Justia Criminal Law Opinion Summaries

Articles Posted in Maryland Supreme Court
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Darryl Edward Freeman was charged with multiple counts related to the killing of Bradley Brown, including first-degree murder, armed robbery, and conspiracy. During the trial in the Circuit Court for Charles County, Detective Corey Wimberly testified about the meaning of the slang terms "lick" and "sweet licks," which he defined as "a robbery" and "an easy target for robbery," respectively. Freeman objected, arguing that Wimberly was not qualified as an expert to provide such definitions. The court overruled the objection and allowed the testimony.Freeman was convicted on all counts, with some counts later merged for sentencing purposes. He appealed to the Appellate Court of Maryland, which affirmed the convictions. The Appellate Court held that Wimberly's testimony was expert in nature but concluded that the circuit court had "implicitly" accepted him as an expert by overruling Freeman's objection.The Supreme Court of Maryland reviewed the case to determine whether the circuit court properly allowed Wimberly to testify about the slang terms as either an expert or a lay witness. The court held that Wimberly's testimony was permissible as lay opinion under Maryland Rule 5-701, as defining the slang term "lick" was within the understanding of a layperson and did not require specialized knowledge. The court concluded that the circuit court did not abuse its discretion in allowing the testimony and affirmed the judgment of the Appellate Court of Maryland. View "Freeman v. State" on Justia Law

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In this case, the defendant, Antonio E. Gonzalez, was charged with assaulting his then-wife and their son. During the trial, the defense sought to cross-examine the wife about her application for a U visa, which is a visa for noncitizens who are victims of certain crimes and are helpful to law enforcement in the investigation or prosecution of criminal activity. The trial court ruled that the defense had not established a sufficient factual foundation for this line of questioning and thus it was not allowed. The defendant was convicted and appealed the decision, arguing that the trial court erred in precluding the cross-examination.The Supreme Court of Maryland held that the trial court did err in this regard. The Court found that the defense had established a sufficient factual foundation for the cross-examination, as the wife had submitted a U visa application based on being a victim of the crime for which the defendant was on trial, and a member of the State’s Attorney’s Office had signed the necessary certification for the U visa. The Court reasoned that these circumstances could have led a jury to infer that the wife had a personal interest in the outcome of the trial or a motive to testify falsely.However, the Court ultimately concluded that this error was harmless and did not influence the verdict. The Court noted that the defendant had acknowledged committing acts that constituted the assaults for which he was convicted, and that the wife's testimony was consistent with other evidence presented at trial. Therefore, the Court affirmed the lower court's decision. View "Gonzalez v. State" on Justia Law

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The case involves Troy Mason, who was charged with second-degree assault. During the trial, it was discovered that a "strangulation form" provided through discovery was not the original form completed at the scene. Mason requested a curative instruction, but the circuit court offered him an opportunity to question the officer outside the presence of the jury, which he agreed to. After learning details about the alleged original strangulation form, Mason decided to proceed with the trial. The next day, he moved for a mistrial and requested a curative instruction, both of which were denied. Mason was convicted and sentenced to ten years of incarceration with all but seven years suspended and a period of supervised probation for five years.The Appellate Court of Maryland affirmed the conviction and the denial of a mistrial. The court found that the circuit court did not abuse its discretion in denying the request for a mistrial, where Mason chose to elicit testimony regarding an item not disclosed in discovery, yet later argued he was prejudiced by this testimony. The Supreme Court of Maryland also held that the circuit court did not err in denying the request by Mason for a curative instruction.The Supreme Court of Maryland affirmed the decision of the Appellate Court, holding that the circuit court did not abuse its discretion in denying Mason's requests for a mistrial or curative instruction. The court concluded that Mason was not prejudiced by the discovery of the undisclosed strangulation form because the form provided in discovery was helpful to him and because the two testifying officers gave conflicting testimony about the form. View "Mason v. State" on Justia Law

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In the case of Antonio E. Gonzalez v. State of Maryland, the defendant, Antonio E. Gonzalez, was charged with assaulting his then-wife, M., and their son, F. During the trial, Gonzalez's counsel attempted to cross-examine M. about her application for a U visa, which is a visa for noncitizens who are victims of certain crimes and are helpful to law enforcement in the investigation or prosecution of criminal activity. The trial court ruled that it would not permit cross-examination of M. concerning her immigration status because Gonzalez's counsel had not established an adequate foundation for such inquiry.The Supreme Court of Maryland held that the trial court erred in precluding Gonzalez's counsel from cross-examining M. about her U visa application. The Supreme Court concluded that, given the nature of the requirement that, for a U visa to be approved, an applicant must be helpful in the investigation or prosecution of criminal activity and provide a certification from a law enforcement or government official to that effect, a sufficient factual foundation for impeachment of a witness concerning a U visa application is established under Maryland Rule 5-616(a)(4) where there has been a showing that a U visa application, based on the witness being a victim of a crime that the defendant is charged with, has been submitted to the government for approval.However, the Supreme Court also concluded that, because any error in precluding cross-examination concerning U visa application was harmless, it was not necessary to deviate from general practice of refraining from addressing issue not decided by the trial court or raised in petition for writ of certiorari. The Supreme Court concluded that trial court’s error was harmless beyond reasonable doubt as defendant testified to committing acts that formed basis of offenses for which he was convicted, witness’s testimony was consistent with another witness’s testimony who was not applicant for U visa, witness’s testimony was consistent with initial description of incident, and other evidence corroborated that both witnesses had been assaulted by defendant. View "Gonzalez v. State" on Justia Law

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The Supreme Court of Maryland held that the State's duty to preserve scientific identification evidence, such as DNA, is limited to specific crimes specified in the Criminal Procedure Article ("CP") § 8-201(j)(1)(ii) and does not extend to all crimes for which a person may petition for DNA testing. The Court ruled that the preservation obligation does not apply to the inchoate (or incomplete) offenses of those crimes listed under the same section of the law. The Court also found that the State's duty to preserve evidence does not extend to attempted murder.The case involved Darrell Eugene Matthews who had been convicted of attempted murder and was seeking post-conviction DNA testing of a glove found at the crime scene. The glove had been destroyed according to the police department's evidence retention policy after Matthews's first petition for DNA testing. The Court held that the circuit court correctly denied Matthews's second petition for post-conviction DNA testing because the State was not required to preserve evidence related to Matthews's attempted murder conviction for the duration of his sentence. The Court also found that the evidence Matthews sought to test had been destroyed in line with the police department's evidence retention policy. View "Matthews v. State" on Justia Law

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The Court of Chancery reversed the judgment of the circuit court convicting Defendant of murder and child abuse, holding that the circuit court erred in admitting evidence of Defendant's prior conviction for child abuse resulting in the death of his infant son, and a new trial was required.Defendant was convicted of second-degree murder, first-degree child abuse resulting in death, and other crimes related to the death of a seventeen-month-old. The appellate division affirmed, holding that the evidence of the death of Defendant's son was admissible under the doctrine of chances. The Supreme Court reversed, holding that the State "stretched the doctrine of chances beyond its limits," and therefore, the circuit court abused its discretion in admitting evidence about the death of Defendant's son. The Court remanded the case for a new trial. View "Browne v. State" on Justia Law

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The Supreme Court reversed the judgment of the appellate court reversing the judgment of the circuit court concluding that Defendant could not show that he was prejudiced by his counsel's assistance under Strickland v. Washington, 466 U.S. 668 (1984), holding that the circuit court correctly concluded that trial counsel's performance was deficient.At issue was whether trial counsel's failure to object to an order prohibiting any consultation regarding the case between Petitioner and trial counsel during Petitioner's murder trial resulted in the actual denial of the Sixth Amendment's guarantee of assistance of counsel. The Supreme Court held (1) prejudice was presumed under the circumstances of this case; and (2) the circuit court correctly concluded that trial counsel's failure to object was objectively unreasonable. View "Clark v. State" on Justia Law

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The Supreme Court upheld the judgment of the circuit court on postconviction review ordering a new trial for Petitioner, holding that Petitioner was provided ineffective assistance of counsel due to trial counsel's failure to object to the trial court's order prohibiting any consultation about the case (a no-communication order) between Petitioner and trial counsel under the circumstances of this case.At issue was a no-communication order entered into between Petitioner and trial counsel during an overnight recess prior to the final day of testimony in Petitioner's murder trial and trial counsel's failure to object to the order. The circuit court ruled that the no-communication order, and trial counsel's failure to object, deprived Petitioner of the assistance of counsel, in violation of the Sixth Amendment, and presumed prejudice, thus ordering a new trial. The appellate court reversed, concluding that Petitioner could not show prejudice. The Supreme Court reversed, holding (1) trial counsel's conduct in this case resulted in the actual denial of the assistance of counsel, and prejudice was presumed; and (2) therefore, the circuit court properly ordered a new trial for Petitioner. View "Clark v. State" on Justia Law

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The Supreme Court affirmed the judgment of the post-conviction court denying Petitioner's pro se petition for post-conviction relief, holding that the post-conviction court did not err in denying the petition.Petitioner was convicted of distribution of heroin and sentencing him to eight years in prison. In his post-conviction motion, Petitioner argued that his trial counsel rendered ineffective assistance during trial and that the State had violated its Brady obligations. The post-conviction court denied relief. The appellate court certified questions of law to the Supreme Court. The Supreme Court answered (1) Defendant failed to establish that trial counsel rendered ineffective assistance by failing to move to compel production of Internal Affairs Division files; and (2) assuming, without deciding, that the State was required to disclose impeachment evidence prior to the suppression hearing, Petitioner failed to establish the Brady materiality standard. View "Blake v. State" on Justia Law

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The Supreme Court affirmed the decision of the post-conviction court denying Defendant's petition for post-conviction relief, holding that the post-conviction court did not err in ruling that trial counsel had not rendered ineffective assistance and that the State had not violated its Brady obligations during the underlying proceedings, holding that there was no error.After a jury trial, Defendant was convicted of distribution of heroin and sentenced to eight years' imprisonment. The appellate court affirmed. Defendant later filed a pro se petition for post-conviction relief, which the post-conviction court denied. On appeal, the appellate court certified questions of law to the Supreme Court. The Supreme Court answered (1) the post-conviction court did not err in ruling that trial counsel had not rendered ineffective assistance by failing to move production of certain evidence; and (2) assuming, without deciding, that the State was required to disclose challenged impeachment evidence prior to the hearing on Defendant's motion to suppress, Defendant failed to establish the Brady materiality standard. View "Blake v. State" on Justia Law