Witnesses from Without State in Criminal Proceedings. For the first time on appeal, Petitioner argued that the State’s prosecution of him violated Md. Code Ann. Cts. & Jud. Proc. (CJ) 9-304(a), and therefore, the circuit court improperly exercised personal jurisdiction over him. The Court of Special Appeals affirmed, concluding that petitioner’s challenge to the exercise of personal jurisdiction was waived. The Court of Appeals affirmed, holding that Petitioner waived the issue of a violation of CJ 9-304(a) by failing to raise it pretrial as required by Maryland Rule 4-252. View "Lewis v. State" on Justia Law

After a jury trial, Petitioner was convicted of armed robbery, robbery, and related offenses. The trial court sentenced Petitioner to twenty years’ imprisonment for armed robbery and merged the remaining offenses. Petitioner appealed, arguing that the trial judge abused his discretion in conducting the voir dire of the prospective jurors. The Court of Special Appeals affirmed the judgment of conviction. The Court of Appeals affirmed, holding that the voir dire process in this case reasonably assured that Petitioner was tried before an impartial jury. The Court, however, used the opportunity of this case to encourage trial judges to adopt certain best practices to help achieve the constitutionally requirement of an impartial jury. View "Collins v. State" on Justia Law