Justia Criminal Law Opinion Summaries

After a jury trial, Defendant was convicted of multiple sexual offenses relating to an attack and rape of a woman. The Court of Appeals affirmed, holding (1) the evidence was sufficient to sustain Defendant's conviction; (2) Defendant's constitutional confrontation rights were not violated when the State's expert witness presented the results of forensic tests as the basis for her conclusion that Defendant was the source of the DNA found on vaginal swabs taken from the rape victim; (3) Defendant's rights to discovery were not violated by the trial court's refusal to order the State to conduct a search for coincidental matches in the FBI's Combined DNA Index System; and (4) the trial court did not err in refusing to include Defendant's proposed jury instruction on the definition of "reasonable degree of scientific certainty." View "Derr v. State" on Justia Law

After a trial trial, Petitioner was convicted of second-degree murder. During the trial, a DNA testified that she could not exclude Petitioner as being the source of DNA recovered from the truck in which the victim was shot. In closing argument, however, the prosecutor told jurors that Petitioner's DNA was present in the victim's truck and that the DNA analyst's statistical analysis supported the State's theory of the case. Petitioner objected to the prosecutor's argument as misstating the DNA evidence and unsuccessfully asked for a mistrial. The court of special appeals affirmed the conviction. The Court of Appeals reversed, holding that the trial court abused its discretion in denying Petitioner's motion for a mistrial after the State mischaracterized the statistical significance of the DNA evidence in rebuttal closing argument. Remanded for a new trial. View "Whack v. State" on Justia Law

After a jury trial in 1986, Petitioner was convicted of attempted first degree rape and related charges. Petitioner subsequently pled guilty to two counts of first degree rape, one count of second degree rape, and related charges. In 2005, Petitioner filed a post-conviction petition covering both cases, alleging, among other things, ineffective assistance of counsel. In 2008, the State argued that Petitioner's petition should be denied on the ground of laches. The circuit court held that laches was available to the State as a defense and denied the petition on that basis. The court of appeals agreed that laches was applicable in post-conviction proceedings but found the record was insufficiently developed for a finding that laches barred the petition in this case. The Court of Appeals vacated the judgment of the intermediate appellate court and remanded with directions to vacate the circuit court's decision, holding that laches does not bar an individual from pursuing post-conviction remedies. View "Lopez v. State" on Justia Law

The district court convicted Petitioner of second-degree assault and reckless endangerment. Petitioner exercised his right to have his case tried do novo in the circuit court. After a jury-waived trial, the circuit court acquitted Petitioner of reckless endangerment and convicted him of second-degree assault. Petitioner filed a petition for certiorari in the Court of Appeals, which the Court issued. The Court then affirmed Petitioner's conviction, holding (1) Petitioner's right to a de novo appeal of his district court conviction was not violated when his testimony from the district court trial was admitted into evidence in his circuit court trial; and (2) Petitioner's Fifth Amendment privilege against self-incrimination was not violated when his testimony from the district court trial was admitted into evidence in his circuit court trial. View "Oku v. State" on Justia Law

After Petitioner pled and was found not criminally responsible for the murder of two people by reason of a mental disorder, Petitioner was committed to a state-run medical facility run by the Department of Health and Mental Hygiene (DHMH), where he spent seven years as a patient. Thereafter, Petitioner applied for conditional release. An ALJ recommended that Petitioner be released subject to specified conditions. On appeal, the circuit court judge ruled that the ALJ's finding that Petitioner would not be a danger to himself or others was not supported by substantial evidence and ordered Petitioner's continued confinement. The court of special appeals affirmed. The Supreme Court reversed, holding that the lower courts erred in considering only whether Petitioner posed any risk to himself or the community without taking into account the conditions of release. Remanded. View "Hawkes v. State" on Justia Law

Following a bench trial, Petitioner was convicted of sexual abuse of a minor and attempted sexual abuse of a minor. The convictions arose from messages thirty-eight-year-old Petitioner wrote to an eight-year-old student professing his love for her. The court of special appeals affirmed the convictions. The Court of Appeals upheld Petitioner's convictions, holding (1) the lower courts did not err in holding that Petitioner did not enjoy a reasonable expectation of privacy in his work desk for purposes of a Fourth Amendment challenge to a search of the desk; (2) sexual abuse of a minor can be committed by the exchange of non-sexually explicit letters and drawings; and (3) a rational trier of fact could have found the essential elements of child sexual abuse beyond a reasonable doubt. View "Walker v. State" on Justia Law

Defendants were tried jointly and convicted of numerous crimes arising from a shooting in Baltimore that left one man dead and two other individuals wounded. The court of special appeals reversed the judgments against both men. Defendants were retried jointly before a jury and were again convicted. The court of special appeals affirmed, for the most part, the judgments of conviction of both Defendants. Defendants appealed, contending, among other things, that where an internal affairs investigator for the police found "facts sustained" against officers, the trial court erred (1) in refusing to permit the defense to inspect internal investigation division files concerning misconduct by certain law enforcement officers, and (2) at trial, in refusing to allow the defense to cross-examine the officers about the misconduct. The Supreme Court reversed with instructions to vacate the judgments of conviction and remand the case for retrial, holding that the denial of access to potentially significant impeachment evidence and the subsequent denial of an opportunity to demonstrate a reasonable actual basis for cross-examination was not harmless beyond a reasonable doubt. View "Fields v. State" on Justia Law

After a jury trial, Petitioner, who had a prior non-violent felony conviction, was convicted of wearing and carrying a handgun and two counts of possession of a regulated firearm by a person with a prior conviction. The court of special appeals vacated as duplicitous Petitioner's conviction and sentence for one count of possession of a regulated firearm by a person previously convicted. The Supreme Court (1) vacated Petitioner's sentence for possession of a regulated firearm, holding that Petitioner was wrongful subjected to an enhanced penalty under Md. Code Ann. art. 27, 449(e), which requires that a predicate prior conviction be for a crime that is both violent and felonious; and (2) held that the rule of lenity required that Petitioner be sentenced in accordance with Md. Code Ann. Crim. Law 5-622(c) rather than section 449(e) because both penalty provisions proscribe the same conduct, but section 5-622(c) mandates a lesser penalty, and the legislature did not clearly express how the two statutes were intended to interface. Remanded for resentencing. View "Alston v. State" on Justia Law

After a re-trial, a jury found Defendant guilty of first degree murder, second degree murder, and related offenses. At issue on appeal was whether pre-trial statements made by and on behalf of Defendant on the morning of the commencement of his re-trial should have been construed by the trial court as requests to discharge his counsel under Maryland Rule 4-215(e) or merely as a request for a continuance. Defendant claimed the circuit court failed to comply with Rule 4-215(e) and violated his constitutional right to counsel when Defendant was denied permission to discharge his counsel after he made several purported requests to do so. The court of special appeals reversed. The Court of Appeals reversed, holding (1) even assuming that the statements made to the trial court were sufficient collectively to engage a Rule 4-215(e) inquiry into the putative merits of Defendant's purported request to discharge his counsel, the conduct of the judges who considered Defendant's request as such complied with the requirements of Rule 4-215(e); and (2) the trial court did not violate Defendant's constitutional right to counsel of choice by denying his request for a continuance. Remanded with directions to affirm the judgment of the circuit court. View "State v. Taylor" on Justia Law

The two consolidated criminal cases before the Court of Appeals here involved Jeffrey Valonis, who was convicted of robbery and related criminal charges in a bench trial, and Anthony Tyler, who was convicted of burglary and malicious destruction of property in a bench trial. At issue before the court was whether the amendment to Maryland Rule 4-245(b), which added the language "the court determines and announces on the record" and requires a trial judge to make an explicit finding of jury trial waiver on the record is subject to strict compliance and whether the failure to make such a factual determination is reversible error. The Court remanded the cases for a new trial, holding that in these two cases, the trial judges committed reversible error in failing to comply with the determine and announce requirement of Rule 4-246(b) and thereby failed to demonstrate a valid waiver of Defendants' right to a trial by jury. View "Valonis v. State" on Justia Law