Justia Constitutional Law Opinion Summaries

Articles Posted in Maryland Court of Appeals
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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

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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

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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

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The Court of Appeals answered a certified question of law by concluding that the then-Chief Judge Mary Ellen Barbara of the Court of Appeals acted within her authority and consistently with the Maryland Constitution when she issued an administrative order temporarily tolling statutes of limitations under Maryland law with respect to civil actions during the COVID-19 pandemic.On April 24, 2020, the Chief issued an administrative order that temporarily tolled statutes in civil cases during the state of emergency created by the COVID-19 pandemic. In a commercial dispute between the parties in this case, the timeliness of certain claims and the diversity jurisdiction of the federal court depended on the validity of the Chief Justice's administrative tolling order and whether the order violated the Maryland Declaration of Rights. The Court of Appeals held that the Chief Justice acted within her authority when she issued the administrative tolling order concerning the timeliness of the complaints filed in Maryland during the pandemic. View "Murphy v. Liberty Mutual Insurance Co." on Justia Law

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In this dispute between a municipality seeking tax setoffs and a county that refused to grant them, the Court of Appeals affirmed the conclusion of the court of special appeals that Md. Code Tax-Prop. ** 6-305 and 6-306 do not fall within a category of constitutionally prohibited legislation, holding that the provisions are permissible within the scope of article XI-E, 1 of the Maryland Constitution.Ocean City, the second largest municipality in Worcester County, repeatedly requested tax setoffs for the money that the city spent on governmental services, such as fire, police, and ambulance services. In lieu of granting Ocean City's requested tax setoffs, Worcester County provided discretionary funding to the city in the form of annual grants. Ocean City then filed this action seeking a declaratory judgment that TP 6-305 and 6-305, which granted the county the ability to deny municipal tax setoff requests, were unconstitutional as violating Md. Const. Art. XI-E, 1. The circuit court granted summary judgment in favor of Worcester County. The court of special appeals affirmed. The Court of Appeals affirmed, holding that TP 6-305 and 6-306 are constitutional within the language of Article XI-E, Section 1. View "Ocean City v. Worcester County" on Justia Law

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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

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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

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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

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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

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The Court of Appeals affirmed the judgment of the court of special appeals affirming Defendant's conviction of murder and attempted murder, holding that Defendant knowingly and voluntarily waived his rights under Miranda and that the circuit court correctly determined that a jury instruction on duress was unwarranted.Before trial, Defendant moved to suppress his confession to a law enforcement officer. The circuit court denied the motion, concluding that Miranda had been complied with and that Defendant's confession was voluntary. The court of special appeals affirmed. The Court of Appeals affirmed, holding (1) Defendant knowingly and voluntarily waived his rights under Miranda, his confession was voluntary, and his circumstances did not render his waiver of rights involuntary; and (2) the circuit court did not err in declining to give a jury instruction on duress because the instruction was unwarranted. View "Madrid v. State" on Justia Law