Justia Civil Rights Opinion Summaries

In 2010, Respondent, a citizen of Ecuador, pled not guilty on an agreed statement of facts and was found guilty of second-degree child abuse. In 2013, Respondent filed a petition for writ of error coram nobis alleging that his trial counsel had rendered ineffective assistance by failing to advise him regarding the immigration consequences he could face as a result of conviction. The coram nobis court denied the petition. The Court of Special Appeals reversed and remanded, concluding that Respondent established that trial counsel did not provide him with the correct “available advice” about the risk of deportation. The Court of Appeals reversed, holding that trial counsel did not perform in a constitutionally deficient manner in advising Respondent as to the immigration consequences of a conviction for second-degree child abuse. View "State v. Sanmartin Prado" on Justia Law

In cases consolidated for this appeal, defendants were found guilty but not criminally responsible at the time of the commission of the offense and were committed to the Department of Health and Mental Hygiene. The court granted conditional releases on various occasions but each conditional release was subsequently revoked, resulting in recommitment to DHMH for treatment. The Maryland Court of Appeal held that the Circuit Court erred in determining that the statutory scheme, Criminal Procedure Article 3-114, for granting or revocation of the conditional release of a committed person violated the separation of powers provision found in Article 8 of the Maryland Declaration of Rights. The court also erred in revoking defendant’s conditional release and ordering his continued commitment for institutional inpatient care and treatment after the ALJ had found that defendant was eligible for conditional release and had recommended the same. The court held that under CP 3-114 the substantial evidence standard applies to a circuit court’s review of an ALJ’s findings of facts and recommendations. View "Stoddard v. State" on Justia Law

The Advice of Rights form assists law enforcement officers with making the advisements that are required by Md. Code, Transp. 16-205.1,2, (the implied consent, administrative per se law), which provides a basis for the automatic suspension of the licenses of drivers who refuse to submit to testing for alcohol and drugs. Seenath, a holder of a commercial driver’s license, argued that the Advice form violated due process under the U.S. Constitution and the Maryland Declaration of Rights because it does not advise that a holder of a commercial driver’s license who drives a non-commercial motor vehicle and fails an alcohol concentration test is ineligible for a “restrictive license,” which allows a driver to drive only for certain purposes, for example, in the course of employment. The Motor Vehicle Administration asked the Maryland Court of Appeal: “Does the standard Advice of Rights form (DR-15) provide the necessary information to a driver who holds a commercial driver’s license of the consequences of submitting to a test of blood alcohol content if the driver’s results are 0.08 or more?” That court responded “yes,” and held that the form is not misleading as to the eligibility for a restrictive license of a holder of a commercial driver’s license and comports with due process. View "Motor Vehicle Admin. v. Seenath" on Justia Law

After a joint jury trial, Petitioner was found guilty of second degree murder, conspiracy to commit murder, and use of a handgun in the commission of a crime of violence. The court of special appeals affirmed. Petitioners filed a petition for writ of certiorari, arguing that the prosecutor’s response to an allegation of racial and gender discrimination in the exercise of a peremptory challenge did not satisfy the requirement of Batson v. Kentucky that the State provide a specific explanation for each challenged strike which is racially, and with respect to gender, neutral. The Court of Appeals reversed, holding that the prosecutor’s explanation for striking the juror at issue, in addition to lacking the requisite specificity, violated Batson because the explanation was neither race- nor gender-neutral. Remanded for a new trial. View "Ray-Simmons v. State" on Justia Law

In 2012, the Maryland Department of Health and Mental Hygiene (DHMH) adopted new procedures regarding the application process for surgical abortion facilities, including the requirement that individuals and other entities obtain a license from the Secretary of DHMH before establishing or operating such a facility. In 2013, Petitioner, pursuant to the Public Information Act, requested the records of all applications submitted for a license under these regulations. DHMH responded by providing copies of the applications but with certain information redacted. DMHM filed a petition seeking judicial confirmation for its continued denial of the information. The circuit court granted the petition, indicating that DHMH’s decision to redact was made on the basis of public safety concerns for those individuals who proposed to operate the facilities. The court of special appeals affirmed. The Court of Appeals affirmed, holding that redaction and denial of the relevant information in this case was necessary to protect the public interest from a substantial injury. View "Glenn v. Dep’t of Health & Mental Hygiene" on Justia Law

Petitioner was convicted of first degree murder and sentenced to life imprisonment. The Court of Special Appeals affirmed. Two issues were presented in this appeal, first, whether Petitioner’s statement, “I don’t want to say nothing. I don’t know” was an ambiguous or clear invocation of his right to remain silent under Miranda, and second, whether Petitioner’s confession, given after he waived his Miranda rights, was voluntary or the product of inducement. The Court of Appeals affirmed, holding (1) Petitioner’s statement, “I don’t want to say nothing. I don’t know” was an ambiguous invocation of his right to remain silent; and (2) Petitioner’s confession was voluntary. View "Williams v. State" on Justia Law

Appellant owned property located within the heart of a planned development. The City of Baltimore sought to condemn the property. When the City and Appellant were unable to agree upon a price to be paid for the property, the City filed a petition for condemnation. Prior to trial, the City filed a petition for immediate possession and title, alleging that immediate possession of the property was necessary. Ultimately, the circuit court concluded that Appellant was a “hold-out,” which justified a “quick-take” condemnation of the property. The Court of Appeals affirmed, holding that the facts of this case justified a “quick-take” condemnation action. View "Makowski v. Mayor & City of Baltimore" on Justia Law

Defendants in this case were charged with criminal offenses, and both defendants waived their right to a jury trial. After bench trials, Defendants were found guilty and sentenced. Each defendant appealed, challenging the trial court’s acceptance of his jury trial waiver. Relevant to this consolidated appeal, the courts of special appeals held that the trial courts sufficiently satisfied the announcement requirement under Md. Rule 4-246(b). The Court of Appeals reversed in part, holding (1) so long as a trial judge determines that a jury trial waiver is made both “knowingly” and “voluntarily,” or uses synonyms that represent the same concepts, the court will have complied fully with Rule 4-246(b); (2) in both cases under review, the trial judges failed to comply with Rule 4-246(b); and (3) to the extent that Valonis v. State could be read to hold that a trial judge’s alleged noncompliance with Rule 4-246(b) is reviewable by the appellate courts despite the failure to object at trial, that interpretation is disavowed. Remanded for new trials. View "Nalls v. State" on Justia Law

After a bench trial, Defendant was convicted of first, third, and fourth degree burglary, theft under $1000, and malicious destruction of property having a value of less than $500. Defendant appealed, challenging the trial judge’s acceptance of his jury trial waiver. The court of special appeals affirmed, concluding that the trial judge sufficiently satisfied the announcement requirement under Md. Rule 4-246(b). The Court of Appeals reversed, holding (1) because the trial judge’s announcement did not state that Defendant’s jury trial waiver was both knowing and voluntary, the judge did not comply with Rule 4-246(b); and (2) the appropriate sanction for the judge’s noncompliance with Rule 4-246 was reversal. View "Szwed v. State" on Justia Law

Petitioner was charged with two counts each of possession of cocaine and distribution of cocaine. On the day of trial, Petitioner waived his right to a jury. Petitioner then pled not guilty as to one of the distribution charges. After a plea colloquy, the trial court found the plea to be “knowing and voluntary.” Petitioner was found guilty of distribution of cocaine after a bench trial. Petitioner appealed, contesting the validity of the court’s acceptance of his jury trial waiver. The court of special appeals affirmed. The Court of Appeals affirmed, holding that the trial court’s announcement after the plea colloquy that Petitioner’s actions were “knowing and voluntary” was sufficient to establish that the judge analyzed the disposition and appearance of Petitioner in order to determine Petitioner’s actual understanding and voluntariness for both the jury waiver and the plea. View "Morgan v. State" on Justia Law