need test in Maryland

2024Inc., 867 F.3d 434, 441 (3d Cir. 2017) (“Affidavits, in combination with records or other reliable and administratively feasible means, can meet the ascertainability standard.”). 33 Because we decide that the circuit court erred in not addressing the merits of the Tenants’ Second Class Motion, we need not address the Appellate Court’s reliance on our decision in Chavis.

2024In an appropriate case, a court could reasonably exercise its discretion to refuse to consider subsequent motions. 57 The need to review Westminster’s tenant ledgers to identify whether tenants were charged particular fees is not necessarily the same as requiring mini-trials, at least as long as review of the corporate records would produce an objective answer concerning whether the tenants were charged those fees without the need to test the evidence extensively or resolve complex disputes.33 See id. at 358 (“A class cannot be certified unless a court can readily identify the class members in

2024See, e.g., People v. Douglas, 22 Cal. App. 5th at 1174 , 232 Cal. Rptr. 3d at 314 .

2024See, e.g., People v. Douglas, 22 Cal. App. 5th at 1174 , 232 Cal. Rptr. 3d at 314 .

2020But we can be reasonably certain that, had trial counsel objected, the trial court would have fleshed out its rationale for admitting 18 State v. Faulkner, 314 Md. 630, 634-35 (1989), sets forth a three-step analysis a trial court should undertake when faced with a motion to admit other crimes evidence. 19 the tire-slashing testimony.

2017Crosby v. State, 408 Md. 490, 508 , 970 A.2d 894, 904 (2009).

2017Crosby v. State, 408 Md. 490, 508 , 970 A.2d 894, 904 (2009).

2015Under the “special needs” doctrine, “[a] search unsupported by probable cause can be constitutional . . . when special needs, beyond the normal need for law enforcement, make the warrant and probable-cause requirement impracticable.” Griffin v. Wisconsin, 483 U.S. 868, 873 (1987) (internal quotation marks omitted); see also Ashcroft v. al-Kidd, 131 S. Ct. 2074 , 2081 (2011) (citing examples, including the need to test train operators to ensure that they are not under the influence of drugs or alcohol).

2015In order for this exception to apply, the State’s “special need” for the search must be “divorced from the State’s general interest in law enforcement.” Ferguson v. City of Charleston, 532 U.S. 67, 79 (2001).

2015Under the “special needs” doctrine, “[a] search unsupported by probable cause can be constitutional . . . when special needs, beyond the normal need for law enforcement, make the warrant and probable-cause requirement impracticable.” Griffin v. Wisconsin, 483 U.S. 868, 873 (1987) (internal quotation marks omitted); see also Ashcroft v. al-Kidd, 131 S. Ct. 2074 , 2081 (2011) (citing examples, including the need to test train operators to ensure that they are not under the influence of drugs or alcohol).

1999See, e.g., People v. Holt, 15 Cal.4th 619, 663 , 63 Cal.Rptr.2d 782, 811 , 937 P.2d 213, 242 (rejecting the defendant’s argument that tape recording of statement made during a custodial interrogation is required to ensure fundamental fairness because “a confession may not be the voluntary ‘product of a rational intellect and a free will,’ and the need to test the voluntariness of a confession on the basis of ‘the totality of all the surrounding circumstances—both the characteristics of the accused and the details of the interrogation’ ”) (citation omitted), cert. denied, — U.S.-, 118 S.Ct. 606

1999See, e.g., People v. Holt, 15 Cal.4th 619, 663 , 63 Cal.Rptr.2d 782, 811 , 937 P.2d 213, 242 (rejecting the defendant's argument that tape recording of statement made during a custodial interrogation is required to ensure fundamental fairness because "a confession may not be the voluntary `product of a rational intellect and a free will,' and the need to test the voluntariness of a confession on the basis of `the totality of all the surrounding circumstances—both the characteristics of the accused and the details of the interrogation'") (citation omitted), cert. denied, ___ U.S. ___, 118 S.Ct.

1999See, e.g., People v. Holt, 15 Cal.4th 619, 663 , 63 Cal.Rptr.2d 782, 811 , 937 P.2d 213, 242 (rejecting the defendant’s argument that tape recording of statement made during a custodial interrogation is required to ensure fundamental fairness because “a confession may not be the voluntary ‘product of a rational intellect and a free will,’ and the need to test the voluntariness of a confession on the basis of ‘the totality of all the surrounding circumstances—both the characteristics of the accused and the details of the interrogation’ ”) (citation omitted), cert. denied, — U.S.-, 118 S.Ct. 606

1999See, e.g., People v. Holt, 15 Cal.4th 619, 663 , 63 Cal.Rptr.2d 782, 811 , 937 P.2d 213, 242 (rejecting the defendant's argument that tape recording of statement made during a custodial interrogation is required to ensure fundamental fairness because "a confession may not be the voluntary `product of a rational intellect and a free will,' and the need to test the voluntariness of a confession on the basis of `the totality of all the surrounding circumstances—both the characteristics of the accused and the details of the interrogation'") (citation omitted), cert. denied, ___ U.S. ___, 118 S.Ct.

1999See, e.g., People v. Holt, 15 Cal.4th 619, 663 , 63 Cal.Rptr.2d 782, 811 , 937 P.2d 213, 242 (rejecting the defendant’s argument that tape recording of statement made during a custodial interrogation is required to ensure fundamental fairness because “a confession may not be the voluntary ‘product of a rational intellect and a free will,’ and the need to test the voluntariness of a confession on the basis of ‘the totality of all the surrounding circumstances—both the characteristics of the accused and the details of the interrogation’ ”) (citation omitted), cert. denied, — U.S.-, 118 S.Ct. 606

1999See, e.g., People v. Holt, 15 Cal.4th 619, 663 , 63 Cal.Rptr.2d 782, 811 , 937 P.2d 213, 242 (rejecting the defendant's argument that tape recording of statement made during a custodial interrogation is required to ensure fundamental fairness because "a confession may not be the voluntary `product of a rational intellect and a free will,' and the need to test the voluntariness of a confession on the basis of `the totality of all the surrounding circumstances—both the characteristics of the accused and the details of the interrogation'") (citation omitted), cert. denied, ___ U.S. ___, 118 S.Ct.

1999See, e.g., People v. Holt, 15 Cal.4th 619, 663 , 63 Cal.Rptr.2d 782, 811 , 937 P.2d 213, 242 (rejecting the defendant's argument that tape recording of statement made during a custodial interrogation is required to ensure fundamental fairness because "a confession may not be the voluntary `product of a rational intellect and a free will,' and the need to test the voluntariness of a confession on the basis of `the totality of all the surrounding circumstances—both the characteristics of the accused and the details of the interrogation'") (citation omitted), cert. denied, ___ U.S. ___, 118 S.Ct.

1999See, e.g., People v. Holt, 15 Cal.4th 619, 663 , 63 Cal.Rptr.2d 782, 811 , 937 P.2d 213, 242 (rejecting the defendant's argument that tape recording of statement made during a custodial interrogation is required to ensure fundamental fairness because "a confession may not be the voluntary `product of a rational intellect and a free will,' and the need to test the voluntariness of a confession on the basis of `the totality of all the surrounding circumstances—both the characteristics of the accused and the details of the interrogation'") (citation omitted), cert. denied, ___ U.S. ___, 118 S.Ct.

1999See, e.g., People v. Holt, 15 Cal.4th 619, 663 , 63 Cal.Rptr.2d 782, 811 , 937 P.2d 213, 242 (rejecting the defendant’s argument that tape recording of statement made during a custodial interrogation is required to ensure fundamental fairness because “a confession may not be the voluntary ‘product of a rational intellect and a free will,’ and the need to test the voluntariness of a confession on the basis of ‘the totality of all the surrounding circumstances—both the characteristics of the accused and the details of the interrogation’ ”) (citation omitted), cert. denied, — U.S.-, 118 S.Ct. 606

1999See, e.g., People v. Holt, 15 Cal.4th 619, 663 , 63 Cal.Rptr.2d 782, 811 , 937 P.2d 213, 242 (rejecting the defendant's argument that tape recording of statement made during a custodial interrogation is required to ensure fundamental fairness because "a confession may not be the voluntary `product of a rational intellect and a free will,' and the need to test the voluntariness of a confession on the basis of `the totality of all the surrounding circumstances—both the characteristics of the accused and the details of the interrogation'") (citation omitted), cert. denied, ___ U.S. ___, 118 S.Ct.

1999See, e.g., People v. Holt, 15 Cal.4th 619, 663 , 63 Cal.Rptr.2d 782, 811 , 937 P.2d 213, 242 (rejecting the defendant's argument that tape recording of statement made during a custodial interrogation is required to ensure fundamental fairness because "a confession may not be the voluntary `product of a rational intellect and a free will,' and the need to test the voluntariness of a confession on the basis of `the totality of all the surrounding circumstances—both the characteristics of the accused and the details of the interrogation'") (citation omitted), cert. denied, ___ U.S. ___, 118 S.Ct.

1999See, e.g., People v. Holt, 15 Cal.4th 619, 663 , 63 Cal.Rptr.2d 782, 811 , 937 P.2d 213, 242 (rejecting the defendant's argument that tape recording of statement made during a custodial interrogation is required to ensure fundamental fairness because "a confession may not be the voluntary `product of a rational intellect and a free will,' and the need to test the voluntariness of a confession on the basis of `the totality of all the surrounding circumstances—both the characteristics of the accused and the details of the interrogation'") (citation omitted), cert. denied, ___ U.S. ___, 118 S.Ct.

1999See, e.g., People v. Holt, 15 Cal.4th 619, 663 , 63 Cal.Rptr.2d 782, 811 , 937 P.2d 213, 242 (rejecting the defendant's argument that tape recording of statement made during a custodial interrogation is required to ensure fundamental fairness because "a confession may not be the voluntary `product of a rational intellect and a free will,' and the need to test the voluntariness of a confession on the basis of `the totality of all the surrounding circumstances—both the characteristics of the accused and the details of the interrogation'") (citation omitted), cert. denied, ___ U.S. ___, 118 S.Ct.

1999See, e.g., People v. Holt, 15 Cal.4th 619, 663 , 63 Cal.Rptr.2d 782, 811 , 937 P.2d 213, 242 (rejecting the defendant's argument that tape recording of statement made during a custodial interrogation is required to ensure fundamental fairness because "a confession may not be the voluntary `product of a rational intellect and a free will,' and the need to test the voluntariness of a confession on the basis of `the totality of all the surrounding circumstances—both the characteristics of the accused and the details of the interrogation'") (citation omitted), cert. denied, ___ U.S. ___, 118 S.Ct.

1999See, e.g., People v. Holt, 15 Cal.4th 619, 663 , 63 Cal.Rptr.2d 782, 811 , 937 P.2d 213, 242 (rejecting the defendant’s argument that tape recording of statement made during a custodial interrogation is required to ensure fundamental fairness because “a confession may not be the voluntary ‘product of a rational intellect and a free will,’ and the need to test the voluntariness of a confession on the basis of ‘the totality of all the surrounding circumstances—both the characteristics of the accused and the details of the interrogation’ ”) (citation omitted), cert. denied, — U.S.-, 118 S.Ct. 606

1999See, e.g., People v. Holt, 15 Cal.4th 619, 663 , 63 Cal.Rptr.2d 782, 811 , 937 P.2d 213, 242 (rejecting the defendant's argument that tape recording of statement made during a custodial interrogation is required to ensure fundamental fairness because "a confession may not be the voluntary `product of a rational intellect and a free will,' and the need to test the voluntariness of a confession on the basis of `the totality of all the surrounding circumstances—both the characteristics of the accused and the details of the interrogation'") (citation omitted), cert. denied, ___ U.S. ___, 118 S.Ct.

1999See, e.g., People v. Holt, 15 Cal.4th 619, 663 , 63 Cal.Rptr.2d 782, 811 , 937 P.2d 213, 242 (rejecting the defendant's argument that tape recording of statement made during a custodial interrogation is required to ensure fundamental fairness because "a confession may not be the voluntary `product of a rational intellect and a free will,' and the need to test the voluntariness of a confession on the basis of `the totality of all the surrounding circumstances—both the characteristics of the accused and the details of the interrogation'") (citation omitted), cert. denied, ___ U.S. ___, 118 S.Ct.

1999See, e.g., People v. Holt, 15 Cal.4th 619, 663 , 63 Cal.Rptr.2d 782, 811 , 937 P.2d 213, 242 (rejecting the defendant's argument that tape recording of statement made during a custodial interrogation is required to ensure fundamental fairness because "a confession may not be the voluntary `product of a rational intellect and a free will,' and the need to test the voluntariness of a confession on the basis of `the totality of all the surrounding circumstances—both the characteristics of the accused and the details of the interrogation'") (citation omitted), cert. denied, ___ U.S. ___, 118 S.Ct.

1999See, e.g., People v. Holt, 15 Cal.4th 619, 663 , 63 Cal.Rptr.2d 782, 811 , 937 P.2d 213, 242 (rejecting the defendant's argument that tape recording of statement made during a custodial interrogation is required to ensure fundamental fairness because "a confession may not be the voluntary `product of a rational intellect and a free will,' and the need to test the voluntariness of a confession on the basis of `the totality of all the surrounding circumstances—both the characteristics of the accused and the details of the interrogation'") (citation omitted), cert. denied, ___ U.S. ___, 118 S.Ct.

1999See, e.g., People v. Holt, 15 Cal.4th 619, 663 , 63 Cal.Rptr.2d 782, 811 , 937 P.2d 213, 242 (rejecting the defendant's argument that tape recording of statement made during a custodial interrogation is required to ensure fundamental fairness because "a confession may not be the voluntary `product of a rational intellect and a free will,' and the need to test the voluntariness of a confession on the basis of `the totality of all the surrounding circumstances—both the characteristics of the accused and the details of the interrogation'") (citation omitted), cert. denied, ___ U.S. ___, 118 S.Ct.

1999See, e.g., People v. Holt, 15 Cal.4th 619, 663 , 63 Cal.Rptr.2d 782, 811 , 937 P.2d 213, 242 (rejecting the defendant's argument that tape recording of statement made during a custodial interrogation is required to ensure fundamental fairness because "a confession may not be the voluntary `product of a rational intellect and a free will,' and the need to test the voluntariness of a confession on the basis of `the totality of all the surrounding circumstances—both the characteristics of the accused and the details of the interrogation'") (citation omitted), cert. denied, ___ U.S. ___, 118 S.Ct.

1999See, e.g., People v. Holt, 15 Cal.4th 619, 663 , 63 Cal.Rptr.2d 782, 811 , 937 P.2d 213, 242 (rejecting the defendant's argument that tape recording of statement made during a custodial interrogation is required to ensure fundamental fairness because "a confession may not be the voluntary `product of a rational intellect and a free will,' and the need to test the voluntariness of a confession on the basis of `the totality of all the surrounding circumstances—both the characteristics of the accused and the details of the interrogation'") (citation omitted), cert. denied, ___ U.S. ___, 118 S.Ct.

1999But see Stephan v. State, 711 P.2d 1156, 1159 (Alaska 1985) (holding that under the due process clause of the state constitution the custodial interrogation of a suspect must be electronically recorded when recording is feasible); State v. Scales, 518 N.W.2d 587, 592 (Minn.1994) (holding that “in the exercise of our supervisory power to insure the fair administration of justice, ... all custodial interrogation including any information about rights, any waiver of those rights, and all questioning shall be electronically recorded where feasible and must be recorded when questioning occurs at a

1999But see Stephan v. State, 711 P.2d 1156, 1159 (Alaska 1985) (holding that under the due process clause of the state constitution the custodial interrogation of a suspect must be electronically recorded when recording is feasible); State v. Scales, 518 N.W.2d 587, 592 (Minn.1994) (holding that "in the exercise of our supervisory power to insure the fair administration of justice,... all custodial interrogation including any information about rights, any waiver of those rights, and all questioning shall be electronically recorded where feasible and must be recorded when questioning occurs at a p

1999See, e.g., People v. Holt, 15 Cal.4th 619, 663 , 63 Cal.Rptr.2d 782, 811 , 937 P.2d 213, 242 (rejecting the defendant's argument that tape recording of statement made during a custodial interrogation is required to ensure fundamental fairness because "a confession may not be the voluntary `product of a rational intellect and a free will,' and the need to test the voluntariness of a confession on the basis of `the totality of all the surrounding circumstances—both the characteristics of the accused and the details of the interrogation'") (citation omitted), cert. denied, ___ U.S. ___, 118 S.Ct.

1999See, e.g., People v. Holt, 15 Cal.4th 619, 663 , 63 Cal.Rptr.2d 782, 811 , 937 P.2d 213, 242 (rejecting the defendant's argument that tape recording of statement made during a custodial interrogation is required to ensure fundamental fairness because "a confession may not be the voluntary `product of a rational intellect and a free will,' and the need to test the voluntariness of a confession on the basis of `the totality of all the surrounding circumstances—both the characteristics of the accused and the details of the interrogation'") (citation omitted), cert. denied, ___ U.S. ___, 118 S.Ct.