15 Maryland opinions name it 2 courts 1988–2025 3 in the last five years
The cases below were cited by Maryland courts in a sentence that names this issue. Sides come from how each citing opinion treated the case (Syfertize flag on that citation), so a case can appear on both: that is where the law is contested. A red or yellow chip is the case's own overall treatment.
| Case | Followed | Cited |
|---|---|---|
Attorney Grievance v. Daileygreen1 sentence2023Rule 1.3 - Diligence Rule 1.3 provides: “An attorney shall act with reasonable diligence and promptness in representing a client.” This duty of diligence can be violated, among other ways, “by 32 failing to advance a client’s cause or endeavor; failing to investigate a client’s matter; and repeatedly failing to return phone calls, respond to letters, or provide an accounting for earned fees.” Attorney Grievance Comm’n v. Dailey, 474 Md. 679, 703 (2021) (quoting Attorney Grievance Comm’n v. Bah, 468 Md. 179, 208 (2020)). | 1 | 1 |
Attorney Grievance v. Bahgreen1 sentence2023Rule 1.3 - Diligence Rule 1.3 provides: “An attorney shall act with reasonable diligence and promptness in representing a client.” This duty of diligence can be violated, among other ways, “by 32 failing to advance a client’s cause or endeavor; failing to investigate a client’s matter; and repeatedly failing to return phone calls, respond to letters, or provide an accounting for earned fees.” Attorney Grievance Comm’n v. Dailey, 474 Md. 679, 703 (2021) (quoting Attorney Grievance Comm’n v. Bah, 468 Md. 179, 208 (2020)). | 1 | 1 |
Attorney Grievance Commission v. Browngreen1 sentence2023Most notably, Mr. Jones’s improper references to “nonrefundable” flat fees in the retainer agreements in both matters, his failure to provide a reasonable refund in the Chambers matter, and his entry of the NCR plea without Jada’s knowledge and consent, were prejudicial to the administration of justice and bring the legal profession into disrepute. 21 For the same reasons that we decline to find a violation of Rule 1.5 based on Mr. Jones’s pre-CDA retention of the $4,000 fee in the Johnson matter, we decline to conclude that Mr. Jones violated Rule 1.16 at the conclusion of his representation | 1 | 1 |
Pouncey v. Stategreen2 sentences2020Pouncey v. State, 297 Md. 264, 269-70 , 465 A.2d 475, 478 (1983). 2020Pouncey v. State, 297 Md. 264, 269-70 , 465 A.2d 475, 478 (1983). | 1 | 1 |
In Re Ryan S.green1 sentence2020See In re Ryan S., 369 Md. 26, 56 (2002) (quotation 13 omitted) (“where the Legislature in a statute expressly authorizes a particular action under certain circumstances, the statute ordinarily should be construed as not allowing the action under other circumstances”). | 1 | 1 |
Marks v. Stategreen1 sentence2020See generally Howard, 440 Md. at 448–49 (jointly caused delay was neutral); Glover, 368 Md. at 225– 26 (joint postponement resulted “from dual factors”); Marks, 84 Md. | 1 | 1 |
Malik v. Stategreen1 sentence2020Based on this record, we may fairly infer that his pretrial incarceration was not as onerous as appellate counsel now “imagine[s].” Cf. Malik, 152 Md. | 1 | 1 |
Howell v. Stategreen1 sentence2020We do not treat the four-month period between the arrest and the first scheduled trial date as delay for purposes of our Barker analysis (from February 23, 2015, until June 16, 2015), because it is neutral and effectively “excluded from our calculations,” on the ground that it was “necessary for the orderly administration of justice[.]” Howell v. State, 87 Md. | 1 | 1 |
Vitek v. Jonesgreen2 sentences2020See Vitek v. Jones, 445 U.S. 480 , 100 S. Ct. 1254 (1980). 2020See Vitek v. Jones, 445 U.S. 480 , 100 S. Ct. 1254 (1980). | 1 | 1 |
Howard v. Stategreen1 sentence2020See generally Howard, 440 Md. at 448–49 (jointly caused delay was neutral); Glover, 368 Md. at 225– 26 (joint postponement resulted “from dual factors”); Marks, 84 Md. | 1 | 1 |
Logan v. Stategreen2 sentences2006See id. at 50-52 , 882 A.2d at 358-59 . 2006See id. at 50-52 , 882 A.2d at 358-59 . | 1 | 1 |
Contee v. Stategreen2 sentences2005See Cantee v. State, 223 Md. 575, 580 , 165 A.2d 889 (1960) (concluding that the defendant “was denied an opportunity ... to frame additional proper voir dire questions ... and the court failed to ask, on its own motion, as it should have done, a proper question designed to ascertain the existence of cause for disqualification. ...”). *62 On the merits, we agree with Logan that the subject matter of the NCR defense was of considerable importance, and it should have been carefully explored on voir dire. 2005See Cantee v. State, 223 Md. 575, 580 , 165 A.2d 889 (1960) (concluding that the defendant “was denied an opportunity ... to frame additional proper voir dire questions ... and the court failed to ask, on its own motion, as it should have done, a proper question designed to ascertain the existence of cause for disqualification. ...”). *62 On the merits, we agree with Logan that the subject matter of the NCR defense was of considerable importance, and it should have been carefully explored on voir dire. | 1 | 1 |
State v. Thomasgreen2 sentences2005As to appellant’s contentions concerning pretrial publicity, the State maintains that the court’s voir dire “was sufficient to adduce any potential juror bias emanating from a juror’s exposure to pretrial publicity....” It insists that “any prospective juror who harbored pre-conceived notions or biases based on the exposure to pretrial publicity would have been detected by means of the voir dire questions actually posed.” According to the State, the court also utilized the proper methodology during voir dire, because it “inquired whether any juror had acquired knowledge of the case,” then “que 2005As to appellant’s contentions concerning pretrial publicity, the State maintains that the court’s voir dire “was sufficient to adduce any potential juror bias emanating from a juror’s exposure to pretrial publicity....” It insists that “any prospective juror who harbored pre-conceived notions or biases based on the exposure to pretrial publicity would have been detected by means of the voir dire questions actually posed.” According to the State, the court also utilized the proper methodology during voir dire, because it “inquired whether any juror had acquired knowledge of the case,” then “que | 1 | 1 |
Grandison v. Stategreen2 sentences1998In Grandison v. State, 305 Md. 685, 711 , 506 A.2d 580, 593 (1986), we considered the paucity of proof that defendant was not criminally responsible as an important factor justifying the trial judge’s refusal to permit the filing of a belated NCR plea on the eve of the date set for trial. 1998In Grandison v. State, 305 Md. 685, 711 , 506 A.2d 580, 593 (1986), we considered the paucity of proof that defendant was not criminally responsible as an important factor justifying the trial judge’s refusal to permit the filing of a belated NCR plea on the eve of the date set for trial. | 1 | 1 |
State v. Fraziergreen2 sentences1998See State v. Frazier, 298 Md. 422 , 470 A.2d 1269 (1984) (discussing “good cause” in context of postponement of trial date; State v. Jones, 270 Md. 388 , 312 A.2d 281 (1973) (analysis of “good cause” requirement to permit a requested withdrawal of an accused’s jury trial waiver)). 1998See State v. Frazier, 298 Md. 422 , 470 A.2d 1269 (1984) (discussing “good cause” in context of postponement of trial date; State v. Jones, 270 Md. 388 , 312 A.2d 281 (1973) (analysis of “good cause” requirement to permit a requested withdrawal of an accused’s jury trial waiver)). | 1 | 1 |
| Marsh v. Stategreen | 1 | 1 |
Martinez v. Stategreen2 sentences1995The Court of Special Appeals accepted Marsh’s argument that Treece and Maryland Rule 4-246 require that the defendant be advised in open court of the right to a jury trial on an NCR defense and held that “for a waiver to be valid, ‘the court must be satisfied that the defendant’s election was made knowledgeably and voluntarily.’ ” Marsh v. State, 98 Md.App. 686, 694 , 635 A.2d 26, 30 (1994) (quoting Martinez v. State, 309 Md. 124, 133 , 522 A.2d 950, 955 (1987)). 1995The Court of Special Appeals accepted Marsh’s argument that Treece and Maryland Rule 4-246 require that the defendant be advised in open court of the right to a jury trial on an NCR defense and held that “for a waiver to be valid, ‘the court must be satisfied that the defendant’s election was made knowledgeably and voluntarily.’ ” Marsh v. State, 98 Md.App. 686, 694 , 635 A.2d 26, 30 (1994) (quoting Martinez v. State, 309 Md. 124, 133 , 522 A.2d 950, 955 (1987)). | 1 | 1 |
| Erdman v. Stategreen | 1 | 1 |
| Case | Negative | Cited |
|---|---|---|
| No negative-treatment citations attached to this issue in Maryland. Read the followed side critically anyway. | ||
| Case | Cited | Years |
|---|---|---|
Dingle v. State
green
2 sentences2006In addition, the court held that the question on pretrial publicity posed by the trial judge to the venire was contrary to Dingle v. State, 361 Md. 1 , 759 A.2d 819 (2000), because that query sought only to uncover the jurors’ own bottom-line conclusions as to their impartiality. 2006In addition, the court held that the question on pretrial publicity posed by the trial judge to the venire was contrary to Dingle v. State, 361 Md. 1 , 759 A.2d 819 (2000), because that query sought only to uncover the jurors’ own bottom-line conclusions as to their impartiality. | 2 | 2005–2006 |
Treece v. State
green
2 sentences1994In Treece v. State, 313 Md. 665 , 547 A.2d 1054 (1988), the Court of Appeals held that, except in unusual circumstances, it is the defendant’s right to assert a NCR plea. 1994In Treece v. State, 313 Md. 665 , 547 A.2d 1054 (1988), the Court of Appeals held that, except in unusual circumstances, it is the defendant’s right to assert a NCR plea. | 2 | 1994–2002 |
Hill v. Lockhart
green
1 sentence2025Lost Opportunity Mr. Brand cites Hill v. Lockhart, 474 U.S. 52 (1985), to support his contention “that he need not show prejudice beyond the fact that he was deprived of his right to a jury trial.” According to Mr. Brand, he “need not prove that he would have prevailed on his NCR claim if he had proceeded to trial in front of a jury” because, in the context of an ineffective assistance claim where trial counsel’s deficiency results in the “loss of a desired procedure[,]” the prejudice suffered is the deprivation of the desired procedure, in this case his right to a jury trial. | 1 | 2025–2025 |
North Carolina v. Alford
green
1 sentence2023She subsequently withdrew her NCR plea and eventually tendered an Alford plea.11 11 Derived from North Carolina v. Alford, 400 U.S. 25 (1970), an Alford plea occurs when a defendant, while maintaining innocence, agrees to a proffer of stipulated evidence or to an agreed statement of facts that provides a factual basis for a finding of guilt. | 1 | 2023–2023 |
State v. Peterson
green
1 sentence2021Id. | 1 | 2021–2021 |
State v. Garnett
green
1 sentence2020Id. at *5 (quoting State v. Garnett, 172 Md. | 1 | 2020–2020 |
Glover v. State
green
1 sentence2020See generally Howard, 440 Md. at 448–49 (jointly caused delay was neutral); Glover, 368 Md. at 225– 26 (joint postponement resulted “from dual factors”); Marks, 84 Md. | 1 | 2020–2020 |
Barker v. Wingo
green
2 sentences2020In a complex murder case involving a defendant whose criminal responsibility was in question after he entered an NCR plea sixteen months into the parties’ trial preparation, when the State was prepared to proceed to trial, the focus of speedy trial analysis under Barker v. Wingo, 407 U.S. 514 (1972), is on the NCR-related delay that occurred after the change in plea paused and then re-set the proverbial clock on trial preparation. 2020Barker, 407 U.S. at 531 , 92 S. Ct. at 2192 . 10 Three of those pre-NCR plea postponements (the first, third, and fifth), totaling four and a half months/139 days, were joint and therefore neutral in weight. | 1 | 2020–2020 |
Arizona v. Roberson
green
2 sentences2009As the Supreme Court stated in Arizona v. Roberson, 486 U.S. at 684 , 108 S.Ct. 2093 , “[A] suspect’s request for counsel should apply to any questions the police wish to pose.” A fortiori, the possible effect of anything the appellee might have said on an NCR plea, which we have already fully discussed in a related context, made the restriction of the right exponentially wrong. 2009As the Supreme Court stated in Arizona v. Roberson, 486 U.S. at 684 , 108 S.Ct. 2093 , “[A] suspect’s request for counsel should apply to any questions the police wish to pose.” A fortiori, the possible effect of anything the appellee might have said on an NCR plea, which we have already fully discussed in a related context, made the restriction of the right exponentially wrong. | 1 | 2009–2009 |
Hill v. State
green
2 sentences2005As to appellant’s contentions concerning pretrial publicity, the State maintains that the court’s voir dire “was sufficient to adduce any potential juror bias emanating from a juror’s exposure to pretrial publicity....” It insists that “any prospective juror who harbored pre-conceived notions or biases based on the exposure to pretrial publicity would have been detected by means of the voir dire questions actually posed.” According to the State, the court also utilized the proper methodology during voir dire, because it “inquired whether any juror had acquired knowledge of the case,” then “que 2005As to appellant’s contentions concerning pretrial publicity, the State maintains that the court’s voir dire “was sufficient to adduce any potential juror bias emanating from a juror’s exposure to pretrial publicity....” It insists that “any prospective juror who harbored pre-conceived notions or biases based on the exposure to pretrial publicity would have been detected by means of the voir dire questions actually posed.” According to the State, the court also utilized the proper methodology during voir dire, because it “inquired whether any juror had acquired knowledge of the case,” then “que | 1 | 2005–2005 |
People v. Mapp
green
2 sentences2005We pause to consider them. *67 In People v. Mapp, 283 Ill.App.3d 979 , 219 Ill.Dec. 174 , 670 N.E.2d 852 (1996), appeal denied, 171 Ill.2d 576 , 222 Ill.Dec. 435 , 677 N.E.2d 969 (1997), the appellant was convicted of armed robbery and felony murder. 2005We pause to consider them. *67 In People v. Mapp, 283 Ill.App.3d 979 , 219 Ill.Dec. 174 , 670 N.E.2d 852 (1996), appeal denied, 171 Ill.2d 576 , 222 Ill.Dec. 435 , 677 N.E.2d 969 (1997), the appellant was convicted of armed robbery and felony murder. | 1 | 2005–2005 |
Boyd v. State
green
2 sentences2005As to appellant’s contentions concerning pretrial publicity, the State maintains that the court’s voir dire “was sufficient to adduce any potential juror bias emanating from a juror’s exposure to pretrial publicity....” It insists that “any prospective juror who harbored pre-conceived notions or biases based on the exposure to pretrial publicity would have been detected by means of the voir dire questions actually posed.” According to the State, the court also utilized the proper methodology during voir dire, because it “inquired whether any juror had acquired knowledge of the case,” then “que 2005As to appellant’s contentions concerning pretrial publicity, the State maintains that the court’s voir dire “was sufficient to adduce any potential juror bias emanating from a juror’s exposure to pretrial publicity....” It insists that “any prospective juror who harbored pre-conceived notions or biases based on the exposure to pretrial publicity would have been detected by means of the voir dire questions actually posed.” According to the State, the court also utilized the proper methodology during voir dire, because it “inquired whether any juror had acquired knowledge of the case,” then “que | 1 | 2005–2005 |
Gregory v. State
green
2 sentences2005What we said in Gregory v. State, 40 Md.App. 297, 326 , 391 A.2d 437 (1978), in the context of cross-examination, seems equally applicable to voir dire: Psychiatry — particularly the forensic branch of it — is an inexact science. 2005What we said in Gregory v. State, 40 Md.App. 297, 326 , 391 A.2d 437 (1978), in the context of cross-examination, seems equally applicable to voir dire: Psychiatry — particularly the forensic branch of it — is an inexact science. | 1 | 2005–2005 |
State v. Jones
green
2 sentences1998See State v. Frazier, 298 Md. 422 , 470 A.2d 1269 (1984) (discussing “good cause” in context of postponement of trial date; State v. Jones, 270 Md. 388 , 312 A.2d 281 (1973) (analysis of “good cause” requirement to permit a requested withdrawal of an accused’s jury trial waiver)). 1998See State v. Frazier, 298 Md. 422 , 470 A.2d 1269 (1984) (discussing “good cause” in context of postponement of trial date; State v. Jones, 270 Md. 388 , 312 A.2d 281 (1973) (analysis of “good cause” requirement to permit a requested withdrawal of an accused’s jury trial waiver)). | 1 | 1998–1998 |
| Hoey v. State green | 1 | 1994–1994 |
| COMPTROLLER OF TREASURY, IT DIV. v. NCR Corp. green | 1 | 1988–1988 |