Justia Criminal Law Opinion Summaries

In this case considering whether unprovoked flight in a high-crime area should no longer be considered a factor that gives rise to rebate articulable suspicion for a Terry stop, the Court of Appeals held that, under the totality of the circumstances, Defendant's rights under either the Fourth Amendment or Article 26 of the Maryland Declaration of Rights were not violated.Defendant, who was standing in an high-crime area in Baltimore City, fled when he saw an unmarked vehicle. Ultimately, detectives stopped Defendant and found a gun in his waistband. Defendant filed a motion to suppress, arguing that the detectives lacked reasonable suspicion to stop him based solely on his unprovoked flight in a high-crime area. The Supreme Court affirmed the denial of the motion, holding that, under under the totality of the circumstances analysis, a court may consider whether unprovoked flight is an indication of criminal activity that, together with evidence of a high-crime area and any other relevant factors, establishes reasonable suspicion for a stop, or whether unprovoked flight, under the circumstances of the case, is a factor consistent with innocence that adds little or nothing to the reasonable suspicion analysis. View "Washington v. State" on Justia Law

The Court of Appeals affirmed the judgment of the court of special appeals reversing the decision of the post-conviction court determining that Appellant's trial counsel provided ineffective assistance by failing to object to certain incomplete or missing jury instructions, holding that defense counsel's failure to object to a "CSI effect" voir dire question did not render her performance constitutionally deficient.In 2007, Appellant was convicted by a jury of murder. In 2010 and 2011, the Court of Appeals held in three cases that a CSI effect message from the bench constituted reversible error. In 2014, Appellant filed a pro se petition for post-conviction relief arguing that he received ineffective assistance of counsel based on his counsel's failure to object to the trial court's CSI effect voir dire question. In 2020, the post-conviction court granted the petition for post-conviction relief and ordered a new trial. The court of special appeals reversed. The Court of Appeals affirmed, holding that under the professional norms that existed at the time of Appellant's trial, defense counsel's failure to object to a CSI-effect voir dire question did not render her performance constitutionally deficient. View "McGhee v. State" on Justia Law

The Court of Appeals vacated the judgment of the court of special appeals concluding that Appellant had waived his right to appeal the denial of his motion to suppress, holding that Appellant did not waive his right to appeal the suppression ruling.After he had been convicted of a crime of violence Appellant was indicted on charges of possessing a regulated firearm. Appellant filed a motion to suppress the gun and the loaded magazine recovered by law enforcement officers while conducting a warrantless search of his hotel room. Thereafter, the State filed a superseding indictment under a new case number to add additional charges. Appellant subsequently renewed his motion to suppress in the new case. The trial court denied the motion, and Appellant was convicted of first-degree assault and other crimes. The court of appeals affirmed, ruling that Appellant waived his challenge to the denial o this motion to suppress. The Court of Appeals remanded the case for further consideration, holding that defense counsel did not waive Appellant's right to appellate review of the denial of his motion to suppress. View "Huggins v. State" on Justia Law

The Court of Appeals affirmed the judgment of the court of special appeals affirming the decision of the circuit court denying Defendant's motion to suppress the fruits of the warrantless search of his backpack and the warranted search of his cell phone, holding that Defendant was not entitled to relief on appeal.After a school resource officer broke up a fight in which Defendant was involved, Defendant's backpack dropped to the ground. When the officer picked up the backpack Defendant ran from the scene. The officer subsequently searched the backpack and discovered a stolen firearm and three cell phones. The officers obtained a warrant to search one cell phone. Thereafter, Defendant was charged with robbery and other offenses. After the trial court denied Defendant's suppression motion as to both searches Defendant pleaded guilty to conspiracy to commit robbery and wearing, carrying, and transporting a handgun. The court of special appeals affirmed. The Supreme Court affirmed, holding (1) because Defendant abandoned his backpack the warrantless search of his backpack was constitutionally permissible; and (2) the warrant authorizing the search of the cell phone did not comply with the particularity requirement of the Fourth Amendment, but the good faith exception to the exclusionary rule applied to the fruits of the cell phone search. View "Richardson v. State" on Justia Law

The Court of Appeals affirmed the judgment of the court of special appeals ruling that it was error to admit a video recording in the underlying criminal trial but the error was harmless beyond a reasonable doubt, holding that the admission of the challenged video was harmless beyond a reasonable doubt.After a jury trial, Defendant was convicted of two counts of second-degree sexual offense and one count of sexual abuse of a minor by a household or family member. On appeal, Defendant argued that the trial court erred by admitting a video recording of a conversation the victim had with her biological grandmother repeating allegations of abuse. The court of appeals concluded that the admission of the video recording was error but that the error was harmless. The Court of Appeals affirmed, holding that, beyond a reasonable doubt, the error in no way influenced the jury's verdict. View "Gross v. State" on Justia Law

The Court of Appeals vacated Defendant's convictions for second-degree assault and second-degree child abuse by a custodian, holding that Defendant, an Afrian American man, was prejudiced by the fact that the Sheriff's deputies who served as courtroom bailiffs during his trial wore thin blue line face masks, as required by the Sheriff.On appeal, Defendant argued that the bailiffs' display of the thin blue line flag on their face masks violated his Sixth Amendment right to a fair trial. The court of special appeals affirmed the convictions, concluding that the display of the thin blue line flag did not violate Defendant's right to a fair trial. The Court of Appeals vacated Defendant's convictions, holding that the bailiffs' display of the thin blue line flag and the pro-law enforcement message that it conveyed was inherently prejudicial to Defendant's constitutional right to a fair trial. View "Smith v. State" on Justia Law

The Court of Appeals affirmed the decision of the court of special appeals affirming the judgment of the circuit court denying Petitioner's motion to correct an illegal sentence, holding that Petitioner's claim did not fall within the category of claims cognizable under Maryland Rule 4-345(a).In 2002, Petitioner pled guilty to committing two murders when he was seventeen years old and was sentenced to two consecutive life sentences. Citing the Supreme Court's decision in Miller v. Alabama, 567 U.S. 460 (2012), and its progeny, Petitioner asserted that his sentence did not include a "meaningful opportunity to obtain release based on demonstrated maturity and rehabilitation" because Maryland parole laws do not provide a right to State-furnished counsel to assist an inmate during the parole process. The lower courts rejected Petitioner's arguments. The Court of Appeals affirmed, holding that Petitioner's argument that he has a right to State-furnished counsel at a future parole hearing was not cognizable as grounds for a motion to correct an illegal sentence. View "Farmer v. State" on Justia Law

The Court of Appeals affirmed the decision of the court of special appeals affirming the judgment of the circuit court denying Appellant's motion to correct an illegal sentence, holding that Appellant's sentencing proceeding complied with the constitutional protections recognized in recent decisions of the Supreme Court.In 2010, Petitioner was convicted of first-degree felony murder and other crimes for his involvement in a burglary at the age of sixteen that resulted in a murder. Petitioner was sentenced to life in prison with all but sixty years suspended for the murder conviction and will be eligible for parole at the time he is forty-two years old. In 2017, Petitioner filed a motion to correct an illegal sentence, arguing that his sentence violated the Eighth Amendment, as interpreted in recent decisions of this Court and the Supreme Court. The circuit court denied the motion, and the court of special appeals affirmed. The Supreme Court affirmed, holding that Petitioner's sentence did not amount to a de facto sentence of life without parole, and his sentence was not grossly disproportionate. View "Jedlicka v. State" on Justia Law

The Court of Appeals held that ambiguity in a sentencing court's remarks about a juvenile offender's post-offense conduct and character, when made before the Supreme Court issued its decisions governing the sentencing of a juvenile offender to life without the possibility of parole, requires that the offender receive a new sentencing hearing for purposes of the Eighth Amendment.Petitioner was seventeen years old when he committed a series of murders. In Maryland, Petitioner pled guilty to six counts of first-degree murder. The sentencing court sentenced him to the maximum sentence of six terms of life in prison without the possibility of parole. After the Supreme Court decided Miller v. Alabama, 567 U.S. 460 (2012), Petitioner filed a motion to correct an illegal sentence. The circuit court denied the motion. The Supreme Court remanded the case, holding that because opposing inferences could be drawn as to whether the sentencing judge determined that Petitioner was not "the rare juvenile offender whose crimes reflects irreparable corruption" for whom the Eighth Amendment allows a sentence of life without parole. View "Malvo v. State" on Justia Law

The Court of Appeals reversed the judgment of the court of special appeals reversing Defendant's sentence on the ground that the district court's failure to advise Defendant of the duration of his probation, as required by Maryland Rule 4-346(a), rendered the sentence illegal, holding that the violation of Rule 4-346(a) did not render the sentence illegal.In imposing Defendant's split sentence of twenty-five years, suspending five years, the court mentioned probation but failed to advise Defendant of the probation's duration. However, the court did include a five-year term and conditions of probation in a probation order signed by Defendant and his counsel before leaving the courtroom. The court of special appeals reversed and remanded to the circuit court to strike the five-year probation from the sentence. The Court of Appeals reversed, holding that the sentencing judge's error constituted clear error, but not one that rendered the sentence illegal. View "State v. Bustillo" on Justia Law