Justia Criminal Law Opinion Summaries

After a jury trial in 2000, Appellant was convicted of first- and second-degree murder, first-degree assault, and the unlawful taking of a motor vehicle. In 2013, Appellant filed a Public Information Act request requesting the results of any testing performed on the hair fibers from the black t-shirt he was wearing when he was arrested in 1997. The State admitted that the black t-shirt was destroyed in 2003, after the appellate process was exhausted. In 2014, Appellant filed a petition in the circuit court requesting a hearing under Mc. Code Ann. Crim. Proc. 8-201(j)(3)(i) to determine whether the State’s failure to produce the requested evidence was the result of intentional and willful destruction. The circuit court denied the petition, concluding that the evidence did not constitute “scientific identification evidence” under the statute, and therefore, the State did not have a duty to preserve it. The Court of Appeals affirmed, holding that the circuit court did not err in denying appellant’s petition because the black t-shirt did not satisfy the statutory definition of “scientific identification evidence,” and therefore, the State did not have a duty to preserve it. View "Wallace v. State" on Justia Law

These two cases concerned administrative hearings in cases where an individual suspected to have been driving (or attempting to drive) while impaired refuses to take a breath test for blood alcohol concentration. In each case, an administrative law judge (ALJ) overturned the suspension on the ground that it was not established by a preponderance of the evidence that the individual had actually been driving (or attempting to drive) at the time the individual was detained by a law enforcement officer. The Supreme Court vacated the judgment in one case and reversed the judgment in the other case, holding (1) in a test refusal case, there is no requirement that the Motor Vehicle Administration prove that the individual was actually driving (or attempting to drive) while under the influence of alcohol; rather, the relevant question is whether the officer had reasonable grounds to believe that the individual was driving (or attempting to drive) while under the influence of alcohol; (2) in one case, the ALJ found that the officer had reasonable grounds, and thus the suspension should have been upheld; and (3) in the other case, the ALJ’s finding on the issue of reasonable grounds was ambiguous, and the case is remanded for clarification. View "Motor Vehicle Administration v. Krafft" on Justia Law

After a jury trial, Defendant was convicted of four counts of first-degree murder, among other crimes. Defendant was sentenced to four consecutive sentences of life imprisonment without the possibility of parole, one for each conviction of first-degree murder. The Court of Special Appeals affirmed the murder convictions and sentences, holding that CR 2-304 does not give a defendant the right to have a jury determine whether the defendant should be sentenced to life imprisonment with the possibility of parole or life imprisonment without the possibility of parole. The Court of Appeals affirmed, holding (1) under CR 2-304(a), where a defendant is convicted of first-degree murder and the State has given notice of an intent to seek life imprisonment without the possibility of parole, the trial court, not the jury, determines whether to sentence the defendant to life imprisonment or life imprisonment without the possibility of parole; and (2) both the United States Constitution and the Maryland Declaration of Rights permit a sentence of life imprisonment without the possibility of parole to be imposed in the same manner as every other sentence except the death penalty, which has been abolished in Maryland. View "Bellard v. State" on Justia Law

Petitioner pled guilty to theft in exchange for the State’s recommendation that she receive no executed jail time. The district court did not follow the State’s recommendation and instead imposed a sentence of thirty days’ incarceration. Petitioner filed a de novo appeal to the circuit court and entered a plea of not guilty. The State subsequently offered a new plea agreement whereby, in exchange for Petitioner’s guilty plea, the State would recommend Petitioner receive thirty days’ incarceration. Petitioner filed a motion to enforce the plea agreement in the circuit court, contending that the state violated the terms of the district court plea agreement by altering its sentencing recommendation. The circuit court denied the motion, concluding that on de novo appeal, the district court plea agreement was no longer enforceable. The Court of Appeals affirmed, holding that the district court plea agreement did not extend to the de novo circuit court proceeding. View "Hartman v. State" on Justia Law

After a jury trial, Defendant was convicted on seventeen various counts, resulting in a cumulative sentence of 390 years imprisonment. The Court of Special Appeals affirmed Defendant’s convictions but vacated his sentences, determining that Md. Code Ann., Crim. Law 3-315 prohibits multiple convictions and sentences per victim, regardless of the duration of the abuse or the type of sexual acts committed. The Court of Appeals affirmed, holding (1) the plain language of the statute prohibits a defendant from being convicted and sentenced for each type of prohibited sexual act as a separate unit of prosecution; and (2) the statute is ambiguous regarding whether a defendant may be convicted and sentenced for multiple uninterrupted ninety-day minimum intervals of a continuing course of conduct, and therefore, the rule of lenity applies to bar multiple punishments. View "State v. Bey" on Justia Law

At issue in this case was whether a law enforcement officer who detects an odor of marijuana emanating from a vehicle with multiple occupants has reasonable articulable suspicion that the vehicle’s occupants are armed and dangerous and thus may frisk the vehicle’s occupants for weapons. The circuit court denied Defendant’s motion to suppress in this case, concluding that the police officer that searched the vehicle in which Defendant was a passenger had reasonable articulable suspicion that Defendant was armed and dangerous. The Court of Special Appeals affirmed. The Court of Appeals reversed, holding (1) an odor of marijuana alone emanating from a vehicle with multiple occupants does not give rise to a reasonable articulable suspicion that the vehicle’s occupants are armed and dangerous and subject to frisk; and (2) at the time of the frisk in this case, there were insufficient circumstances giving rise to reasonable articulable suspicion that Defendant was armed and dangerous to justify the frisk. View "Norman v. State" on Justia Law

Defendant was charged with two counts of first-degree murder and related charges. Defendant filed a motion to suppress statements he made to police during an interrogation at the police department. The circuit court granted Defendant’s motion to suppress statements Defendant made to a police officer before the officer advised Defendant of his Miranda rights. The Court of Special Appeals reversed, concluding that the suppression court had incorrectly determined that, from the outset of the interrogation, Defendant was in custody for purposes of Miranda. The Court of Appeals reversed, holding that Defendant was in custody for purposes of Miranda for the entirety of the interrogation that preceded Miranda warnings, and therefore, the circuit court properly suppressed Defendant’s statements made to the police. View "Brown v. State" on Justia Law

After a jury trial, Petitioner was convicted of first-degree murder and sentenced to life imprisonment. The Court of Special Appeals affirmed. Petitioner appealed, inter alia, the denial of his motion to suppress the statements he made to police officers during his interrogation, arguing that they were obtained in violation of his Miranda right to counsel. The Court of Appeals affirmed, holding (1) the trial judge violated Maryland Rule 4-326(D)(2) by communicating an ex parte answer to a juror’s question without disclosing it to the defendant or any lawyer, but the error was harmless beyond a reasonable doubt; and (2) Petitioner did not invoke his Miranda right to counsel by demanding to see a lawyer from his holding cell before being interrogated, and therefore, the circuit court did not err in denying Petitioner’s motion to suppress the statements he made to detectives during his interrogation. View "Gupta v. State" on Justia Law

A family magistrate of the circuit court for Baltimore County found that Cody H. had committed the delinquent act of assault by punching a sixteen-year-old victim in the face and breaking his jaw. The magistrate judgment made a recommendation for a restitution award of $1,489 to the victim for medical expenses but did not award restitution for lost earnings. The State filed exceptions to the recommendation. A juvenile court judge sustained the State’s exception and imposed an additional restitution amount of $5,000 for loss of earnings. The Court of Appeals affirmed, holding that the loss of earnings restitution award in this case was proper under the restitution statute, Md. Code Ann., Crim. Proc. 11-603. View "In re Cody H." on Justia Law

Respondent was acquitted in a jury trial of first-degree murder premeditated murder, second-degree specific intent murder, and other charges. Thereafter, the State sought to prosecute Respondent for second-degree felony murder predicated on first-degree assault. Respondent interposed a plea of double jeopardy, which was denied. The Court of Special Appeals reversed, concluding that a subsequent trial for felony murder based upon first-degree assault was barred by the Double Jeopardy Clause. The Court of Appeals affirmed but on different grounds, holding that first-degree assault may not serve as a predicate for second-degree felony murder when that assault is not collateral to the lethal act. In so holding, the Court overruled Roary v. State, which was the foundation and predicate for the State’s charge for second-degree felony murder based on first-degree assault. View "State v. Jones" on Justia Law