Justia Civil Rights Opinion Summaries

At issue in this case was whether a law enforcement officer who detects an odor of marijuana emanating from a vehicle with multiple occupants has reasonable articulable suspicion that the vehicle’s occupants are armed and dangerous and thus may frisk the vehicle’s occupants for weapons. The circuit court denied Defendant’s motion to suppress in this case, concluding that the police officer that searched the vehicle in which Defendant was a passenger had reasonable articulable suspicion that Defendant was armed and dangerous. The Court of Special Appeals affirmed. The Court of Appeals reversed, holding (1) an odor of marijuana alone emanating from a vehicle with multiple occupants does not give rise to a reasonable articulable suspicion that the vehicle’s occupants are armed and dangerous and subject to frisk; and (2) at the time of the frisk in this case, there were insufficient circumstances giving rise to reasonable articulable suspicion that Defendant was armed and dangerous to justify the frisk. View "Norman v. State" on Justia Law

Defendant was charged with two counts of first-degree murder and related charges. Defendant filed a motion to suppress statements he made to police during an interrogation at the police department. The circuit court granted Defendant’s motion to suppress statements Defendant made to a police officer before the officer advised Defendant of his Miranda rights. The Court of Special Appeals reversed, concluding that the suppression court had incorrectly determined that, from the outset of the interrogation, Defendant was in custody for purposes of Miranda. The Court of Appeals reversed, holding that Defendant was in custody for purposes of Miranda for the entirety of the interrogation that preceded Miranda warnings, and therefore, the circuit court properly suppressed Defendant’s statements made to the police. View "Brown v. State" on Justia Law

After a jury trial, Petitioner was convicted of first-degree murder and sentenced to life imprisonment. The Court of Special Appeals affirmed. Petitioner appealed, inter alia, the denial of his motion to suppress the statements he made to police officers during his interrogation, arguing that they were obtained in violation of his Miranda right to counsel. The Court of Appeals affirmed, holding (1) the trial judge violated Maryland Rule 4-326(D)(2) by communicating an ex parte answer to a juror’s question without disclosing it to the defendant or any lawyer, but the error was harmless beyond a reasonable doubt; and (2) Petitioner did not invoke his Miranda right to counsel by demanding to see a lawyer from his holding cell before being interrogated, and therefore, the circuit court did not err in denying Petitioner’s motion to suppress the statements he made to detectives during his interrogation. View "Gupta v. State" on Justia Law

After a jury trial, Defendant was convicted of attempted second-degree murder and other offenses. Defendant appealed his conviction of attempted second-degree murder, challenging the trial judge’s finding that defense counsel’s explanations for striking jurors were a pretext for racial discrimination. The Court of Special Appeals affirmed. The Court of Appeals reversed, holding (1) the trial judge’s finding that defense counsel’s peremptory challenges were a pretext for racial discrimination was clearly erroneous; and (2) the evidence was insufficient for a rational trier of fact to find beyond a reasonable doubt specific intent for the crime of attempted second-degree murder. Remanded for a new trial as to all remaining counts except for the count charging attempted second-degree murder. View "Spencer v. State" on Justia Law

Appellant was convicted of conspiracy to commit murder and sentenced to life imprisonment. Appellant filed a pro se petition for postconviction DNA testing of a broom and dust pan pursuant to Md. Code Ann. Crim. Proc. (CP) 8-201. The postconviction court dismissed the petition, concluding that Appellant did not have standing to file a petition under CP 8-201(b) because he was not convicted of a crime of violence. The Court of Appeals affirmed, holding (1) a defendant convicted of conspiracy to commit murder is not eligible to file a petition for postconviction DNA testing under CP 8-201(b); and (2) the postconviction DNA testing statute does not violate due process or equal protection rights under the United States Constitution or the Maryland Declaration of Rights. View "Washington v. State" on Justia Law

After a trial, Defendant was found guilty of possession of cocaine with intent to distribute and possession of a firearm during a drug trafficking crime. Defendant appealed, arguing that the trial court erred in denying his motion to suppress evidence obtained after a Terry frisk because the law enforcement officers did not have reasonable suspicion to justify the frisk. The Court of Special Appeals affirmed the denial of the motion to suppress, concluding that the facts created reasonable suspicion that Defendant was armed and dangerous and that he had committed or was planning to commit a crime. The Court of Appeals reversed, holding that, under the totality of the circumstances, the officers did not have reasonable articulable suspicion to frisk Defendant, and therefore, the Court of Special Appeals erred in concluding that the evidence was correctly suppressed. View "Sellman v. State" on Justia Law

Defendant was indicted for several drug offenses. Defendant filed a motion to suppress evidence seized by police officers from his person, alleging that his detention in handcuffs while in a car that he had been driving was searched constituted an unlawful arrest and that the evidence obtained by the officers were the fruits of that arrest. The motion to suppress was denied. Defendant entered a conditional guilty plea to one count of possession of cocaine with intent to distribute. The Court of Appeals affirmed, holding (1) the police officers possessed reasonable suspicion to stop Defendant and ask him to leave the vehicle based upon their belief that Defendant may have been armed and dangerous; and (2) the use of handcuffs per se does not ordinarily transform a Terry stop into an arrest, and the continued use of handcuffs by the police officers in this case constituted a Terry stop because of an ongoing concern for officer safety. View "Chase v. State" on Justia Law

This case centered around Petitioner’s written request under Maryland Public Information Act (MPIA) for information regarding the value of unclaimed property accounts in the custody of the Comptroller of Maryland. The Comptroller decided that the requested information was prohibited under the MPIA. The circuit court ordered the Comptroller to disclose the requested records in value order. The Court of Appeals affirmed in part and reversed in part, concluding that Petitioner was entitled to a list of claims but not sorted by value. On remand, the circuit court ordered the Comptroller to submit a modified MPIA request limited to certain accounts without sorting any by value. The Court of Special Appeals affirmed. The Court of Appeals affirmed, holding that the MPIA prohibited disclosure of the comparative value of accounts in the Comptroller’s custody. View "Immanuel v. Comptroller" on Justia Law

After a deputy sheriff stopped Petitioner for a traffic violation, the officer inserted his head into the passenger side window of Petitioner’s vehicle. The officer detected the odor of marijuana, and Petitioner was placed under arrest. Petitioner filed a motion to suppress, arguing that an unconstitutional search occurred when the officer inserted his head into the passenger window. The circuit court denied Petitioner’s suppression motion. The court then found Petitioner guilty of possession of marijuana. The Court of Special Appeals affirmed. The Court of Appeals reversed, holding that the circuit court erred in denying Petitioner’s motion to suppress because the evidence was unclear regarding the timing of the officer’s detection of the odor of marijuana, and in the absence of a finding that the officer detected the odor of marijuana before he inserted his head into the window, the State failed to satisfy its burden to show that the search was lawful. View "Grant v. State" on Justia Law

A clinical review panel authorized the forced medication of Petitioner, a resident of a facility operated by the Department of Health and Mental Hygiene. An administrative law judge (ALJ) affirmed. Petitioner sought judicial review, arguing that, on its face, Md. Code Ann. Health-Gen. (HG) 10-708(g) violates the Maryland Declaration of Rights by permitting forced medication without a showing that an individual is dangerous to himself or others. The circuit court affirmed the ALJ’s decision. The Court of Appeals affirmed, holding (1) HG 10-708(g) is not unconstitutional on its face; but (2) the authorization for involuntary medication may only be constitutionally carried out when an overriding justification exists. View "Allmond v. Dep’t of Health & Mental Hygiene" on Justia Law