Justia Constitutional Law Opinion Summaries

Petitioner was charged with conspiracy to commit theft, making a false statement to the police while under arrest, and related offenses after the vehicle in which he was an occupant was stopped by police officers and the police discovered multiple fake credit cards in the wallet of a female passenger. The police then arrested all occupants of the vehicle. Petitioner filed a motion to suppress, contending that the evidence was obtained as a result of an illegal stop. The circuit court denied the motion to suppress. Defendant appealed, contending that his Fourth Amendment rights were violated because the police lacked probable cause to arrest him. The court of special appeals held that police had probable cause to arrest Petitioner and therefore any evidence obtained by police as the fruit of that arrest was not subject to suppression. The Supreme Court affirmed, holding that Petitioner's claim was not properly before the appellate courts because Petitioner waived it by not raising it before the circuit court. View "Ray v. State" on Justia Law

The supervisory employee exception to the handgun law allows such an employee to carry a handgun, with the employer's permission, within the enclosed premises of the business in which the employee works. Petitioner, the head of security for a nightclub, was arrested by the county police for carrying a handgun without a permit in the open parking lot of the nightclub. Petitioner filed a lawsuit against the county and three of the police officers involved in his arrest for a violation of the Maryland Declaration of Rights, false arrest and imprisonment, and malicious prosecution, contending that his arrest was illegal because the parking lot should be considered to be "within the confines" of the nightclub. A jury found in favor of Petitioner on his state constitutional claim and on the false arrest and imprisonment claim. The court of special appeals reversed, holding that the parking lot of the club was not "within the confines of the business establishment." The Court of Appeals affirmed, holding that when Petitioner left the "confines" of the nightclub and took his handgun into the parking lot, he was no longer with the supervisory employee exception to the handgun law. View "Blue v. Prince George's County" on Justia Law

Petitioner owned land in the Town of Goldsboro in Caroline County. Lake Bonnie provided the water source for the property, on which Petitioner operated a campground. In the mid-1990s, the Maryland Department of Environment (MDE) reported water quality impacts on Lake Bonnie due to failing septic systems in the Town and ordered the Town to take action regarding the septic systems. As of 2010, however, the Town had failed to comply with the order, and MDE had failed to enforce the order. Consequently, Lake Bonnie was polluted, the campground was destroyed, and the bank foreclosed on Petitioner's property. Petitioner sued the Town, County, MDE, and State, alleging several causes of action. All counts were dismissed against the Town, County, and State. The court of appeals affirmed. The Supreme Court affirmed in part and reversed in part, holding (1) because it was not clear from the face of her complaint that Petitioner's causes of action for negligence, trespass, and inverse condemnation were barred by limitations, the court of special appeals erred in affirming the motion to dismiss on those counts; and (2) Petitioner's causes of action for nuisance were barred by limitations, and the court of appeals correctly affirmed the motion to dismiss. View "Litz v. Md. Dep't of Env't" on Justia Law

Defendant was charged with murder and expressed a desire to have a bench trial. During the jury trial waiver colloquy, the trial judge provided Defendant with advice that the judge was not required to give Defendant and that was also erroneous. After a jury-waived trial, Defendant was convicted of first degree murder and sentenced to life imprisonment. Defendant appealed, arguing that his waiver of the right to a jury trial was not knowing and voluntary. The Court of Appeals reversed and remanded for a new trial, holding (1) the trial judge's erroneous advisement may have misled Defendant to believe a jury trial was a less attractive option than it actually was, thereby influencing Defendant's decision to waive his jury trial right; and (2) accordingly, the trial judge did not ensure that Defendant's waiver was knowing. View "Winters v. State" on Justia Law

In 1999, Petitioner pled guilty to a drug offense. Petitioner subsequently filed a petition for a writ of error coram nobis, asserting that his guilty plea was not voluntarily made due to his counsel's failure to advise him of the possible immigration consequences of his plea. The circuit court denied the petition. While Petitioner's appeal was pending, the U.S. Supreme Court decided Padilla v. Kentucky. On appeal, the court of special appeals determined that Padilla did not retroactively apply to vacate Petitioner's conviction. The Court of Appeals reversed. On remand, the court of special appeals again affirmed the denial of Petitioner's petition because Petitioner had not raised the issue of ineffective assistance of counsel in his plea. The Court of Appeals granted certiorari, but prior to oral argument, the U.S. Supreme Court held that Padilla did not apply retroactively. The Court of Appeals affirmed the denial of Petitioner's petition for coram nobis relief, holding that Petitioner's claims of involuntariness or ineffective assistance of counsel did not have independent state bases in Maryland in 1999. View "Miller v. State" on Justia Law

In 2003, Appellant was convicted of rape. The Court of Appeals reversed, holding that the Maryland DNA Collection Act, which permits law enforcement authorities to collect DNA samples from individuals arrested for certain crimes, violated the Fourth Amendment as applied to Appellant. The U.S. Supreme Court reversed, holding that the DNA search of Appellant did not violate his Fourth Amendment rights. On remand, Appellant asked the Court to consider the issues left unresolved by King I. The Court of Appeals held (1) the Maryland DNA Collection Act does not violate Article 26 of the Maryland Declaration of Rights; and (2) the trial judge did not improperly shift the burden of proof to the defense to demonstrate how the State failed to comply with the Act, and even if a statutory violation were proven, there was no reversible error. View "King v. State" on Justia Law

Plaintiffs, each of whom was arrested for a crime and brought before a District Court Commissioner for an initial appearance, filed a complaint against the District Court of Maryland and several court officials alleging that they were denied public defender representation during their initial appearance proceedings. Plaintiffs contended that the initial appearance proceeding is a critical stage of the criminal proceeding requiring state-furnished counsel pursuant to the Public Defender Act (Act) and that the failure to provide counsel violated their due process rights. The Court of Appeals held that the Act required the public defender to represent indigent criminal defendants at the initial appearance proceedings. While motions for reconsideration of the Court's opinion were pending, the General Assembly passed statutes amending the Act to provide that representation was not required to be furnished to an indigent individual at an initial appearance before a district court commissioner. The Court proceeded to hold that, under the due process component of the Maryland Declaration of Rights, an indigent defendant has a right to state-furnished counsel at an initial appearance before a district court commissioner. Remanded. View "DeWolfe v. Richmond " on Justia Law

After a jury trial, Petitioner was convicted of first degree murder and conspiracy to commit first degree murder. Petitioner unsuccessfully filed a petition for post-conviction relief, alleging ineffective assistance of counsel, after which he unsuccessfully filed an application for leave to appeal. Thereafter, Petitioner filed a motion for reconsideration, which the intermediate appellate court granted. The appellate court then determined that the application lacked merit because Petitioner was not prejudiced by the alleged errors of his counsel. The Court of Appeals reversed, holding that Petitioner received ineffective assistance of counsel when his trial counsel failed to object to approximately thirty instances during trial when the State admitted evidence that Petitioner had remained silent in the face of custodial police questioning after Petitioner had been issued Miranda warnings. Remanded. View "Coleman v. State" on Justia Law

After a jury trial, Defendant was convicted of second degree rape, second degree assault, and multiple counts of second, third, and fourth degree sexual offenses. The Court of Appeals affirmed, holding (1) the trial court did not err in allowing a DNA analyst to testify regarding the analysis of another DNA analyst, who did not testify at trial, and did not err in admitting the non-testifying analyst's report into evidence, as (i) the State met its burden of showing chain of custody of a napkin, from which DNA was found connecting Defendant to the victim, (ii) admitting the report of the non-testifying analyst did not violate the rule against hearsay, and (iii) admitting he report did not violate Defendant's right to confrontation; and (2) the trial judge did not err in admitting hearsay statements of the victim as excited utterances through the testimonies of the victim's roommate and the investigating officer. View "Cooper v. State" on Justia Law

After a jury trial, Defendant was convicted of multiple sexual offenses relating to an attack and rape of a woman. The Court of Appeals affirmed, holding (1) the evidence was sufficient to sustain Defendant's conviction; (2) Defendant's constitutional confrontation rights were not violated when the State's expert witness presented the results of forensic tests as the basis for her conclusion that Defendant was the source of the DNA found on vaginal swabs taken from the rape victim; (3) Defendant's rights to discovery were not violated by the trial court's refusal to order the State to conduct a search for coincidental matches in the FBI's Combined DNA Index System; and (4) the trial court did not err in refusing to include Defendant's proposed jury instruction on the definition of "reasonable degree of scientific certainty." View "Derr v. State" on Justia Law