Justia Civil Rights Opinion Summaries

After a jury trial, Petitioner, a dentist, was convicted of various sexual crimes against a minor patient. In the circuit court, while self-represented, Petitioner filed a petition for DNA testing, requesting that the clothes the victim wore on the day of her rape be tested. After a hearing, the circuit court denied the petition. Petitioner appealed, arguing that, under Maryland Rule 4-707(b), he was entitled to appointed counsel at the hearing on the petition. The Court of Appeals affirmed, holding (1) Rule 4-707(b) does not entitle an indigent petitioner to be appointed counsel for the purposes of a petition under Md. Code Ann. Crim. Proc. 8-201; (2) the circuit court did not abuse its discretion in not considering whether to appoint counsel for Defendant for purposes of the petition under section 8-201; and (3) the circuit court applied the correct standard in ruling on the petition under section 8-201. View "Fuster v. State" on Justia Law

In two separate cases, Petitioner was convicted of second-degree murder and two counts of solicitation to obstruct justice, among other offenses. The cases were consolidated for appeal, and the court of special appeals affirmed. At issue before the Court of Appeals, among other things, was whether the trial court abused its discretion in disqualifying one of Petitioner’s defense counsel, who had a previous attorney-client relationship with a key state’s witness, where the witness refused to waive the conflict of interest and Petitioner’s counsel had arranged for co-counsel to cross-examine the witness. The Court of Appeals affirmed, holding (1) the trial court did not abuse its discretion in disqualifying Petitioner’s attorney, as Petitioner’s waiver of the conflict was not sufficient to cure the conflict; and (2) merger was precluded for convictions of the two counts of solicitation, where the relevant statutes contained parallel anti-merger provisions. View "Alexis v. State" on Justia Law

Petitioner was charged with certain traffic offenses in the district court. The district court acquitted Petitioner as to the charge of disobeying a lawful order or direction of a police officer but convicted Petitioner of four counts of fleeing and eluding police. Petitioner filed notice of a de novo appeal. Prior to trial, Petitioner filed a motion to dismiss the fleeing and eluding counts, arguing that, because he was acquitted of disobeying a lawful order, prosecution of the fleeing and eluding charges would violate the state and federal prohibitions against double jeopardy. The circuit court denied the motion. The Supreme Court affirmed, holding that prosecution of the fleeing and eluding charges did not violate the prohibitions against double jeopardy or the doctrine of collateral estoppel. View "Scriber v. State" on Justia Law

After a jury trial, Petitioner was found guilty of two counts of first-degree murder and related offenses. Petitioner appealed the denial of his motion to suppress the contents of a storage locker belonging to him, arguing that it was the tainted fruit of the consent he had given to police while he was unlawfully detained at the police station. The court of special appeals affirmed the conviction. The Court of Appeals affirmed, holding (1) the police obtained Petitioner’s consent to search his locker during their lawful detention of him; and (2) therefore, the suppression court correctly ruled that Petitioner was not entitled to suppression of the evidence found in the locker. View "Barnes v. State" on Justia Law

Defendant was charged with misuse of telephone facilities and harassment. Prior to the start of trial, Defendant’s public defender informed the court: “Your Honor, on behalf of [Defendant], I’d request a postponement. He indicates that he would like to hire private counsel in this matter.” The trial judge denied postponement, and, after a trial, Defendant was convicted as charged. Defendant appealed, arguing that reversal was required because the trial court denied his request to obtain private counsel without complying with the requirements of Md. R. Crim. P. 4-215(e). The court of appeals affirmed, concluding that Defendant did not express a “clear intent” to discharge or replace his attorney, and therefore, Rule 4-215(e) was not implicated. The Court of Appeals reversed, holding (1) when an ambiguous statement by a defendant or his or her counsel is made under Rule 4-215(e), the trial judge must engage in a Rule 4-215(e) colloquy with the defendant; and (2) in this case, the trial judge could have reasonably concluded from defense counsel’s statements that Defendant wanted to discharge his attorney and thus had a duty to engage in a Rule 4-215(e) colloquy with Defendant. View "Gambrill v. State" on Justia Law

The State charged Petitioner with various drug-related crimes. Petitioner’s co-defendant filed three proposed voir dire questions asking whether any prospective juror had ever been the victim of a crime or a member of a law enforcement agency. The circuit court declined to ask any of the proposed voir dire questions. The jury ultimately convicted Petitioner of drug-related crimes. The court of special appeals affirmed. The Court of Appeals reversed, holding (1) a trial court need not ask during voir dire whether any prospective juror has ever been the victim of a crime, but, on request, a trial court must ask whether any of the prospective jurors have strong feelings about the crime with which the defendant is charged; and (2) where all of the State’s witnesses are members of law enforcement agencies and/or where the basis for a conviction is reasonably likely to be the testimony of members of law enforcement agencies, on request, a trial court must ask during voir dire whether any of the prospective jurors have ever been a member of a law enforcement agency. View "Pearson v. State" on Justia Law

Petitioner was charged with various offenses, including reckless endangerment. Because the indictment did not set out the elements of the charged offense or the factual basis for that offense, Petitioner requested that the State provide him with a bill of particulars. Rather than answer each question Petitioner asked in his request, the State simply directed Petitioner to discovery. The trial court overruled Petitioner’s exceptions, finding that the State’s responses satisfied the statutory requirement that the State’s response “furnish the particulars sought.” A jury found Petitioner guilty of reckless endangerment. Petitioner appealed, arguing that the trial court abused its discretion by denying his exceptions to the State’s non-specific responses to the questions posed in his request for a bill of particulars. The court of special appeals affirmed. The Court of Appeals reversed, holding (1) the State’s responses to the questions posed in Petitioner’s demand for a bill of particulars were inadequate; and (2) therefore, the trial court abused its discretion when it overruled Petitioner’s exceptions to those responses. View "Dzikowski v. State" on Justia Law

In two cases, Montgomery County took a portion of properties owned by Respondents. Because the parties disputed the value paid for either taking the County filed a complaint for condemnation. During the proceedings, the circuit court imposed discovery violation sanctions precluding Respondents from introducing evidence as to the fair market value of the taken properties. Respondents were therefore unable to generate a genuine issue of material fact concerning the County's appraisal valuations. As a result, the circuit court granted summary judgment for the County on the issue of just compensation. The court of special appeals reversed, concluding that summary judgment on the question of just compensation is not available in condemnation proceedings because a property owner cannot be deprived of the constitutional right to have a jury determine just compensation. The Court of Appeals reversed, holding (1) permitting summary judgment does not violate the constitutional right to have the opportunity for a jury trial to ascertain just compensation in compensation actions provided the landowner litigates the case according to the Maryland Rules; and (2) summary judgment was properly granted in each case because there was no genuine dispute of material fact and the County was entitled to judgment as a matter of law. View "Montgomery County v. Soleimanzadeh" on Justia Law

Petitioner was charged in two cases with second-degree burglary, theft, and malicious destruction of property. Petitioner moved to suppress all evidence obtained as the result of law enforcement's global positioning system (GPS) tracking of his vehicle. The motions were denied, and Petitioner was convicted of various charges arising out of the two cases. While Petitioner's appeal of the convictions was pending, the U.S. Supreme Court decided United States v. Jones, which held that GPS tracking of a vehicle constitutes a search under the Fourth Amendment. The court of special appeals affirmed the consolidated appeals. The Court of Appeals affirmed, holding that Petitioner was not entitled to the suppression of evidence where (1) before Jones, binding appellate precedent in Maryland authorized the GPS tracking of a vehicle on public roads; (2) law enforcement officers acted in objectively reasonable reliance on that authority when they conducted their GPS tracking of Petitioner's vehicle; and (3) the Davis v. United States good-faith exception to the exclusionary rule applied in this case. View "Kelly 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 the conviction. The Supreme Court affirmed, holding that trial court (1) complied with Md. Code Ann. Crim. Proc. 3-104(a) when it allowed Petitioner to withdraw his request for a competency evaluation and afterwards did not make a competency determination on the record, because Petitioner's withdrawal of his request for a competency evaluation, in addition to the slight evidence on the record to support a finding of incompetency, supported the circuit court's acknowledgment that the issue of competency was moot and the presumption that Petitioner's competency was not rebutted; and (2) properly denied Petitioner's request for an instruction on legally adequate provocation because the evidence presented did not generate such a defense. View "Wood v. State" on Justia Law