Justia Civil Rights Opinion Summaries

Articles Posted in Maryland Court of Appeals
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The Court of Appeals held that Defendant had a reasonable expectation of privacy in data contained on his hard drive and that the government conducted an unreasonable search by examining data without any authority to do so either by a warrant or an exception to the warrant requirement.At issue was whether the consensual creation of a copy of the hard drive of Defendant's seized laptop computer permanently eliminated Defendant's privacy interest in the hard drive. The circuit court denied Defendant's motion to suppress and ultimately convicted him of three counts of distribution of child pornography. The appellate court reversed, concluding that individuals have a legitimate expectation of privacy in the digital data within their computer and that Defendant's revocation of his consent to examine the data from his laptop precluded a forensic examination of the mirror-image copy of its hard drive without a warrant. The Court of Appeals affirmed, holding that the search in this case was unreasonable after Defendant withdrew his consent. View "State v. McDonnell" on Justia Law

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The Court of Appeals affirmed the judgment of the appellate court reversing the decision of the circuit circuit court that examination of data contained on Defendant's hard drive was not a search in violation of the Fourth Amendment, holding that the government violated Defendant's Fourth Amendment rights in this case.Defendant voluntarily consented to government agents seizing his laptop computer, creating a copy of its hard drive, and searching the data on it. After the copy was made but before the government examined the data Defendant withdrew his consent. Defendant moved to suppress the evidence from the forensic examination of the copy of his laptop's hard drive. The circuit court denied the motion. On appeal, Defendant asserted that he had a legitimate expectation of privacy in the mirror-image copy of his laptop hard drive. The appellate court agreed and reversed. The Court of Appeals affirmed, holding (1) Defendant had a reasonable expectation of privacy in the data contained on his hard drive; (2) because the government did not examine the data before Defendant withdrew his consent Defendant did not lose his reasonable expectation of privacy in the data; and (3) the government conducted an unreasonable search by examining the data without any authority to do so. View "State v. McDonnell" on Justia Law

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The Court of Appeals affirmed the judgment of the appellate court dismissing Appellant's appeal of the circuit court's ruling affirming the judgment of the Maryland Commission on Civil Rights finding no probable cause to believe that Krav Maga MD, LLC (KMMD) engaged in disability discrimination, holding that the appellate court correctly dismissed Appellant's appeal.Appellant alleged that KMMD, her gym, engaged in disability discrimination by deleting a comment that Appellant had posted on the gym's Facebook account relating to her disability and then later by terminating her membership. The Commission ultimately found no probable cause the find that KMMD had discriminated against Appellant based on her disability. The circuit court affirmed the Commission's finding of no probable cause. On appeal, the appellate court ruled that it lacked jurisdiction to consider Appellant's appeal. The Court of Appeals affirmed, holding that the appellate court correctly dismissed Appellant's appeal. View "Rowe v. Md. Comm'n on Civil Rights" on Justia Law

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In this case considering whether unprovoked flight in a high-crime area should no longer be considered a factor that gives rise to rebate articulable suspicion for a Terry stop, the Court of Appeals held that, under the totality of the circumstances, Defendant's rights under either the Fourth Amendment or Article 26 of the Maryland Declaration of Rights were not violated.Defendant, who was standing in an high-crime area in Baltimore City, fled when he saw an unmarked vehicle. Ultimately, detectives stopped Defendant and found a gun in his waistband. Defendant filed a motion to suppress, arguing that the detectives lacked reasonable suspicion to stop him based solely on his unprovoked flight in a high-crime area. The Supreme Court affirmed the denial of the motion, holding that, under under the totality of the circumstances analysis, a court may consider whether unprovoked flight is an indication of criminal activity that, together with evidence of a high-crime area and any other relevant factors, establishes reasonable suspicion for a stop, or whether unprovoked flight, under the circumstances of the case, is a factor consistent with innocence that adds little or nothing to the reasonable suspicion analysis. View "Washington v. State" on Justia Law

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The Court of Appeals affirmed the judgment of the court of special appeals reversing the decision of the post-conviction court determining that Appellant's trial counsel provided ineffective assistance by failing to object to certain incomplete or missing jury instructions, holding that defense counsel's failure to object to a "CSI effect" voir dire question did not render her performance constitutionally deficient.In 2007, Appellant was convicted by a jury of murder. In 2010 and 2011, the Court of Appeals held in three cases that a CSI effect message from the bench constituted reversible error. In 2014, Appellant filed a pro se petition for post-conviction relief arguing that he received ineffective assistance of counsel based on his counsel's failure to object to the trial court's CSI effect voir dire question. In 2020, the post-conviction court granted the petition for post-conviction relief and ordered a new trial. The court of special appeals reversed. The Court of Appeals affirmed, holding that under the professional norms that existed at the time of Appellant's trial, defense counsel's failure to object to a CSI-effect voir dire question did not render her performance constitutionally deficient. View "McGhee v. State" on Justia Law

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The Court of Appeals vacated the judgment of the court of special appeals concluding that Appellant had waived his right to appeal the denial of his motion to suppress, holding that Appellant did not waive his right to appeal the suppression ruling.After he had been convicted of a crime of violence Appellant was indicted on charges of possessing a regulated firearm. Appellant filed a motion to suppress the gun and the loaded magazine recovered by law enforcement officers while conducting a warrantless search of his hotel room. Thereafter, the State filed a superseding indictment under a new case number to add additional charges. Appellant subsequently renewed his motion to suppress in the new case. The trial court denied the motion, and Appellant was convicted of first-degree assault and other crimes. The court of appeals affirmed, ruling that Appellant waived his challenge to the denial o this motion to suppress. The Court of Appeals remanded the case for further consideration, holding that defense counsel did not waive Appellant's right to appellate review of the denial of his motion to suppress. View "Huggins v. State" on Justia Law

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The Court of Appeals affirmed the judgment of the court of special appeals affirming the decision of the circuit court denying Defendant's motion to suppress the fruits of the warrantless search of his backpack and the warranted search of his cell phone, holding that Defendant was not entitled to relief on appeal.After a school resource officer broke up a fight in which Defendant was involved, Defendant's backpack dropped to the ground. When the officer picked up the backpack Defendant ran from the scene. The officer subsequently searched the backpack and discovered a stolen firearm and three cell phones. The officers obtained a warrant to search one cell phone. Thereafter, Defendant was charged with robbery and other offenses. After the trial court denied Defendant's suppression motion as to both searches Defendant pleaded guilty to conspiracy to commit robbery and wearing, carrying, and transporting a handgun. The court of special appeals affirmed. The Supreme Court affirmed, holding (1) because Defendant abandoned his backpack the warrantless search of his backpack was constitutionally permissible; and (2) the warrant authorizing the search of the cell phone did not comply with the particularity requirement of the Fourth Amendment, but the good faith exception to the exclusionary rule applied to the fruits of the cell phone search. View "Richardson v. State" on Justia Law

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The Court of Appeals vacated Defendant's convictions for second-degree assault and second-degree child abuse by a custodian, holding that Defendant, an Afrian American man, was prejudiced by the fact that the Sheriff's deputies who served as courtroom bailiffs during his trial wore thin blue line face masks, as required by the Sheriff.On appeal, Defendant argued that the bailiffs' display of the thin blue line flag on their face masks violated his Sixth Amendment right to a fair trial. The court of special appeals affirmed the convictions, concluding that the display of the thin blue line flag did not violate Defendant's right to a fair trial. The Court of Appeals vacated Defendant's convictions, holding that the bailiffs' display of the thin blue line flag and the pro-law enforcement message that it conveyed was inherently prejudicial to Defendant's constitutional right to a fair trial. View "Smith v. State" on Justia Law

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The Court of Appeals reversed the judgment of the court of special appeals affirming the decision of the circuit court granting summary judgment in favor of Defendants in this case involving violent peer conflicts between adolescents in middle school, holding that the circuit court erred.Plaintiffs filed a five-count complaint against several school defendants and the Board of Education for Dorchester County, alleging violations of their daughter's state constitutional right to due process and other causes of action stemming from their daughter's bullying by other students. The circuit court granted summary judgment for Defendants, and the court of special appeals affirmed. The Court of Appeals reversed, holding (1) the Act does not preempt CJ ยง 5-518, and Plaintiffs' negligence claims against the individual school employees were not preempted by federal law; (2) the educational malpractice doctrine does not apply to Plaintiffs' negligent supervision claims; and (3) material disputes of fact precluded the entry of summary judgment. View "Gambrill v. Bd. of Education of Dorchester County" on Justia Law

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The Court of Appeals affirmed the decision of the court of special appeals affirming the judgment of the circuit court denying Appellant's motion to correct an illegal sentence, holding that Appellant's sentencing proceeding complied with the constitutional protections recognized in recent decisions of the Supreme Court.In 2010, Petitioner was convicted of first-degree felony murder and other crimes for his involvement in a burglary at the age of sixteen that resulted in a murder. Petitioner was sentenced to life in prison with all but sixty years suspended for the murder conviction and will be eligible for parole at the time he is forty-two years old. In 2017, Petitioner filed a motion to correct an illegal sentence, arguing that his sentence violated the Eighth Amendment, as interpreted in recent decisions of this Court and the Supreme Court. The circuit court denied the motion, and the court of special appeals affirmed. The Supreme Court affirmed, holding that Petitioner's sentence did not amount to a de facto sentence of life without parole, and his sentence was not grossly disproportionate. View "Jedlicka v. State" on Justia Law