Justia Criminal Law Opinion Summaries

In two separate cases, Petitioner was convicted of second-degree murder and two counts of solicitation to obstruct justice, among other offenses. The cases were consolidated for appeal, and the court of special appeals affirmed. At issue before the Court of Appeals, among other things, was whether the trial court abused its discretion in disqualifying one of Petitioner’s defense counsel, who had a previous attorney-client relationship with a key state’s witness, where the witness refused to waive the conflict of interest and Petitioner’s counsel had arranged for co-counsel to cross-examine the witness. The Court of Appeals affirmed, holding (1) the trial court did not abuse its discretion in disqualifying Petitioner’s attorney, as Petitioner’s waiver of the conflict was not sufficient to cure the conflict; and (2) merger was precluded for convictions of the two counts of solicitation, where the relevant statutes contained parallel anti-merger provisions. View "Alexis v. State" on Justia Law

Petitioner was charged with certain traffic offenses in the district court. The district court acquitted Petitioner as to the charge of disobeying a lawful order or direction of a police officer but convicted Petitioner of four counts of fleeing and eluding police. Petitioner filed notice of a de novo appeal. Prior to trial, Petitioner filed a motion to dismiss the fleeing and eluding counts, arguing that, because he was acquitted of disobeying a lawful order, prosecution of the fleeing and eluding charges would violate the state and federal prohibitions against double jeopardy. The circuit court denied the motion. The Supreme Court affirmed, holding that prosecution of the fleeing and eluding charges did not violate the prohibitions against double jeopardy or the doctrine of collateral estoppel. View "Scriber v. State" on Justia Law

After a jury trial, Petitioner was found guilty of two counts of first-degree murder and related offenses. Petitioner appealed the denial of his motion to suppress the contents of a storage locker belonging to him, arguing that it was the tainted fruit of the consent he had given to police while he was unlawfully detained at the police station. The court of special appeals affirmed the conviction. The Court of Appeals affirmed, holding (1) the police obtained Petitioner’s consent to search his locker during their lawful detention of him; and (2) therefore, the suppression court correctly ruled that Petitioner was not entitled to suppression of the evidence found in the locker. View "Barnes v. State" on Justia Law

Defendant was charged with misuse of telephone facilities and harassment. Prior to the start of trial, Defendant’s public defender informed the court: “Your Honor, on behalf of [Defendant], I’d request a postponement. He indicates that he would like to hire private counsel in this matter.” The trial judge denied postponement, and, after a trial, Defendant was convicted as charged. Defendant appealed, arguing that reversal was required because the trial court denied his request to obtain private counsel without complying with the requirements of Md. R. Crim. P. 4-215(e). The court of appeals affirmed, concluding that Defendant did not express a “clear intent” to discharge or replace his attorney, and therefore, Rule 4-215(e) was not implicated. The Court of Appeals reversed, holding (1) when an ambiguous statement by a defendant or his or her counsel is made under Rule 4-215(e), the trial judge must engage in a Rule 4-215(e) colloquy with the defendant; and (2) in this case, the trial judge could have reasonably concluded from defense counsel’s statements that Defendant wanted to discharge his attorney and thus had a duty to engage in a Rule 4-215(e) colloquy with Defendant. View "Gambrill v. State" on Justia Law

The State charged Petitioner with various drug-related crimes. Petitioner’s co-defendant filed three proposed voir dire questions asking whether any prospective juror had ever been the victim of a crime or a member of a law enforcement agency. The circuit court declined to ask any of the proposed voir dire questions. The jury ultimately convicted Petitioner of drug-related crimes. The court of special appeals affirmed. The Court of Appeals reversed, holding (1) a trial court need not ask during voir dire whether any prospective juror has ever been the victim of a crime, but, on request, a trial court must ask whether any of the prospective jurors have strong feelings about the crime with which the defendant is charged; and (2) where all of the State’s witnesses are members of law enforcement agencies and/or where the basis for a conviction is reasonably likely to be the testimony of members of law enforcement agencies, on request, a trial court must ask during voir dire whether any of the prospective jurors have ever been a member of a law enforcement agency. View "Pearson v. State" on Justia Law

After a jury trial, Petitioner was convicted of second degree murder, two counts of attempted second degree murder, and related weapons offenses. The court of special appeals affirmed. During the trial, defense counsel informed the trial court that he had trouble communicating with Petitioner, mentioned that there was “something wrong” with Petitioner, and requested that Petitioner be evaluated. The Court of Appeals granted certiorari to answer the question of whether defense counsel triggered the competency statute, requiring the trial court to order a competency evaluation and make a competency determination. The Court of Appeals affirmed, holding that defense counsel did not trigger the trial judge’s duty to make a competency determination under the circumstances. View "Kennedy v. State" on Justia Law

After a jury trial, Petitioner was convicted of distribution of cocaine and conspiracy to distribute cocaine. The sentencing judge imposed a twenty-five-year mandatory enhanced sentence without the possibility of parole based on Petitioner’s prior drug convictions. Petitioner appealed, alleging that his sentence was illegal under Maryland Rule 4-345(a). The Court of Appeals affirmed, holding (1) Petitioner waived any challenge to the imposition of his sentence because he failed to object during the sentencing proceeding; and (2) even if the Court were to determine that the issue was preserved, the trial court did not err in imposing an enhanced sentence where the evidence was sufficient for the sentencing judge to conclude that Petitioner committed the qualifying predicate offenses beyond a reasonable doubt. View "Bryant v. State" on Justia Law

After a jury trial, Petitioner was found guilty of conspiracy to commit first degree burglary and sentenced to ten years’ incarceration. On appeal, Petitioner argued, among other things, that the trial court erred by offering, over objection, an “investigative or scientific techniques” jury instruction. The court of special appeals affirmed the conviction. At issue before the Court of Appeals was whether the trial court violated the standards set forth in Atkins v. State and Stabb v. State that an “anti-CSI effect” instruction, limited only to curative administration, shall not be entertained without proof that a “CSI effect” exists and is only triggered when a material misstatement of the law occurs. The Court of Appeals reversed, holding that the trial court in this case erred by giving the contested instruction, as the instruction was given preemptively and defense counsel did not misstate the law or the State’s burden. Remanded for a new trial. View "Robinson v. State" on Justia Law

After a jury trial, Petitioner was convicted of theft of property valued in excess of $100,000 and related offenses stemming from his unauthorized occupancy of a home for approximately seven months. Defendant appealed the sufficiency of the evidence supporting his convictions for theft, theft of property valued in excess of $100,000, and first-degree burglary. The Court of Appeals affirmed in part and reversed in part, holding (1) the evidence was sufficient to support a conviction for theft; (2) the evidence was insufficient to support a conviction for theft of property valued in excess of $100,000 but was sufficient to support a conviction for theft of property having a value of at least $10,000 but less than $100,000; and (3) the evidence was sufficient to support a conviction for first-degree burglary. View "Hobby v. State" on Justia Law

Petitioner was charged with various offenses, including reckless endangerment. Because the indictment did not set out the elements of the charged offense or the factual basis for that offense, Petitioner requested that the State provide him with a bill of particulars. Rather than answer each question Petitioner asked in his request, the State simply directed Petitioner to discovery. The trial court overruled Petitioner’s exceptions, finding that the State’s responses satisfied the statutory requirement that the State’s response “furnish the particulars sought.” A jury found Petitioner guilty of reckless endangerment. Petitioner appealed, arguing that the trial court abused its discretion by denying his exceptions to the State’s non-specific responses to the questions posed in his request for a bill of particulars. The court of special appeals affirmed. The Court of Appeals reversed, holding (1) the State’s responses to the questions posed in Petitioner’s demand for a bill of particulars were inadequate; and (2) therefore, the trial court abused its discretion when it overruled Petitioner’s exceptions to those responses. View "Dzikowski v. State" on Justia Law