Justia Criminal Law Opinion Summaries
Articles Posted in Maryland Court of Appeals
Davis v. State
The Court of Appeals reversed the judgment of the court of special appeals affirming Petitioner's convictions and the judgment of the circuit court denying Petitioner's motion to transfer jurisdiction to the juvenile court pursuant to Md. Code Crim. Proc. 4-202, holding that the circuit court did not properly consider Petitioner's amenability to treatment in a juvenile institution, program, or facility.Petitioner was charged with several crimes that he committed when he was sixteen that were beyond the jurisdiction of the juvenile court. After the circuit court denied Petitioner's motion to transfer jurisdiction to the juvenile court Petitioner entered a conditional guilty plea. The court of special appeals. The Court of Appeals reversed and remanded the matter for a new hearing on Petitioner's motion to transfer, holding that it was evident from the circuit court's remarks that it did not properly consider amenability. View "Davis v. State" on Justia Law
Madrid v. State
The Court of Appeals affirmed the judgment of the court of special appeals affirming Defendant's conviction of murder and attempted murder, holding that Defendant knowingly and voluntarily waived his rights under Miranda and that the circuit court correctly determined that a jury instruction on duress was unwarranted.Before trial, Defendant moved to suppress his confession to a law enforcement officer. The circuit court denied the motion, concluding that Miranda had been complied with and that Defendant's confession was voluntary. The court of special appeals affirmed. The Court of Appeals affirmed, holding (1) Defendant knowingly and voluntarily waived his rights under Miranda, his confession was voluntary, and his circumstances did not render his waiver of rights involuntary; and (2) the circuit court did not err in declining to give a jury instruction on duress because the instruction was unwarranted. View "Madrid v. State" on Justia Law
State v. Ablonczy
The Court of Appeals affirmed the judgment of the court of special appeals reversing Defendant's conviction for armed robbery, robbery and other crimes, holding that accepting a jury as ultimately empaneled does not waive any prior objection to the trial court's refusal to propound voir dire questions.Prior to the commencement of the jury trial in this case, defense counsel submitted several voir dire questions to be posed to the venire. When the trial court declined to pose a proposed question defense counsel objected, but the objection was overruled. At the conclusion of jury selection, the court asked whether either party objected to the jury as empaneled. Defense counsel responded, "no." After Defendant was convicted, he appealed, arguing that the trial court committed reversible error in failing to ask the proposed question. The court of special appeals reversed. The Supreme Court affirmed, holding (1) objections relating to a trial court's determination not to ask a proffered voir dire question are not waived by later acceptance, without qualification, of the jury as empaneled; and (2) Defendant did not waive his objection to the trial court's decision not to ask the proffered voir dire question at issue by accepting the jury as empaneled without repeating his prior objection. View "State v. Ablonczy" on Justia Law
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Criminal Law, Maryland Court of Appeals
Tengeres v. State
The Court of Appeals reversed the judgment of the circuit court denying Appellant's motion to reinstate her appeal and her motion to reconsider that denial, holding that the circuit court incorrectly applied the "good cause" standard when it denied Appellant's motion to reinstate her appeal.Appellant was convicted for failing to send her child to school. Appellant appealed, and the circuit court scheduled the case for a trial de novo. Thereafter, the COVID-19 pandemic required the circuit court to postpone several criminal cases on its docket, including Appellant's appeal for a trial de novo. During a status hearing which Defendant was unable to attend, the circuit court dismissed Appellant's appeal. The Court of Appeals reversed, holding that, under the undisputed facts in the record, the circuit court would abuse its discretion if it did not reinstate the appeal. View "Tengeres v. State" on Justia Law
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Criminal Law, Maryland Court of Appeals
Hunt v. State
The Court of Appeals held that, under the unique circumstance of the late Joseph Kopera's deception of Maryland's courts and defendants for decades in a number of criminal cases in which he testified as an expert in the field of firearms ballistics, due diligence did not require defense counsel to unearth Kopera's fraud prior to 2007.In 2007, an attorney working for the innocence project discovered that Kopera gave perjured testimony in hundreds of criminal trials concerning his credentials. Ronnie Hunt later filed a second amended petition for writ of actual innocence, arguing that had Kopera's fake credentials been known, it was reasonably probable that the outcome of his trial would have been different. The circuit court denied the petition on the ground that Kopera's false testimony concerning his credentials was not newly discovered evidence. The court of special appeals affirmed. The Court of Appeals reversed, holding (1) in this and all similarly situated cases tried prior to the discovery of Kopera's fraud, due diligence did not require defense counsel to unearth the charade prior to 2007; and (2) remand was required for the trial court to determine whether Hunt could establish a substantial possibility that, had Kopera's false testimony been known at the time of his trial, the result of Hunt's trial may have been different. View "Hunt v. State" on Justia Law
Posted in:
Criminal Law, Maryland Court of Appeals
Whittington v. State
The Court of Appeals affirmed the judgment of the court of special appeals affirming the circuit court's denial of Defendant's motion to suppress, holding that the court of special appeals did not err in holding that the placement and use of a GPS tracking device was legal.In investigating suspected drug distribution activities Harford County Narcotics Task Force applied for and received an "application for court order" to install a GPS tracking device on Defendant's vehicle. The Task Force detectives subsequently applied for a received a search warrant for Defendant's vehicle and suspected residence. After the search warranted was executed, Defendant was indicted on drug-related charges. Defendant filed a motion to suppress, arguing that the GPS tracking of his vehicle was unconstitutional. The circuit court held that the search warrant lacked probable cause but that the good faith exception to the exclusionary rule applied. Defendant then entered a conditional guilty plea. The court of appeals affirmed. The Court of Appeals affirmed, holding (1) the use of the GPS tracking device was legal because the GPS order satisfied the Fourth Amendment warrant requirement; (2) the issuing judge had substantial evidence for finding probable cause; and (3) the good faith exception to the Fourth Amendment exclusionary rule applied in this case. View "Whittington v. State" on Justia Law
Clark v. State
The Court of Appeals affirmed the judgment of the court of special appeals affirming Defendant's sentence that was imposed in connection with his convictions for illegal possession of an assault weapon and possession of a firearm by a person disqualified from possessing a firearm as a result of a prior felony drug conviction, holding that merger of the convictions was not required.In sentencing Defendant, the circuit court imposed the maximum sentence on each charge, to be served consecutively. At issue was whether Defendant's convictions for statutory offenses must be merged for purposes of sentencing under either the "required evidence test" or the "rule of lenity." The court of special appeals rejected Defendant's arguments that the two convictions should merge for purposes of sentencing and affirmed Defendant's sentence. The Supreme Court affirmed, holding that it was within the discretion of the circuit court to impose consecutive sentences for Defendant's two convictions. View "Clark v. State" on Justia Law
Posted in:
Criminal Law, Maryland Court of Appeals
Trott v. State
The Court of Appeals affirmed the judgment of the circuit court denying Defendant's motion to suppress, holding that, under the circumstances presented in this case, the police had reasonable suspicion to conduct a brief investigatory detention of Defendant, and the stop did not violate the parameters of the Fourth Amendment.In response to an anonymous 911 call that provided the location and license plate of a vehicle driven by a possibly intoxicated driver, the responding police officer located he vehicle in a parking lot, knocked on the window, and spoke to Defendant, who admitted to having had multiple drinks and that his driver's license was revoked. Defendant was arrested after he was unable to successfully complete a field sobriety test. On appeal, Defendant argued that the anonymous call could not support a finding of reasonable suspicion. The Supreme Court affirmed, holding that, under the totality of the circumstances, the stop at issue comported with the reasonable suspicion requirement of the Fourth Amendment. View "Trott v. State" on Justia Law
Taylor v. State
The Court of Appeals reversed Defendant's conviction for various charges related to a home invasion, holding that a the trial court erred by giving an anti-CSI effect instruction and that the error was not harmless.At trial, the judge gave an anti-CSI effect jury instruction, which advises the jury that the prosecution need not prove its case through scientific or forensic techniques featured in police procedural television shows. Defendant challenged the instruction on appeal, arguing that the instruction violated his right to a fair trial. The Supreme Court agreed, holding (1) the trial judge abused his discretion by giving what amounted to a preemptive anti-CSI effect instruction that was not in conjunction with a reiteration of the reasonable doubt standard; and (2) the error in the anti-CSI effect instruction was not harmless. View "Taylor v. State" on Justia Law
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Criminal Law, Maryland Court of Appeals
Conner v. State
The Court of Appeals affirmed the decision of the court of special appeals affirming the judgment of the circuit court finding Appellant in violation of his probation and sentencing him to serve ten years, holding that there was no error.Appellant pled guilty in five cases involving theft charges and violations of probation. As a condition of probation, the circuit court ordered Appellant to enroll in, comply with the conditions of, and successfully complete the Drug Court program. The State later alleged that Appellant violated his probation by failing to comply with the requirements of Drug Court. Appellant was found in violation of his probation. The Court of Appeals affirmed, holding that a trial judge assigned to a drug court program is not required to recuse him or herself from presiding over a violation of probation proceeding for a current drug court participant. View "Conner v. State" on Justia Law
Posted in:
Criminal Law, Maryland Court of Appeals