Justia Civil Rights Opinion Summaries

Petitioner owned land in the Town of Goldsboro in Caroline County. Lake Bonnie provided the water source for the property, on which Petitioner operated a campground. In the mid-1990s, the Maryland Department of Environment (MDE) reported water quality impacts on Lake Bonnie due to failing septic systems in the Town and ordered the Town to take action regarding the septic systems. As of 2010, however, the Town had failed to comply with the order, and MDE had failed to enforce the order. Consequently, Lake Bonnie was polluted, the campground was destroyed, and the bank foreclosed on Petitioner's property. Petitioner sued the Town, County, MDE, and State, alleging several causes of action. All counts were dismissed against the Town, County, and State. The court of appeals affirmed. The Supreme Court affirmed in part and reversed in part, holding (1) because it was not clear from the face of her complaint that Petitioner's causes of action for negligence, trespass, and inverse condemnation were barred by limitations, the court of special appeals erred in affirming the motion to dismiss on those counts; and (2) Petitioner's causes of action for nuisance were barred by limitations, and the court of appeals correctly affirmed the motion to dismiss. View "Litz v. Md. Dep't of Env't" on Justia Law

Defendant was charged with murder and expressed a desire to have a bench trial. During the jury trial waiver colloquy, the trial judge provided Defendant with advice that the judge was not required to give Defendant and that was also erroneous. After a jury-waived trial, Defendant was convicted of first degree murder and sentenced to life imprisonment. Defendant appealed, arguing that his waiver of the right to a jury trial was not knowing and voluntary. The Court of Appeals reversed and remanded for a new trial, holding (1) the trial judge's erroneous advisement may have misled Defendant to believe a jury trial was a less attractive option than it actually was, thereby influencing Defendant's decision to waive his jury trial right; and (2) accordingly, the trial judge did not ensure that Defendant's waiver was knowing. View "Winters v. State" on Justia Law

In 1999, Petitioner pled guilty to a drug offense. Petitioner subsequently filed a petition for a writ of error coram nobis, asserting that his guilty plea was not voluntarily made due to his counsel's failure to advise him of the possible immigration consequences of his plea. The circuit court denied the petition. While Petitioner's appeal was pending, the U.S. Supreme Court decided Padilla v. Kentucky. On appeal, the court of special appeals determined that Padilla did not retroactively apply to vacate Petitioner's conviction. The Court of Appeals reversed. On remand, the court of special appeals again affirmed the denial of Petitioner's petition because Petitioner had not raised the issue of ineffective assistance of counsel in his plea. The Court of Appeals granted certiorari, but prior to oral argument, the U.S. Supreme Court held that Padilla did not apply retroactively. The Court of Appeals affirmed the denial of Petitioner's petition for coram nobis relief, holding that Petitioner's claims of involuntariness or ineffective assistance of counsel did not have independent state bases in Maryland in 1999. View "Miller v. State" on Justia Law

In 2003, Appellant was convicted of rape. The Court of Appeals reversed, holding that the Maryland DNA Collection Act, which permits law enforcement authorities to collect DNA samples from individuals arrested for certain crimes, violated the Fourth Amendment as applied to Appellant. The U.S. Supreme Court reversed, holding that the DNA search of Appellant did not violate his Fourth Amendment rights. On remand, Appellant asked the Court to consider the issues left unresolved by King I. The Court of Appeals held (1) the Maryland DNA Collection Act does not violate Article 26 of the Maryland Declaration of Rights; and (2) the trial judge did not improperly shift the burden of proof to the defense to demonstrate how the State failed to comply with the Act, and even if a statutory violation were proven, there was no reversible error. View "King v. State" on Justia Law

Plaintiffs, each of whom was arrested for a crime and brought before a District Court Commissioner for an initial appearance, filed a complaint against the District Court of Maryland and several court officials alleging that they were denied public defender representation during their initial appearance proceedings. Plaintiffs contended that the initial appearance proceeding is a critical stage of the criminal proceeding requiring state-furnished counsel pursuant to the Public Defender Act (Act) and that the failure to provide counsel violated their due process rights. The Court of Appeals held that the Act required the public defender to represent indigent criminal defendants at the initial appearance proceedings. While motions for reconsideration of the Court's opinion were pending, the General Assembly passed statutes amending the Act to provide that representation was not required to be furnished to an indigent individual at an initial appearance before a district court commissioner. The Court proceeded to hold that, under the due process component of the Maryland Declaration of Rights, an indigent defendant has a right to state-furnished counsel at an initial appearance before a district court commissioner. Remanded. View "DeWolfe v. Richmond " on Justia Law

After a jury trial, Petitioner was convicted of first degree murder and conspiracy to commit first degree murder. Petitioner unsuccessfully filed a petition for post-conviction relief, alleging ineffective assistance of counsel, after which he unsuccessfully filed an application for leave to appeal. Thereafter, Petitioner filed a motion for reconsideration, which the intermediate appellate court granted. The appellate court then determined that the application lacked merit because Petitioner was not prejudiced by the alleged errors of his counsel. The Court of Appeals reversed, holding that Petitioner received ineffective assistance of counsel when his trial counsel failed to object to approximately thirty instances during trial when the State admitted evidence that Petitioner had remained silent in the face of custodial police questioning after Petitioner had been issued Miranda warnings. Remanded. View "Coleman v. State" on Justia Law

After a jury trial, Defendant was convicted of second degree rape, second degree assault, and multiple counts of second, third, and fourth degree sexual offenses. The Court of Appeals affirmed, holding (1) the trial court did not err in allowing a DNA analyst to testify regarding the analysis of another DNA analyst, who did not testify at trial, and did not err in admitting the non-testifying analyst's report into evidence, as (i) the State met its burden of showing chain of custody of a napkin, from which DNA was found connecting Defendant to the victim, (ii) admitting the report of the non-testifying analyst did not violate the rule against hearsay, and (iii) admitting he report did not violate Defendant's right to confrontation; and (2) the trial judge did not err in admitting hearsay statements of the victim as excited utterances through the testimonies of the victim's roommate and the investigating officer. View "Cooper v. State" on Justia Law

After a jury trial, Defendant was convicted of multiple sexual offenses relating to an attack and rape of a woman. The Court of Appeals affirmed, holding (1) the evidence was sufficient to sustain Defendant's conviction; (2) Defendant's constitutional confrontation rights were not violated when the State's expert witness presented the results of forensic tests as the basis for her conclusion that Defendant was the source of the DNA found on vaginal swabs taken from the rape victim; (3) Defendant's rights to discovery were not violated by the trial court's refusal to order the State to conduct a search for coincidental matches in the FBI's Combined DNA Index System; and (4) the trial court did not err in refusing to include Defendant's proposed jury instruction on the definition of "reasonable degree of scientific certainty." View "Derr v. State" on Justia Law

After a trial trial, Petitioner was convicted of second-degree murder. During the trial, a DNA testified that she could not exclude Petitioner as being the source of DNA recovered from the truck in which the victim was shot. In closing argument, however, the prosecutor told jurors that Petitioner's DNA was present in the victim's truck and that the DNA analyst's statistical analysis supported the State's theory of the case. Petitioner objected to the prosecutor's argument as misstating the DNA evidence and unsuccessfully asked for a mistrial. The court of special appeals affirmed the conviction. The Court of Appeals reversed, holding that the trial court abused its discretion in denying Petitioner's motion for a mistrial after the State mischaracterized the statistical significance of the DNA evidence in rebuttal closing argument. Remanded for a new trial. View "Whack v. State" on Justia Law

After a jury trial in 1986, Petitioner was convicted of attempted first degree rape and related charges. Petitioner subsequently pled guilty to two counts of first degree rape, one count of second degree rape, and related charges. In 2005, Petitioner filed a post-conviction petition covering both cases, alleging, among other things, ineffective assistance of counsel. In 2008, the State argued that Petitioner's petition should be denied on the ground of laches. The circuit court held that laches was available to the State as a defense and denied the petition on that basis. The court of appeals agreed that laches was applicable in post-conviction proceedings but found the record was insufficiently developed for a finding that laches barred the petition in this case. The Court of Appeals vacated the judgment of the intermediate appellate court and remanded with directions to vacate the circuit court's decision, holding that laches does not bar an individual from pursuing post-conviction remedies. View "Lopez v. State" on Justia Law