Justia Civil Rights Opinion Summaries

The Court of Appeals held that ambiguity in a sentencing court's remarks about a juvenile offender's post-offense conduct and character, when made before the Supreme Court issued its decisions governing the sentencing of a juvenile offender to life without the possibility of parole, requires that the offender receive a new sentencing hearing for purposes of the Eighth Amendment.Petitioner was seventeen years old when he committed a series of murders. In Maryland, Petitioner pled guilty to six counts of first-degree murder. The sentencing court sentenced him to the maximum sentence of six terms of life in prison without the possibility of parole. After the Supreme Court decided Miller v. Alabama, 567 U.S. 460 (2012), Petitioner filed a motion to correct an illegal sentence. The circuit court denied the motion. The Supreme Court remanded the case, holding that because opposing inferences could be drawn as to whether the sentencing judge determined that Petitioner was not "the rare juvenile offender whose crimes reflects irreparable corruption" for whom the Eighth Amendment allows a sentence of life without parole. View "Malvo v. State" on Justia Law

The Court of Appeals reversed the decision of the court of special appeals reversing Defendant's conviction of one count of second-degree assault, holding that it was harmless error to fail to propound a voir dire question regarding Defendant's right to remain silent and not testify where Defendant actually testified.During trial, Defendant requested a voir dire question on her right not to testify, but the trial court declined to ask the question. During trial, Defendant testified in her defense. In reversing, the court of special appeals determined that the trial court erred under Kazadi v. State, 467 Md. 1 (2020), and that the error was not harmless. The Court of Appeals reversed, holding (1) the Kazadi error in this case was subject to the harmless error doctrine; and (2) the Kazadi error was harmless. View "State v. Jordan" on Justia Law

The Court of Appeals vacated the judgment of the court of special appeals concluding that Defendant had waived his right to appeal the denial of his suppression motion, holding that Defendant did not waive his right to appeal the suppression ruling.Defendant, who was indicted on charges of possessing a regulated firearm after having been convicted of a crime of violence and other crimes, moved to suppress the gun and loaded magazine that police recovered inside a closed overnight bag during a warrantless search of Defendant's hotel room. The trial judge denied the motion to suppress. Thereafter, the State filed a superseding indictment under a new case number to add additional charges. When Defendant renewed his motion to suppress the transcript and all exhibits from the motion filed in the first case were admitted and incorporated into the record. The handgun and magazine were admitted into evidence during Defendant's ensuing trial. The court of special appeals denied Defendant's appeal, concluding that Defendant waived his right to appeal the suppression ruling by making no objection to the introduction of the challenged evidence at trial. The Court of Appeals vacated the decision below, holding that Defendant did not waive his right to appeal the suppression ruling. View "Huggins v. State" on Justia Law

The Court of Appeals reversed the decision of the court of special appeals reversing the judgment of the circuit court, sitting as the juvenile court, denying D.D.'s motion to suppress evidence of a loaded gun found by law enforcement officers in D.D.'s waistband, holding that there was no constitutional violation in this case.At issue in this case was whether this Court should extend the holding in Lewis v. State, 470 Md. 1 (2020), that the odor of marijuana alone does not provide probable cause to believe that the person is in possession of a criminal amount of the drug, to an investigatory detention. In reversing the juvenile court's denial of D.D.'s suppression motion, the court of special appeals held that the investigatory detention of D.D., which was based solely on the order of marijuana, violated the Fourth Amendment. The Court of Appeals reversed, holding (1) the odor of marijauna provides reasonable suspicion of criminal activity sufficient to conduct a brief investigatory detention; and (2) the officers in the instant case had reasonable suspicion to detain D.D., and therefore, the pat-down that led to the discovery of the gun on D.D. was also reasonable. View "In re D.D." on Justia Law

The Court of Appeals affirmed the decision of the court of special appeals affirming Defendant's convictions for first-degree felony murder, first-degree burglary, and the theft of a Jeep, holding that Defendant was not entitled to relief on his allegations of error.Specifically, the Court of Appeals held (1) Defendant's felony murder conviction was not preempted by the manslaughter by motor vehicle statute; (2) Defendant's sentence of life in prison with the possibility of parole was not unconstitutional under either the Eighth Amendment or Article 25 of the Maryland Declaration of Rights; and (3) Defendant was not entitled to an individualized sentencing proceeding under Miller v. Alabama, 567 U.S. 460 (2012). View "Harris v. State" on Justia Law

The Court of Appeals affirmed the decision of the court of special appeals reversing the ruling of the circuit court that Baltimore City police detective Adam Lewellen had acted within the scope of his employment and that the Baltimore City Police Department was liable for the judgment against him, holding that Plaintiff was not entitled to judgment as a matter of law.Plaintiff sued Lewellen for several torts, and the circuit court found Lewellen liable for negligence, violations of the Maryland Declaration of Rights, and civil conspiracy. The court awarded damages in favor of Plaintiff in the amount of $167,008. The court did not make any finding as to whether Lewellen was acting within the scope of his employment for purposes of the Local Government Tort Claims Act (LGTCA), Md. Code Cts. & Jud. Proc 5-301 et seq. Plaintiff later filed a motion seeking to collect from the Police Department, pursuant to the LGTCA, the damages he had been awarded against Lewellen. The circuit court granted the motion. The court of special appeals reversed, concluding that Plaintiff failed to establish that Lewellen's actions were motivated at least in part to further the Police Department's interests. The Court of Appeals affirmed, holding that the court of special appeals' opinion was unassailable in its analysis and conclusions. View "Esteppe v. Baltimore City Police Department" on Justia Law

The Court of Appeals reversed the judgment of the court of special appeals affirming Defendant's convictions, holding that, under article 21 of the Maryland Declaration of Rights, a statement contained in a scientific report is testimonial if a reasonable declarant would have understood the primary purpose for the creation of the report to be to establish or prove past events potentially relevant to later criminal prosecution.Defendant was indicted on charges of first-, third-, and fourth-degree burglary, theft, and malicious destruction of property. At the scene of the reported burglary, a police officer swabbed the burglar's suspected blood from the window frame and a curtain. Thereafter, Molly Rollo, a forensic scientist, conducted a DNA analysis of the samples and produced a report providing a DNA profile for a male contributor. A subsequent DNA records database search identified Defendant as a possible match. At trial, the court admitted Rollo's report into evidence and allowed a different forensic scientist, Tiffany Keener, to convey the report's results to the jury without requiring that Rollo be available for cross-examination. The Court of Appeals reversed the convictions, holding that the trial court violated Defendant's rights to confrontation and cross-examination under Article 21 of the Maryland Declaration of Rights. View "Leidig v. State" on Justia Law

The Court of Appeals affirmed the judgment of the trial court convicting Defendant of first-degree rape and other offenses, holding that the trial court did not violate Defendant's constitutional rights by allowing the technical review of a report analyzing DNA evidence to testify about the results of that analysis without requiring the primary author of the report to be available for cross-examination.In 2008, an unidentified assailant sexually assaulted a nineteen-year-old woman in her apartment. Forensic evidence was collected from the woman's body and from her apartment, and forensic scientists generated a DNA profile from the evidence for an "unknown male #1." Nine years later, the FBI's Combined DNA Index System produced Defendant as a match for "unknown male #1." Defendant was subsequently convicted with several offenses relating to the sexual assault. Thomas Hebert was the primary author of two reports that analyzed and/or compared DNA evidence relevant to this case. The State did not call Hebert as a witness and instead offered the testimony of two other Forensic Services Division analysts in Hebert's stead. The court of special appeals reversed the convictions, concluding that the trial court violated Defendant's constitutional rights to confrontation. The Court of Appeals reversed, holding that Defendant's constitutional rights were not violated under the circumstances of this case. View "State v. Miller" on Justia Law

The Court of Appeals affirmed Defendant's convictions of numerous criminal offenses related to a drunk driving incident that resulted in the death of a cyclist, holding that Defendant's challenge to the jury selection method in this case was unavailing.On appeal, Defendant argued that the trial judge impermissibly excluded numerous groups of people from his jury without making specific findings of bias or other cause, in violation of his right to an impartial jury. The court of special appeals affirmed the convictions. The Court of Appeals affirmed, holding that there was no indication in the record that any cognizable group was excluded from the jury as a result of the method of jury selection used in this case. View "Kidder v. State" on Justia Law

The Court of Appeals dismissed this appeal of the court of special appeals' denial of an application for leave to appeal in a postconviction proceeding, holding that this Court lacked subject matter jurisdiction pursuant to Md. Code Cts. & Jud. Proc. (CJ) 12-202.Petitioner was found guilty of first-degree murder and other crimes. Nearly ten years after Petitioner was sentenced, he filed a petition for postconviction relief, alleging ineffective assistance of both trial and appellate counsel. The postconviction court denied the petition. Petitioner filed an application for leave to appeal, which the court of special appeals denied without explanation. Petitioner then petitioned the Court of Appeals for writ of certiorari. The Court of Appeals dismissed the appeal for lack of subject matter jurisdiction, holding that CJ 12-202 is not precluded by article IV, section 14A of the Maryland Constitution. View "Mahai v. State" on Justia Law