Justia Civil Rights Opinion Summaries

A jury convicted Petitioner of distribution of a controlled dangerous substance. The court of special appeals affirmed, reasoning that a witness's prior consistent statements are admissible even if the witness had multiple motives to fabricate, so long as the witness made the statements before any one of the motivates to fabricate. Alternatively, the court held that the witness's prior consistent statements were admissible as rehabilitative evidence under Maryland Rule 5-616(c). The Supreme Court reversed, holding (1) the prior consistent statements were not admissible under Maryland Rule 5-802.1(b) because they were made after the declarant had an expressed or implied motive to fabricate the statements, and the alleged motives were presented as such at trial before the trial judge made a determination as to the statements' admissibility; and (2) the prior consistent statements were inadmissible as hearsay and were neither relevant nor admissible under Rule 5-616(c) to rehabilitate a witness. View "Thomas v. State" on Justia Law

Respondent was convicted by a jury of second-degree depraved heart murder. Respondent appealed his conviction to the court of special appeals, where he argued, inter alia, that the trial court's failure to disclose to him a communication between a juror and the judge's secretary violated Maryland Rule 4-326(d), requiring reversal of his conviction. The intermediate appellate court agreed and reversed the conviction, holding that the circuit court committed reversible error when it failed to disclose, in accordance with Rule 4-326(d), the communication, and in remanding the case for a new trial. The Court of Appeals affirmed, holding that the court's failure to disclose the subject communication to counsel was error, and because it prejudiced Respondent, this error required reversal of Respondent's conviction. View "State v. Harris" on Justia Law

Petitioner was tried before a jury in the circuit court and convicted of four counts of attempted armed robbery, four counts of conspiracy to commit those offenses, and related crimes. The court of special appeals concluded that the four conspiracy convictions should merge, leaving but one such conviction, and rejected Petitioner's remaining contentions, holding (1) the instructions satisfied the constitutional requirement that the jury be advised of the State's burden to prove beyond a reasonable doubt each element of the charged crimes, and (2) fundamental fairness did not require merger of conspiracy to commit armed robbery and attempted armed robbery. Petitioner sought review of the latter two holdings of the court of special appeals. The Court of Appeals affirmed, holding (1) the trial court did not abuse its discretion in issuing its jury instructions; and (2) because the convictions targeted two different crimes, fundamental fairness did not require merger of Petitioner's conviction for conspiracy to commit armed robbery with his attempted armed robbery convictions. View "Carroll v. State" on Justia Law

After a jury trial, Petitioner was convicted of distributing and possessing a controlled dangerous substance. The court of special appeals affirmed the conviction. Defendant subsequently filed a petition for postconviction relief, arguing that he had received ineffective assistance of counsel because counsel sued Petitioner during the representation for unpaid legal fees. The postconviction court granted Petitioner a new trial, reasoning that counsel had a conflict of interest in representing Petitioner. The court of appeals reversed after applying the general test set forth in Strickland v. Washington. At issue on appeal was whether the exception to Strickland's general rule applied in this case. The exception, set forth in Cuyler v. Sullivan, states that the defendant is excused from proving the prejudice prong of the Strickland test upon a showing that counsel was burdened by an "actual conflict of interest." The Supreme Court reversed, holding (1) this case entailed a conflict of interest governed by the Sullivan rubric; and (2) Petitioner was entitled under the Sullivan rule to the benefit of the presumption of prejudice only if he could show the conflict of interest was "actual" in the sense that it had an adverse effect upon counsel's performance. Remanded.

After having been convicted on an agreed-upon statement of the facts of wearing, carrying, or transporting a handgun illegally and of being in possession of a handgun after conviction of a disqualifying offense, Defendant appealed. Before any action was taken by the court of special appeals, the Supreme Court granted certiorari to consider whether the use by police of a Taser that fired two metal darts in the back of Defendant affected a Terry stop or Defendant's arrest. The Court of Appeals reversed, holding (1) the use of a Taser in this case converted what otherwise may have been a Terry stop into a de facto arrest for Fourth Amendment purposes, and there did not exist sufficient probable cause to arrest Defendant; and (2) Defendant's statement to the police that he had a gun in his pocket and the gun recovered from him should have been suppressed. Remanded for a new trial.

Petitioner was convicted of first-degree felony murder. Petitioner's defense at trial was that his participation in the crimes with which he was charged was coerced. Petitioner argued on appeal that the trial court's refusal to instruct the jury with respect to duress was error. The court of special appeals affirmed, rejecting, in the process, the State's argument that the defense of duress is not applicable to felony murder. The Supreme Court reversed, holding (1) in Maryland, duress is a defense to felony murder; but (2) to establish and be entitled to the defense of duress, a defendant need not first prove he attempted to stop or thwart the offense that he was compelled to commit. Remanded for a new trial.

At issue in this case was when "meaningful trial proceedings" begin for purposes of Md. Rule 4-215(e) regarding a defendant's request to discharge counsel. Defendant in this case requested to discharge counsel preceding voir dire the morning before trial. After roll call of the jury was taken, the judge excused the venire panel and allowed Petitioner to discharge counsel and proceed pro se. Defendant was tried and convicted. The court of special appeals affirmed, holding that, because meaningful trial proceedings had begun, Rule 4-215(e) did not apply to Defendant's request to discharge counsel. Therefore, the court of special appeals reviewed the trial judge's decision for abuse of discretion, finding none. The Court of Appeals affirmed, holding (1) the court of special appeals correctly held that once the venire panel was summoned to the courtroom, meaningful trial proceedings had begun; and (2) therefore, the court of appeals did not err in holding Rule 4-215(e) did not apply to Defendant's request to discharge his counsel.

Defendant was on probation for a drunken driving offense when his DNA was collected for a separate murder investigation. The DNA was taken from saliva that Defendant left on a straw in the course of complying with an alcohol monitoring program mandated by the terms of his probation. The DNA test resulted in incriminating evidence against Defendant. The State introduced the DNA and lab report into evidence, and Defendant was convicted of involuntary manslaughter. The court of special appeals affirmed, concluding that Defendant did not have a reasonable expectation of privacy in the testing straw or the DNA on it, and therefore, the seizure of Defendant's DNA without a warrant did not violate the Fourth Amendment. The Court of Appeals affirmed, holding (1) Defendant's Fourth Amendment rights were not violated when the State recovered his DNA from the straw utilized for the mandatory test; and (2) the evidence was sufficient to sustain Defendant's conviction.

Father filed for divorce from Mother. In that proceeding, the parties contested physical and legal custody of their daughters. Prior to the merits hearing, a circuit court judge ordered preparation by court-related personnel a custody investigation report to evaluate the custodial abilities of each parent. The report was completed one week before the merits hearing, and Mother's counsel was able to review the report for only ninety minutes. As a consequence, Mother's attorney moved to exclude the report. The circuit court denied the motion. The judge then granted a divorce and awarded custody of the children to Father with visitation to Mother. The court of special appeals affirmed. At issue on appeal was whether the circuit court's unwritten policy that limits counsel of record in child custody proceedings to viewing custody investigation reports only in person in the clerk's office during normal business hours was viable. Without affirming or reversing, the Court of Appeals remanded for supplementation of the record as to the full contours of the relevant policy.

After a jury trial, Defendant was convicted of manslaughter by motor vehicle, participating in a race or speed contest, and failing to remain at the scene of an accident resulting in death. Defendant appealed, arguing that the trial court unduly restricted his counsel during closing argument by limiting which comparative standards of proof he could argue to the jury. The court of special appeals affirmed. The Court of Appeals affirmed because the trial court's refusal to allow a discussion of extraneous legal standards was not an abuse of its broad discretion in controlling the scope of closing argument so as to avoid potential confusion of the jury.