Justia Criminal Law Opinion Summaries

In 2002, Steven Anthony Thomas was indicted for three hotel robberies in Charles County, Maryland. He pleaded guilty to two counts of armed robbery and one count of second-degree burglary, resulting in a total sentence of 40 years. In 2014, his sentence for the first armed robbery was reduced to 12.5 years, triggering a new five-year period for filing a motion to modify his sentence under Maryland Rule 4-345(e). Thomas filed a timely motion in 2015, which the court held in abeyance. He supplemented his motion multiple times, but the court took no action before the five-year period expired in December 2019.The Circuit Court for Charles County eventually held a hearing in 2021 and concluded it lacked authority to revise the sentence after the five-year period. The Appellate Court of Maryland reversed, relying on Schlick v. State, which held that the circuit court retained fundamental jurisdiction over a timely-filed motion even after the five-year period expired.The Supreme Court of Maryland reviewed the case and overruled Schlick v. State. The court held that under Rule 4-345(e), a circuit court does not have jurisdiction to revise a sentence more than five years after its imposition. The court emphasized that the rule's language is unambiguous and imposes a strict temporal limit. The court also clarified that deferring a motion to reduce a sentence for the full five-year period is equivalent to denying it within that period. Consequently, the Supreme Court of Maryland reversed the Appellate Court's decision, affirming that the circuit court lacked authority to modify Thomas's sentence after the five-year deadline. View "State v. Thomas" on Justia Law

In 1999, Mark McCloy was convicted under 18 U.S.C. § 1512(c)(1) for tampering with a potential witness in an EEOC proceeding. In 2021, he applied to purchase a handgun in Maryland, stating he had no disqualifying convictions. The Maryland State Police (MSP) disapproved his application, determining his federal conviction was equivalent to a disqualifying Maryland crime under CR § 9-305.McCloy appealed the MSP's decision to the Office of Administrative Hearings (OAH). The Administrative Law Judge (ALJ) found that 18 U.S.C. § 1512(c)(1) was not equivalent to CR § 9-305 but sua sponte determined it was comparable to CR § 9-306, affirming the MSP's disapproval. McCloy sought judicial review in the Circuit Court for Queen Anne’s County, which affirmed the ALJ’s decision but on the grounds that CR § 9-305 was the appropriate equivalent Maryland crime.The Appellate Court of Maryland affirmed the circuit court’s decision, holding that the relevant Maryland law for determining equivalency is the law in effect at the time of the application, not the conviction. The court used a two-step approach to determine equivalency, comparing the elements of the statutes and considering whether a reasonable mind could conclude the statutes prohibit similar conduct.The Supreme Court of Maryland reversed the Appellate Court’s decision. It held that the relevant Maryland law for determining whether an out-of-State crime is disqualifying is the law in effect when the application is submitted. The court adopted a modified categorical approach, comparing the elements of the out-of-State crime with the Maryland crime. If the elements are broader, the MSP must have conclusive evidence of the acts forming the basis of the conviction to determine if those acts would support a conviction under a disqualifying Maryland crime. The court concluded that McCloy’s federal conviction was not equivalent to a disqualifying Maryland crime and remanded the case with instructions to reverse the MSP’s disapproval of McCloy’s firearm application. View "In the Matter of McCloy" on Justia Law

The case involves Thomas Dwayne Cook, who was convicted of first-degree assault and reckless endangerment for attacking Lieutenant Aubrey Fletcher while serving a prison sentence. Cook sought post-conviction DNA testing of a shirt he wore during the incident, claiming that the DNA results could support his self-defense claim and challenge the severity of the victim's injuries.The Circuit Court for Somerset County denied Cook's petition for DNA testing without a hearing, stating that there was overwhelming evidence of Cook's guilt and that DNA testing would not produce exculpatory or mitigating evidence. Cook appealed this decision, arguing that the court applied the wrong standard and that he should have been allowed to respond to the State's answer to his petition.The Supreme Court of Maryland reviewed the case and affirmed the lower court's decision. The court held that Cook did not demonstrate a reasonable probability that DNA testing would produce exculpatory or mitigating evidence. The court found that even if the DNA testing showed the blood on Cook's shirt was his own, it would not support his self-defense claim or negate the severity of the victim's injuries. The court also held that the Circuit Court did not err in denying the petition without waiting for Cook's response to the State's answer, as the rules do not require the court to wait for such a response before ruling.In conclusion, the Supreme Court of Maryland affirmed the Circuit Court's denial of Cook's petition for post-conviction DNA testing, finding no reasonable probability that the testing would produce exculpatory or mitigating evidence. View "Cook v. State" on Justia Law

The petitioner was arrested under a warrant for allegedly violating Maryland's juror intimidation statute. After a bench trial, the circuit court acquitted her based on its interpretation of the statute. Subsequently, the petitioner filed a civil suit against a sheriff’s deputy, claiming false arrest, false imprisonment, malicious prosecution, and violations of her rights under the Maryland Declaration of Rights. The deputy had filed the application for charges after consulting with the State’s Attorney’s Office, which determined that the petitioner’s conduct violated the statute.The Circuit Court for Wicomico County granted summary judgment in favor of the State, ruling that the deputy could not be held civilly liable for the petitioner’s arrest pursuant to a warrant issued by a judicial officer. The Appellate Court of Maryland affirmed this decision, concluding that the warrant provided legal justification for the arrest and that the officers’ interpretation of the statute was objectively reasonable.The Supreme Court of Maryland reviewed the case and upheld the lower courts' decisions. The Court held that the circuit court did not err in granting summary judgment in favor of the State on the common law claims of malicious prosecution, false arrest, and false imprisonment, as well as on the constitutional claims under Articles 24 and 26 of the Maryland Declaration of Rights. The Court emphasized that when an arrest is made pursuant to a warrant, probable cause is predetermined by a judicial officer, creating a strong presumption of objective reasonableness. The petitioner failed to overcome this presumption.Additionally, the Court held that the circuit court did not err in granting summary judgment on the petitioner’s claim that her arrest and imprisonment violated her free speech rights under Article 40. The Court found that the judicial officer had probable cause to believe that the petitioner’s speech constituted a “true threat” and thus fell outside the protections of Article 40. Finally, the Court upheld the circuit court’s ruling that the juror intimidation statute was not unconstitutionally vague. View "Rovin v. State" on Justia Law

In this case, Charles Mitchell was convicted by a jury in the Circuit Court for Baltimore City of sexually abusing his nine-year-old daughter. During voir dire, Mitchell's defense counsel requested the court to ask potential jurors if they had concerns about a child testifying and if they believed a child could lie about such a serious crime. The court only asked the first part of the question, omitting the second part. The jury found Mitchell guilty, and he was sentenced to 25 years in prison, with all but five years suspended.The Appellate Court of Maryland affirmed the conviction, holding that Mitchell had preserved his claims of error related to voir dire. The court noted that trial courts have broad discretion in voir dire but must ask questions reasonably likely to reveal specific cause for disqualification. The Appellate Court, bound by the precedent set in Stewart v. State, ruled that questions about the credibility of child-witnesses did not support disqualification for cause and thus found no abuse of discretion in the trial court's refusal to ask the second part of the proposed question.The Supreme Court of Maryland reviewed the case and abrogated part of its decision in Stewart v. State, recognizing that significant changes in the law had occurred. The court held that bias regarding a child witness could be a specific cause for disqualification of a juror when the child's testimony is crucial to the trial. The court ruled that the trial court abused its discretion by not rephrasing the defense's question to properly inquire about potential juror bias against child-witnesses. The Supreme Court of Maryland reversed the Appellate Court's decision and remanded the case for a new trial. View "Mitchell v. State" on Justia Law

In this case, law enforcement conducted a 55-minute interview with Tony Blake, who was terminally ill, regarding a drug trafficking operation. Blake made several statements implicating both himself and the defendant, Lamont Smith. The State sought to admit the entire interview as a declaration against penal interest, arguing that the statements were so interwoven that they could not be separated. Defense counsel objected, arguing that not all statements were self-inculpatory to Blake and that the statements were severable.The Circuit Court for Wicomico County admitted the entire interview without parsing each statement to determine its admissibility. The court treated the interview as a single statement and ruled it admissible as a declaration against penal interest. At trial, the interview was played for the jury, and Smith was found guilty on multiple charges related to possession and conspiracy to distribute controlled dangerous substances.On appeal, the Appellate Court of Maryland held that the trial court erred by admitting the entire interview without conducting the required parsing analysis to determine the admissibility of each statement. The court vacated Smith’s convictions, finding that the trial court failed to follow the process established in State v. Matusky, which requires a statement-by-statement analysis to determine if each statement is genuinely self-inculpatory.The Supreme Court of Maryland affirmed the Appellate Court’s decision, holding that the trial court must break down the narrative and determine the separate admissibility of each statement. The court emphasized that the test for admissibility is whether a reasonable person in the declarant’s circumstances would have believed the statement was adverse to their penal interest at the time it was made. The court concluded that Smith adequately preserved his objection to the trial court’s failure to undertake the required parsing process. View "State v. Smith" on Justia Law

The case involves Christopher Mooney, who was convicted of second-degree assault, reckless endangerment, and various firearm-related offenses following the nonfatal shooting of Joshua Zimmerman in Baltimore City. Zimmerman testified that he was shot in the back while sitting in his vehicle. A video recorded by a nearby camera, which depicted the events surrounding the shooting, was admitted into evidence over Mooney's objection.In the Circuit Court for Baltimore City, the jury found Mooney guilty based on the video evidence and Zimmerman’s testimony. Mooney appealed, arguing that the video was not properly authenticated because Zimmerman did not witness the entire event depicted in the video. The Appellate Court of Maryland affirmed the convictions, holding that the video was properly authenticated through a combination of Zimmerman’s testimony and circumstantial evidence.The Supreme Court of Maryland reviewed the case to determine whether the video was properly authenticated. The Court held that the "reasonable juror" test applies to the authentication of videos, meaning there must be sufficient evidence for a reasonable juror to find by a preponderance of the evidence that the video is what it is claimed to be. The Court concluded that videos can be authenticated through circumstantial evidence under Maryland Rule 5-901(b)(4).The Court found that the video was properly authenticated through Zimmerman’s testimony and circumstantial evidence. Zimmerman testified that the video accurately depicted the events he witnessed, and Detective Liu testified about the video’s origin. The Court held that the combination of this testimony and the circumstantial evidence was sufficient for a reasonable juror to find that the video was a fair and accurate depiction of the shooting and the surrounding events. The Supreme Court of Maryland affirmed the judgment of the Appellate Court. View "Mooney v. State" on Justia Law

Aaron Jarvis was involved in a physical altercation with his brother-in-law, Ethan Durrett, which resulted in Jarvis stabbing Durrett. The incident occurred after a heated exchange of text messages regarding a family dispute. Jarvis claimed he acted in self-defense, fearing for his safety due to Durrett's aggressive behavior and larger physical stature. Jarvis testified that he brandished a knife to deter Durrett and that the stabbing was accidental during a struggle.The Circuit Court for Cecil County instructed the jury on perfect self-defense but declined to instruct on imperfect self-defense. Jarvis was acquitted of attempted murder charges but convicted of first-degree assault and other lesser offenses. He was sentenced to 15 years of incarceration, with all but 10 years suspended, and five years of supervised probation.The Appellate Court of Maryland held that the trial court erred in not instructing the jury on imperfect self-defense, given that it had instructed on perfect self-defense. However, the court deemed this error harmless, reasoning that an acquittal of attempted murder was more favorable than a mitigated conviction of attempted voluntary manslaughter.The Supreme Court of Maryland reviewed the case and held that the trial court did not err in declining to instruct the jury on imperfect self-defense. The court found no evidence that Jarvis subjectively believed his use of deadly force was necessary for his safety. Jarvis's testimony indicated that the stabbing was accidental, and there was no evidence to support that he believed stabbing Durrett was necessary for self-defense. Consequently, the Supreme Court affirmed the judgment of the Appellate Court. View "Jarvis v. State" on Justia Law

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

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