Justia Civil Rights Opinion Summaries

Petitioner was charged with murder and other related offenses. During defense counsel's opening statement, counsel referenced Petitioner's willingness to take a lie detector test during his interrogation by the police. The trial judge gave a curative instruction to the jury immediately following the improper reference. Two days further into the trial, the prosecutor filed a motion for a mistrial for reason of that improper remark. The trial judge granted the motion. Petitioner subsequently filed a motion to dismiss, arguing that retrial was prohibited under double jeopardy principles. The court of special appeals affirmed, concluding that the trial judge properly determined that manifest necessity existed for a mistrial, and therefore, double jeopardy principles did not prevent a retrial. The Court of Appeals affirmed, holding that the trial judge did not abuse his discretion in making a determination of manifest necessity to declare a mistrial where the judge considered his previously issued curative instruction and found it insufficient to cure the prejudice caused by defense counsel's improper remark. View "Simmons v. State" on Justia Law

After a jury trial, Petitioner was convicted of multiple counts of second degree murder and other crimes. The court of appeals affirmed, concluding that the trial court erred in prohibiting Petitioner's cross-examination of a State's witness regarding the witness' expectation of leniency in a separate pending case should he testify against Petitioner but that the error was harmless. The Court of Appeals reversed, holding (1) the trial court erred in limiting Petitioner's cross-examination of the witness with regard to his expectation of leniency; and (2) contrary to the conclusion of the intermediate appellate court, the effect of that error was not harmless to the result of the trial. View "Dionas v. State" on Justia Law

Petitioner was convicted of second degree assault and sentenced to ten years in prison and three months probation. After Petitioner was sentenced, he tore up a copy of his probation papers while seated next to the exit door in the courtroom. Subsequently, while walking down a hall outside the courtroom, Petitioner threatened in front of a law enforcement officer to harm a witness/victim. The trial court revoked Petitioner's probation, determining that, through his actions, Petitioner committed direct criminal contempt of court and violated Md. Code Ann. Crim. Law 9-303(a), the retaliation statute. The court of special appeals affirmed. The Court of Appeals affirmed in part and reversed in part, holding (1) section 9-303(a) does not require communicating a threat to a victim/witness or a belief that the threat may be communicated to the victim/witness, and in this case, Petitioner committed a threat within the meaning of the statute; and (2) the record did not support a finding that Petitioner was in direct contempt of court when he tore up his personal copy of the probation papers following his sentencing. Remanded. View "Hammonds v. State" on Justia Law

After a jury trial in 1998, Appellant was convicted of murder and sentenced to death. In 2011, Appellant filed a second motion to correct an illegal sentence, claiming that his death sentence was unconstitutional and illegal under Article 16 of the Maryland Declaration of Rights, which provides that "sanguinary Laws ought to be avoided as far as is consistent with the safety of the State[.]" Appellant claimed that at the time the clause was adopted as Article 14 in 1776, a sanguinary law meant the death penalty for any crime, and therefore, Article 14 abrogated capital punishment for any offense that did not impact State security. The circuit court denied Appellant's motion. The Court of Appeals affirmed, holding (1) where death was the common law penalty for murder and the sanguinary laws clause applied only to legislative action, the death penalty was not abrogated by Article 14; and (2) if the sanguinary laws clause was retroactive, it was not intended to include death as a possible penalty for murder. View "Miles v. State" on Justia Law

After a jury trial, Petitioner was convicted of controlled substance and resisting arrest offenses. The court of special appeals affirmed, holding (1) the trial court did not violate Maryland Rule 4-215(e) by failing to respond to a letter Petitioner sent to the court prior to trial seeking to discharge his counsel; and (2) the evidence was sufficient to support Petitioner's conviction for resisting a lawful arrest. The Court of Appeals reversed in part and affirmed in part, holding (1) Petitioner's letter to the trial court was sufficient to trigger Rule 4-215(e), and the trial court's failure to inquire into the reasons behind Petitioner's request to discharge counsel was reversible error; and (2) the court of special appeals did not misinterpret Maryland's resisting arrest statute in finding that the evidence was sufficient to support Petitioner's conviction for resisting arrest. Remanded. View "Williams v. State" on Justia Law

Petitioner was charged with assault, reckless endangerment, firearms violations, and a drug-related offense. Petitioner sought to suppress detectives' observations during and after an investigatory stop of Petitioner on the ground that the stop violated the Fourth Amendment. The suppression court granted Petitioner's request, determining that the investigatory stop violated the Fourth Amendment because the detectives did not have a reasonable suspicion that Petitioner had committed a drug-related crime or a traffic infraction. The court of special appeals reversed. The Court of Appeals affirmed, holding that, although the suppression court correctly concluded that the series of acts the detectives observed were by themselves innocent, taken together, those acts supported the detectives' suspicion that Petitioner was engaged in criminal activity. View "Holt v. State" on Justia Law

After a jury trial, Defendant was convicted of first degree murder and the use of a handgun in the commission of a crime of violence. According to the State's theory of the case, Defendant was a hit man for the Black Guerilla Family gang (BGF) and was ordered by his gang boss to kill the victim. During trial, several witnesses testified that the murder was related to Defendant's affiliation with the BGF. The court of special appeals affirmed. The Court of Appeals reversed and remanded for a new trial, holding that the trial court abused its discretion in allowing a "gang expert" to opine as to the nature of gangs in general, the BGF specifically, and the import of Defendant's tattoos towards establishing that he was a member of a gang, as the probative value of the expert's testimony was substantially outweighed by unfair prejudice, and this error was not harmless. View "Burris v. State" on Justia Law

Appellees in this case were seventeen-year-olds who would have been eighteen by the 2008 general election. After exhausting their administrative remedies, Plaintiffs filed separate complaints in the circuit court against the Maryland State Boar of Elections (MSBE), alleging that the MSBE violated several provisions of the Election Law Article by prohibiting seventeen-year-olds who would be eighteen by the next general election from casting any votes in non-partisan primary elections for county school boards. The circuit court concluded that the voter eligibility requirements of the Maryland Constitution did not apply to non-partisan elections for Boards of Education, municipal elections, and local ballot questions not mandated by the Constitution. The Court of Appeals vacated the circuit court and held that seventeen-year-olds who will turn eighteen by close of voter registration before the next general election were constitutionally and statutorily entitled to vote in primary elections, whether partisan or non-partisan, subject to all other provisions of the Constitution and statutory election law. Remanded. View "State Bd. of Elections v. Snyder" on Justia Law

Petitioner was charged with conspiracy to commit theft, making a false statement to the police while under arrest, and related offenses after the vehicle in which he was an occupant was stopped by police officers and the police discovered multiple fake credit cards in the wallet of a female passenger. The police then arrested all occupants of the vehicle. Petitioner filed a motion to suppress, contending that the evidence was obtained as a result of an illegal stop. The circuit court denied the motion to suppress. Defendant appealed, contending that his Fourth Amendment rights were violated because the police lacked probable cause to arrest him. The court of special appeals held that police had probable cause to arrest Petitioner and therefore any evidence obtained by police as the fruit of that arrest was not subject to suppression. The Supreme Court affirmed, holding that Petitioner's claim was not properly before the appellate courts because Petitioner waived it by not raising it before the circuit court. View "Ray v. State" on Justia Law

The supervisory employee exception to the handgun law allows such an employee to carry a handgun, with the employer's permission, within the enclosed premises of the business in which the employee works. Petitioner, the head of security for a nightclub, was arrested by the county police for carrying a handgun without a permit in the open parking lot of the nightclub. Petitioner filed a lawsuit against the county and three of the police officers involved in his arrest for a violation of the Maryland Declaration of Rights, false arrest and imprisonment, and malicious prosecution, contending that his arrest was illegal because the parking lot should be considered to be "within the confines" of the nightclub. A jury found in favor of Petitioner on his state constitutional claim and on the false arrest and imprisonment claim. The court of special appeals reversed, holding that the parking lot of the club was not "within the confines of the business establishment." The Court of Appeals affirmed, holding that when Petitioner left the "confines" of the nightclub and took his handgun into the parking lot, he was no longer with the supervisory employee exception to the handgun law. View "Blue v. Prince George's County" on Justia Law