Justia Civil Rights Opinion Summaries

In 1990, Appellant Michael Washington was convicted by a jury of first degree rape and related offenses and was sentenced to life in prison. Appellant later petitioned for a search for DNA material pursuant to Md. Code Ann. Crim. Proc. 8-201, after which the sheriff's office conceded it had destroyed biological evidence relating to Appellant's conviction. A hearing judge denied Appellant's subsequent petitions relating to this destruction of evidence. The Supreme Court affirmed, holding (1) the lower court did not err in finding that the State performed a reasonable search for the requested biological identification; (2) the State's duty to preserve scientific identification evidence, pursuant to section 8-201(j) begins as of the date the statute was enacted and is not to be applied retroactively; (3) because the hearing judge did not err in determining that the scientific identification evidence was destroyed prior to the enactment date of the statute, the statute was not applicable and Appellant was not entitled to the relief provided; and (4) the lower court did not err in finding that Appellant's conviction did not rest upon unreliable scientific identification evidence and denying Washington's motion for a new trial on that basis.

Petitioner Elroy Matthews invoked Md. Rule 4-345(a) to challenge the legality of the sentence he received following his plea of guilty to certain charges as part of a plea agreement. Petitioner argued that the sentence was illegal because it exceeded the sentence to which the court had bound itself. The circuit court denied the motion without a hearing. The court of special appeals held that a challenge to the legality of a sentence on the ground that it violates a binding term of a plea agreement is not cognizable under Rule 4-345(a), and even if it were, the sentence Petitioner received was not illegal. The Court of Appeals reversed, holding (1) Rule 4-345(a) is an appropriate vehicle for challenging a sentence that is imposed in violation of a plea agreement to which the sentencing court bound itself; and (2) the sentence Petitioner was serving was illegal because it exceeded the sentencing cap to which the circuit court agreed to be bound. Remanded for resentencing.

A police officer was dispatched to investigate a two-car collision, where she determined that one of the cars involved in the collision was owned by Respondent, Dana Carpenter. After a post-crash investigation, the officer requested Carpenter to submit to a chemical breath test, and Carpenter refused. Following a hearing, an administrative law judge (ALJ) suspended Carpenter's license for refusal to submit to the breath test. The circuit court reversed the suspension, determining that the police officer did not possess reasonable grounds to detain Carpenter. The Court of Appeals reversed the district court, holding that, pursuant to Md. Code Ann. Transp. 16-205.1(b)(2), the ALJ's determination that the police officer had reasonable grounds to detain Carpenter was supported by substantial evidence and was not premised upon an erroneous conclusion of law. Remanded with directions to affirm the decision of the ALJ.

After three separate trials for several criminal offenses, Appellant Benoit Tshiwala was sentenced to an aggregate of seventy years in prison. Appellant subsequently filed an application for review of his sentences, and a three-judge review panel reduced the total period of imprisonment to thirty-nine years. Thereafter, Appellant filed a motion for reconsideration of sentence, which was denied. Appellant then instituted the present action by filing a motion to correct an illegal sentence pursuant to Md. R. Crim. P. 4-345(a), alleging that the three judges who denied reconsideration were not authorized to rule on the motion. The circuit court denied Appellant's motion to correct an illegal sentence. The Supreme Court affirmed, holding that Tshiwala's claim was not cognizable under a motion to correct an illegal sentence because Tshiwala's claim did not involve an "illegal sentence" within the meaning of Rule 4-345(a).

Plaintiffs, each of whom was arrested for a crime that qualified as a serious offense and requested an attorney to represent him or her at the initial appearance, sought a declaration that they and the class of indigent persons they represented had the right, under the federal and state constitutions and the Public Defender Act, to be represented by the public defender at bail hearings, which were conducted as part of the initial appearance before commissioners at the central booking jail. The circuit court granted summary judgment for Plaintiffs, entered a declaratory judgment, and denied Plaintiffs' request for an injunction to enforce the rights declared. The Court of Appeals affirmed, holding (1) the bail hearing that occurs at the initial appearance before a Commissioner is a stage of the criminal proceeding under the Act; and (2) consequently, if a defendant qualifies for public defender representation, a bail hearing may not occur at the initial appearance unless the defendant has been afforded appointed counsel or waived the right to counsel.

Petitioner Rodney Moore was convicted of illegal possession of a regulated firearm and sentenced to five years' imprisonment without possibility of parole. The court of special appeals affirmed. The Court of Appeals granted certiorari and affirmed, holding that the proof of operability of the firearm, as it is defined in Md. Code Ann. Pub. Safety 5-101(h), is not a prerequisite to a conviction of illegal possession of a regulated firearm under Md. Code Ann. Pub. Safety 5-133(c), which prohibits a person convicted of a crime of violence or offenses related to the sale and distribution of controlled dangerous substances from possessing a regulated firearm.

Petitioner Olusegun Ogundipe was charged with multiple crimes stemming from his involvement in an incident in which one man was killed, one man was seriously injured, and one man was assaulted. Following a jury trial in the circuit court, Petitioner was convicted as charged. The court of special appeals affirmed the jury's verdict. The Court of Appeals granted certiorari to answer whether there is a duty of the trial court to disclose a signed verdict sheet to a defendant or his counsel before the jury is discharged. The Court affirmed, holding that the trial court did not err in failing to disclose the contents of the verdict sheet used by the jury in its deliberations before dismissing the jury because the jury verdict sheet is not a communication within the meaning of Md. R. Crim. P. 4-326(d), which requires the court to notify and disclose to counsel any jury communication received before responding to the communication.

Employee filed a complaint against Employer, claiming (1) racial and sex discrimination after Employer required her to undergo an independent medical examination for a gynecological condition, and (2) retaliatory termination of her employment. A jury held for Employee on the issues of sex discrimination and retaliatory termination. Employee was awarded damages and attorney's fees. The court of special appeals reversed, holding that Employee's claims were preempted by the Labor-Management Relations Act, and even if they were not, Employee failed to adduce sufficient evidence of her claims. The Court of Appeals reversed, holding (1) the court of special appeals' erred in determining that Employee's retaliation claim was preempted where it was independent of a collective-bargaining agreement; (2) the court of special appeals erred in its analysis of the comparator evidence in the context of Employee's claim of disparate treatment; (3) Employee presented legally sufficient evidence that she was subject to retaliatory treatment.

Petitioner Gary Smith was convicted at a jury trial of depraved heart second-degree murder and use of a handgun in the commission of a felony. The principle issue at trial was whether the decedent was murdered or committed suicide. Smith appealed, contending, inter alia, that the trial court erroneously excluded certain defense evidence relating to the decedent's state of mind. The Court of Special Appeals affirmed, concluding that the excluded evidence was too remote and not reliable. The Court of Appeals granted certiorari and reversed, holding that the trial court abused its discretion in admitting prosecution evidence of the decedent's 'normal' state of mind but refusing to admit equally relevant defense evidence of the decedent's 'depressed' state of mind. Remanded for a new trial.

Petitioner Gerald Titus was convicted by a jury of obstructing and hindering a police officer in the performance of his duty, driving under the influence of alcohol per se, driving while impaired by alcohol, and giving a false or fictitious name to a uniformed police officer. The Court of Special Appeals affirmed Petitioner's conviction and sentence. The Court of Appeals reversed Petitioner's conviction for obstructing and hindering, holding that the evidence presented by the State at trial with regard to this offense was insufficient to prove the necessary elements beyond a reasonable doubt because there was no evidence at trial to show how Petitioner's conduct actually obstructed or hindered a law enforcement officer in performing his duties.