Justia Criminal Law Opinion Summaries

Petitioner was charged in two cases with second-degree burglary, theft, and malicious destruction of property. Petitioner moved to suppress all evidence obtained as the result of law enforcement's global positioning system (GPS) tracking of his vehicle. The motions were denied, and Petitioner was convicted of various charges arising out of the two cases. While Petitioner's appeal of the convictions was pending, the U.S. Supreme Court decided United States v. Jones, which held that GPS tracking of a vehicle constitutes a search under the Fourth Amendment. The court of special appeals affirmed the consolidated appeals. The Court of Appeals affirmed, holding that Petitioner was not entitled to the suppression of evidence where (1) before Jones, binding appellate precedent in Maryland authorized the GPS tracking of a vehicle on public roads; (2) law enforcement officers acted in objectively reasonable reliance on that authority when they conducted their GPS tracking of Petitioner's vehicle; and (3) the Davis v. United States good-faith exception to the exclusionary rule applied in this case. View "Kelly 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 the conviction. The Supreme Court affirmed, holding that trial court (1) complied with Md. Code Ann. Crim. Proc. 3-104(a) when it allowed Petitioner to withdraw his request for a competency evaluation and afterwards did not make a competency determination on the record, because Petitioner's withdrawal of his request for a competency evaluation, in addition to the slight evidence on the record to support a finding of incompetency, supported the circuit court's acknowledgment that the issue of competency was moot and the presumption that Petitioner's competency was not rebutted; and (2) properly denied Petitioner's request for an instruction on legally adequate provocation because the evidence presented did not generate such a defense. View "Wood v. State" on Justia Law

Petitioner was charged with murder and other related offenses. During defense counsel's opening statement, counsel referenced Petitioner's willingness to take a lie detector test during his interrogation by the police. The trial judge gave a curative instruction to the jury immediately following the improper reference. Two days further into the trial, the prosecutor filed a motion for a mistrial for reason of that improper remark. The trial judge granted the motion. Petitioner subsequently filed a motion to dismiss, arguing that retrial was prohibited under double jeopardy principles. The court of special appeals affirmed, concluding that the trial judge properly determined that manifest necessity existed for a mistrial, and therefore, double jeopardy principles did not prevent a retrial. The Court of Appeals affirmed, holding that the trial judge did not abuse his discretion in making a determination of manifest necessity to declare a mistrial where the judge considered his previously issued curative instruction and found it insufficient to cure the prejudice caused by defense counsel's improper remark. View "Simmons v. State" on Justia Law

After a jury trial, Petitioner was convicted of multiple counts of second degree murder and other crimes. The court of appeals affirmed, concluding that the trial court erred in prohibiting Petitioner's cross-examination of a State's witness regarding the witness' expectation of leniency in a separate pending case should he testify against Petitioner but that the error was harmless. The Court of Appeals reversed, holding (1) the trial court erred in limiting Petitioner's cross-examination of the witness with regard to his expectation of leniency; and (2) contrary to the conclusion of the intermediate appellate court, the effect of that error was not harmless to the result of the trial. View "Dionas v. State" on Justia Law

Petitioner was convicted of second degree assault and sentenced to ten years in prison and three months probation. After Petitioner was sentenced, he tore up a copy of his probation papers while seated next to the exit door in the courtroom. Subsequently, while walking down a hall outside the courtroom, Petitioner threatened in front of a law enforcement officer to harm a witness/victim. The trial court revoked Petitioner's probation, determining that, through his actions, Petitioner committed direct criminal contempt of court and violated Md. Code Ann. Crim. Law 9-303(a), the retaliation statute. The court of special appeals affirmed. The Court of Appeals affirmed in part and reversed in part, holding (1) section 9-303(a) does not require communicating a threat to a victim/witness or a belief that the threat may be communicated to the victim/witness, and in this case, Petitioner committed a threat within the meaning of the statute; and (2) the record did not support a finding that Petitioner was in direct contempt of court when he tore up his personal copy of the probation papers following his sentencing. Remanded. View "Hammonds v. State" on Justia Law

After a jury trial, Defendant was convicted of conspiracy to commit first degree burglary. The court of special appeals affirmed the conviction. At issue before the Court of Appeals was whether the trial court committed reversible error in giving an "anti-CSI effect" instruction to the jury after defense counsel remarked in opening statement that no scientific evidence existed linking Defendant to the crimes for which he was charged. The Court of Appeals reversed, holding (1) an "anti-CSI effect" instruction, limited only to curative administration, shall not be entertained without legal and empirical proof that a "CSI effect" exists, and is only triggered when a material misstatement of law occurs; and (2) the trial court erred in this case by giving the contested instruction. Remanded for a new trial. View "Robinson v. State" on Justia Law

After a jury trial in 1998, Appellant was convicted of murder and sentenced to death. In 2011, Appellant filed a second motion to correct an illegal sentence, claiming that his death sentence was unconstitutional and illegal under Article 16 of the Maryland Declaration of Rights, which provides that "sanguinary Laws ought to be avoided as far as is consistent with the safety of the State[.]" Appellant claimed that at the time the clause was adopted as Article 14 in 1776, a sanguinary law meant the death penalty for any crime, and therefore, Article 14 abrogated capital punishment for any offense that did not impact State security. The circuit court denied Appellant's motion. The Court of Appeals affirmed, holding (1) where death was the common law penalty for murder and the sanguinary laws clause applied only to legislative action, the death penalty was not abrogated by Article 14; and (2) if the sanguinary laws clause was retroactive, it was not intended to include death as a possible penalty for murder. View "Miles v. State" on Justia Law

After a jury trial, Petitioner was convicted of controlled substance and resisting arrest offenses. The court of special appeals affirmed, holding (1) the trial court did not violate Maryland Rule 4-215(e) by failing to respond to a letter Petitioner sent to the court prior to trial seeking to discharge his counsel; and (2) the evidence was sufficient to support Petitioner's conviction for resisting a lawful arrest. The Court of Appeals reversed in part and affirmed in part, holding (1) Petitioner's letter to the trial court was sufficient to trigger Rule 4-215(e), and the trial court's failure to inquire into the reasons behind Petitioner's request to discharge counsel was reversible error; and (2) the court of special appeals did not misinterpret Maryland's resisting arrest statute in finding that the evidence was sufficient to support Petitioner's conviction for resisting arrest. Remanded. View "Williams v. State" on Justia Law

Petitioner was charged with assault, reckless endangerment, firearms violations, and a drug-related offense. Petitioner sought to suppress detectives' observations during and after an investigatory stop of Petitioner on the ground that the stop violated the Fourth Amendment. The suppression court granted Petitioner's request, determining that the investigatory stop violated the Fourth Amendment because the detectives did not have a reasonable suspicion that Petitioner had committed a drug-related crime or a traffic infraction. The court of special appeals reversed. The Court of Appeals affirmed, holding that, although the suppression court correctly concluded that the series of acts the detectives observed were by themselves innocent, taken together, those acts supported the detectives' suspicion that Petitioner was engaged in criminal activity. View "Holt v. State" on Justia Law

Petitioner was convicted of second degree assault in two cases. Petitioner, who was incarcerated at a correctional facility, appealed both convictions but was not transported to court on the date he was scheduled to appear for his appeals. Based solely on secondhand information from an unidentified source indicating that Petitioner refused to be transported, the circuit court dismissed Petitioner's appeals. Petitioner subsequently filed a motion to reinstate his appeal, indicating that he had not refused to be transported to court. The trial judge denied the motion. Petitioner then filed a petition for a writ of certiorari, which the Court of Appeals granted. The Court of Appeals vacated the judgment of the circuit court, holding that the circuit court erred in dismissing Petitioner's motion to reinstate his appeal under the circumstances of this case. View "Mobuary v. State" on Justia Law