Justia Civil Rights Opinion Summaries

Articles Posted in Maryland Court of Appeals
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The Court of Appeals dismissed this appeal of the court of special appeals' denial of an application for leave to appeal in a postconviction proceeding, holding that this Court lacked subject matter jurisdiction pursuant to Md. Code Cts. & Jud. Proc. (CJ) 12-202.Petitioner was found guilty of first-degree murder and other crimes. Nearly ten years after Petitioner was sentenced, he filed a petition for postconviction relief, alleging ineffective assistance of both trial and appellate counsel. The postconviction court denied the petition. Petitioner filed an application for leave to appeal, which the court of special appeals denied without explanation. Petitioner then petitioned the Court of Appeals for writ of certiorari. The Court of Appeals dismissed the appeal for lack of subject matter jurisdiction, holding that CJ 12-202 is not precluded by article IV, section 14A of the Maryland Constitution. View "Mahai v. State" on Justia Law

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The Court of Appeals affirmed the judgment of the court of special appeals affirming the circuit court's dismissal of Plaintiff's malicious prosecution claim and reversing the grant of Defendant's motion for judgment notwithstanding the verdict (JNOV) on Plaintiff's discrimination claim, holding that the court of special appeals did not err.Plaintiff sued the Town of Riverdale Park and members of the Riverdale Park Police Department for claims including intentional discrimination on the basis of national origin. The circuit court granted the Town's motion for judgment on the malicious prosecution claim and sent the discrimination claim to the jury. The jury found in favor of Plaintiff and awarded damages. The circuit court granted the Town's motion for JNOV, citing Plaintiff's lack of evidence. The court of special appeals affirmed the dismissal of the malicious prosecution claim but reversed the grant of the motion for JNOV. The Court of Appeals affirmed, holding that Plaintiff presented sufficient evidence of discrimination to withstand a motion for JNOV. View "Town of Riverdale Park v. Askhar" on Justia Law

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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

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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

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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

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The Court of Appeals affirmed the judgment of the court of special appeals affirming the denial of Defendant's motion for new trial on the grounds that certain newly discovered evidence was immaterial, holding that there was no Brady violation in this case.Defendant was convicted of two counts of first-degree murder. Following the trial but prior to sentencing, the State informed Defendant's counsel of an interview that took place between two detectives and the family members of one of the State's witnesses. Defendant moved for a new trial, arguing that the nondisclosure of the interview violated Brady v. Maryland, 373 U.S. 83 (1963). The circuit court denied the motion, finding that the evidence of the interview was not material. The Court of Appeals affirmed, holding that the nondisclosure of the interview did not constitute a Brady violation. View "Canales-Yanez v. State" on Justia Law

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The Court of Appeals affirmed the judgment of the court of special appeals reversing Defendant's convictions on the grounds that the circuit court should have granted Defendant's motion to suppress, holding that the State failed to meet its burden of establishing the constitutionality of Defendant's seizure at the suppression hearing.When Maryland Transit Administration (MTA) police officers conducted a fare sweep aboard a Light Rail train Defendant confessed that he did not have a ticket. An officer obtained identifying information from Defendant and ran a warrant check on him revealing the existence of a warrant for Defendant's arrest. In attempting to arrest Defendant, officers saw that Defendant had a gun. Defendant moved to suppress the gun, arguing that the fare sweep constituted a warrantless seizure not based on reasonable suspicion. The circuit court denied the motion to suppress. The court of special appeals reversed, concluding that the circuit court erred in denying Defendant's suppression motion. The Court of Appeals affirmed, holding (1) police officers effected a seizure of Defendant without reasonable suspicion by announcing the fare sweep, and Defendant did not impliedly consent to the seizure by riding the train; and (2) the record was insufficiently developed to conclude whether Light Rail sweeps are constitutional under the special needs doctrine. View "State v. Carter" on Justia Law

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The Court of Appeals affirmed Defendant's convictions for sexually abusing several female students while he was their elementary school teacher, holding that any error by the trial court in excluding character evidence of appropriateness with children in Defendant's custody or care was harmless beyond a reasonable doubt.On appeal, Defendant argued that the trial judge erred by excluding evidence from parents of students and from professional colleagues that, in their opinion, Defendant was the type of person who behaved appropriately with children in his custody or care. The Court of Special Appeals affirmed. The Court of Appeals also affirmed, holding (1) character evidence of appropriateness with children in one's custody or care may be admissible in a criminal case where a defendant is accused of sexually abusing a child; (2) any error in excluding Defendant's proffered character evidence was harmless beyond a reasonable doubt; and (3) Defendant's constitutional arguments were not preserved for appellate review or abandoned and, in any event, lacked merit. View "Vigna v. State" on Justia Law

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The Court of Appeals reversed the decision of the court of special appeals reversing the decision of the post-conviction court granting Petitioner post-conviction relief based on the court's finding that Petitioner received ineffective assistance of counsel, holding that Petitioner's counsel rendered ineffective assistance based on a conflict of interest.Petitioner pleaded guilty to possession with intent to distribute a controlled dangerous substance. Petitioner subsequently filed a petition for post-conviction relief, alleging that he received ineffective assistance of counsel because he was misadvised of the immigration consequences of his plea agreement and because his counsel failed to disclose a personal conflict of interest. The post-conviction court granted Petitioner relief based on the court's finding of an actual conflict of interest. The court of special appeals reversed. The Court of Appeals reversed, holding that defense counsel's conflict of interest rendered his representation of Petitioner constitutionally deficient under the Sixth Amendment to the United States Constitution and Article 21 of the Maryland Declaration of Rights. View "Podieh v. State" on Justia Law

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The Court of Appeals held that the odor of marijuana on or about a person, without more, does not provide law enforcement officers with probable cause to arrest and perform a warrantless search of that person incident to the arrest.Defendant filed a motion to suppress, arguing that he was unlawfully seized and subjected to a search incident to arrest. In denying Defendant's motion to suppress, the suppression court ruled that the odor of marijuana gave police probable cause to arrest Defendant and, incident to the arrest, conduct a full search of Defendant's person. The Court of Special Appeals affirmed. The Court of Appeals reversed, holding (1) the mere odor of marijuana emanating from a person, without more, does not provide the police with probable cause to support an arrest and a search of the arrestee; and (2) because the search of Petitioner was based solely on the odor of marijuana emanating from his person, the officer lacked the requisite probable cause to conduct that search. View "Lewis v. State" on Justia Law