Wright motion in Maryland

9 Maryland opinions name it 2 courts 1971–2022 2 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.

Followed or applied (3)

Case	Followed	Cited
Chaney v. Stategreen md · 2007 · cited in 2 Maryland opinions naming this issue, 2022–2022 2 sentences 2022Maryland Rule 4-345(a) provides that “[t]he court may correct an illegal sentence at any time.” In other words, illegal sentences may be corrected even if “(1) no objection was made when the sentence was imposed, (2) the defendant purported to consent to it, or (3) the sentence was not challenged in a timely-filed direct appeal.” Chaney v. State, 397 Md. 460, 466 (2007). 2022Maryland Rule 4-345(a) provides that “[t]he court may correct an illegal sentence at any time.” In other words, illegal sentences may be corrected even if “(1) no objection was made when the sentence was imposed, (2) the defendant purported to consent to it, or (3) the sentence was not challenged in a timely-filed direct appeal.” Chaney v. State, 397 Md. 460, 466 (2007).	2	2
Johnson v. Stategreen md · 2012 · cited in 2 Maryland opinions naming this issue, 2022–2022 2 sentences 2022And to qualify as an illegal sentence under Rule 4-345(a), “the illegality must inhere in the sentence itself, rather than stem from trial court error during the sentencing proceeding.” Johnson v. State, 427 Md. 356, 367 (2012) (quoting Matthews 5 The State also asserts that we should decline to address Mr. Wright’s claim because he had not provided a copy of the key charging document and the evidence in the record did not otherwise capture the content of the 2000 indictment. 2022And to qualify as an illegal sentence under Rule 4-345(a), “the illegality must inhere in the sentence itself, rather than stem from trial court error during the sentencing proceeding.” Johnson v. State, 427 Md. 356, 367 (2012) (quoting Matthews 5 The State also asserts that we should decline to address Mr. Wright’s claim because he had not provided a copy of the key charging document and the evidence in the record did not otherwise capture the content of the 2000 indictment.	2	2
Wilson v. Stategreen md · 1994 · cited in 1 Maryland opinions naming this issue, 2000–2000 2 sentences 2000See Wilson, 334 Md. at 322-23 , 639 A.2d 125 ; Chapman v. State 331 Md. 448, 456-57 , 628 A.2d 676 (1993). 2000See Wilson, 334 Md. at 322-23 , 639 A.2d 125 ; Chapman v. State 331 Md. 448, 456-57 , 628 A.2d 676 (1993).	1	1

Distinguished, questioned or overruled (0)

Case	Negative	Cited
No negative-treatment citations attached to this issue in Maryland. Read the followed side critically anyway.

Also cited on this issue (11)

Case	Cited	Years
Wright v. State green mdctspecapp · 1975 2 sentences 2016In Wright v. State, 24 Md.App. 309, 313 , 330 A.2d 482 (1975), we held the trial court did not err in not granting Wright’s motion for a new trial where there was no evidence of prejudice when the foreman that had dozed off was awakened immediately upon dozing and had been attentive both before and after the incident. 2016In Wright v. State, 24 Md.App. 309, 313 , 330 A.2d 482 (1975), we held the trial court did not err in not granting Wright’s motion for a new trial where there was no evidence of prejudice when the foreman that had dozed off was awakened immediately upon dozing and had been attentive both before and after the incident.	1	2016–2016
Wright v. State green md · 1995 2 sentences 2015The court denied the motion, and as to the jurisdictional issue, relied on Wright v. State, 339 Md. 399 , 663 A.2d 590 (1995), discussed infra, because “the Wright principle kicks in where the duty to account would authorize jurisdiction within the State of Maryland.” (Italics added). 2015The court denied the motion, and as to the jurisdictional issue, relied on Wright v. State, 339 Md. 399 , 663 A.2d 590 (1995), discussed infra, because “the Wright principle kicks in where the duty to account would authorize jurisdiction within the State of Maryland.” (Italics added).	1	2015–2015
Stoddard v. State green md · 2005 1 sentence 2005For instance, the concurring opinion says the following about Mueller and Kirkpatrick's FEDERAL EVIDENCE: "Mueller and Kirkpatrick purport to see some limited lingering value in Wright's analysis of the so-called `two-step inference' (belief from conduct, fact from belief), but they acknowledge that `FRE 801 rejects the broad proposition endorsed by Baron Parke' and suggest that, `arguably, it would be wiser to forget Wright than continue to discuss it.'" Concurring op. at 730, 887 A.2d at 593 (quoting Christopher B.	1	2005–2005
Allgood v. State green md · 1987 2 sentences 2003Id. at 82 , 522 A.2d 917 . 2003Id. at 82 , 522 A.2d 917 .	1	2003–2003
Chapman v. State green md · 1993 2 sentences 2000See Wilson, 334 Md. at 322-23 , 639 A.2d 125 ; Chapman v. State 331 Md. 448, 456-57 , 628 A.2d 676 (1993). 2000See Wilson, 334 Md. at 322-23 , 639 A.2d 125 ; Chapman v. State 331 Md. 448, 456-57 , 628 A.2d 676 (1993).	1	2000–2000
Martin v. State green mdctspecapp · 1970 2 sentences 1984Maryland Rule 756a unequivocally provides: “If the motion is not then granted, the defendant may offer evidence, but if so, he withdraws his motion.” Winkles v. State, 40 Md.App. 616 , 392 A.2d 1173 (1978); Williams v. State, 19 Md.App. 204 , 310 A.2d 593 (1973); Martin v. State, 10 Md.App. 274 , 269 A.2d 182 (1970); Richardson v. State, 6 Md.App. 448 , 251 A.2d 924 (1969). 1984Maryland Rule 756a unequivocally provides: “If the motion is not then granted, the defendant may offer evidence, but if so, he withdraws his motion.” Winkles v. State, 40 Md.App. 616 , 392 A.2d 1173 (1978); Williams v. State, 19 Md.App. 204 , 310 A.2d 593 (1973); Martin v. State, 10 Md.App. 274 , 269 A.2d 182 (1970); Richardson v. State, 6 Md.App. 448 , 251 A.2d 924 (1969).	1	1984–1984
Richardson v. State green mdctspecapp · 1969 2 sentences 1984Maryland Rule 756a unequivocally provides: “If the motion is not then granted, the defendant may offer evidence, but if so, he withdraws his motion.” Winkles v. State, 40 Md.App. 616 , 392 A.2d 1173 (1978); Williams v. State, 19 Md.App. 204 , 310 A.2d 593 (1973); Martin v. State, 10 Md.App. 274 , 269 A.2d 182 (1970); Richardson v. State, 6 Md.App. 448 , 251 A.2d 924 (1969). 1984Maryland Rule 756a unequivocally provides: “If the motion is not then granted, the defendant may offer evidence, but if so, he withdraws his motion.” Winkles v. State, 40 Md.App. 616 , 392 A.2d 1173 (1978); Williams v. State, 19 Md.App. 204 , 310 A.2d 593 (1973); Martin v. State, 10 Md.App. 274 , 269 A.2d 182 (1970); Richardson v. State, 6 Md.App. 448 , 251 A.2d 924 (1969).	1	1984–1984
Williams v. State green mdctspecapp · 1973 2 sentences 1984Maryland Rule 756a unequivocally provides: “If the motion is not then granted, the defendant may offer evidence, but if so, he withdraws his motion.” Winkles v. State, 40 Md.App. 616 , 392 A.2d 1173 (1978); Williams v. State, 19 Md.App. 204 , 310 A.2d 593 (1973); Martin v. State, 10 Md.App. 274 , 269 A.2d 182 (1970); Richardson v. State, 6 Md.App. 448 , 251 A.2d 924 (1969). 1984Maryland Rule 756a unequivocally provides: “If the motion is not then granted, the defendant may offer evidence, but if so, he withdraws his motion.” Winkles v. State, 40 Md.App. 616 , 392 A.2d 1173 (1978); Williams v. State, 19 Md.App. 204 , 310 A.2d 593 (1973); Martin v. State, 10 Md.App. 274 , 269 A.2d 182 (1970); Richardson v. State, 6 Md.App. 448 , 251 A.2d 924 (1969).	1	1984–1984
Winkles v. State green mdctspecapp · 1978 2 sentences 1984Maryland Rule 756a unequivocally provides: “If the motion is not then granted, the defendant may offer evidence, but if so, he withdraws his motion.” Winkles v. State, 40 Md.App. 616 , 392 A.2d 1173 (1978); Williams v. State, 19 Md.App. 204 , 310 A.2d 593 (1973); Martin v. State, 10 Md.App. 274 , 269 A.2d 182 (1970); Richardson v. State, 6 Md.App. 448 , 251 A.2d 924 (1969). 1984Maryland Rule 756a unequivocally provides: “If the motion is not then granted, the defendant may offer evidence, but if so, he withdraws his motion.” Winkles v. State, 40 Md.App. 616 , 392 A.2d 1173 (1978); Williams v. State, 19 Md.App. 204 , 310 A.2d 593 (1973); Martin v. State, 10 Md.App. 274 , 269 A.2d 182 (1970); Richardson v. State, 6 Md.App. 448 , 251 A.2d 924 (1969).	1	1984–1984
North Carolina v. Pearce red scotus · 1969 1 sentence 1971The United States Court of Appeals for the Fourth Circuit reversed the District Court’s judgment; it held that Wright’s claim raised substantial constitutional questions under North Carolina v. Pearce, 395 U. S. 711 , which had not been considered by the Maryland courts.	1	1971–1971
Elijah Wright v. Maryland Penitentiary, State of Maryland green ca4 · 1970 1 sentence 1971Wright v. Warden, 429 F. 2d 1101 .	1	1971–1971

Where else courts name it

TX 42 (2002–2025) IN 38 (1978–2023) OH 26 (1986–2024) GA 24 (1967–2025) MS 20 (1987–2018) CA 15 (1992–2026) FL 14 (1979–2022) PA 14 (1968–2026) IL 14 (1992–2025) WA 11 (2007–2021) MD 9 (1971–2022) DE 9 (1979–2024) VA 8 (1998–2025) IA 8 (1973–2021) MO 8 (1975–2023) NJ 5 (1999–2025) UT 5 (1994–2021) AK 5 (1979–2017) WI 5 (1989–2023) MI 4 (2008–2019) KS 4 (2013–2021) NY 4 (1995–2025) AL 4 (1994–2009) WY 4 (1993–2023) SD 4 (1999–2021) ID 3 (2000–2023) LA 3 (1977–2009) CT 3 (1993–2014) MN 3 (1935–2014) SC 3 (1923–2016) TN 3 (2007–2026) MT 2 (2002–2002) MA 2 (1992–2024) HI 2 (1997–2004) NE 2 (1985–2016) AZ 2 (2016–2017) AR 2 (1992–2024)

Opinions by the citing court's state. A doctrine retained in one state and abandoned in another shows up here as a year span that stalls.

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