67 Maryland opinions name it 2 courts 1981–2026 17 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 |
|---|---|---|
Bishop v. Stategreen2 sentences2023The defendant may also plead nolo contendere, as appellant did here, or take an Alford plea.5 Bishop, 417 Md. at 16 . 2022The court entered a corrected order on February 4, 2015. 4 An Alford plea takes its name from North Carolina v. Alford, 400 U.S. 25 (1970), and is a “guilty plea containing a protestation of innocence.” Bishop v. State, 417 Md. 1, 19 (2010) (citations omitted). 4 completing community service hours under the terms of her probation, seeking employment, and receiving appropriate mental health therapy. | 13 | 20 |
North Carolina v. Alfordgreen2 sentences2025Ward v. State, 290 Md. 76, 83 (1981). 3 The term “Alford plea” is a legal eponym drawn from the United States Supreme Court case, North Carolina v. Alford, 400 U.S. 25 (1970). 2023App. at 569, 283 A.3d at 737. 17 In Fitzgerald, 615 F.Supp.2d at 1158 , the Court of Appeals for the Ninth Circuit had affirmed the District Court’s order granting Fitzgerald a new trial on a ground unrelated to the Brady violation, and, on remand, Fitzgerald moved to dismiss based on the Brady issue. 18 In Lang, 2019 WL 1673317 at *1, 23, upon finding that the government recklessly failed to disclose exculpatory material prior to trial, the trial court granted a motion to dismiss the indictment after the jury had returned a verdict of guilty on bank robbery and conspiracy charges. - 22 - Alfo | 10 | 39 |
Ward v. Stategreen2 sentences2022“In an Alford plea, the defendant, ‘although pleading guilty, continues to deny his or her guilt, but enters the plea to avoid the threat of greater punishment.’” Id. (quoting Ward v. State, 83 Md. 2022“A defendant entering an Alford plea, while maintaining his or her 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.” Id. (citing Jackson v. State, 448 Md. 387 , 391 n.3 (2016)). 8 a liar. | 6 | 13 |
Lee Malvo v. Randall Mathenagreen2 sentences2022He testified for nearly two full days and gave a detailed account of his travels with Mr. Muhammad and their crime spree.14 In affirming Mr. Muhammad’s conviction, the Court of Special Appeals noted that much of what Mr. Malvo testified to 9 The sentencing preceded the 2005 Roper decision that held that the death penalty may not be constitutionally imposed on juvenile offenders. 10 Mathena, 893 F.3d at 268-69 . 11 An Alford plea is the “functional equivalent” of a guilty plea without an actual admission of guilt. 2022He testified for nearly two full days and gave a detailed account of his travels with Mr. Muhammad and their crime spree.14 In affirming Mr. Muhammad’s conviction, the Court of Special Appeals noted that much of what Mr. Malvo testified to 9 The sentencing preceded the 2005 Roper decision that held that the death penalty may not be constitutionally imposed on juvenile offenders. 10 Mathena, 893 F.3d at 268-69 . 11 An Alford plea is the “functional equivalent” of a guilty plea without an actual admission of guilt. | 3 | 3 |
Barnes v. Stategreen2 sentences2016Given that one of the circumstances that comprised Sharp’s counsel’s argument that the circuit court might have been *695 motivated by an impermissible consideration during sentencing was that the circuit court made a “court’s offer,” which Sharp rejected, we will address the propriety of the circuit court having made a “court’s offer.” In Barnes v. State, 70 Md.App. 694, 711, 706, 523 A.2d 635, 643, 641 (1987), the Court of Special Appeals had an opportunity to discuss this topic, and held that a defendant’s Alford plea 15 was involuntary where, “[r]ather than merely approving or rejecting a 2016Given that one of the circumstances that comprised Sharp’s counsel’s argument that the circuit court might have been *695 motivated by an impermissible consideration during sentencing was that the circuit court made a “court’s offer,” which Sharp rejected, we will address the propriety of the circuit court having made a “court’s offer.” In Barnes v. State, 70 Md.App. 694, 711, 706, 523 A.2d 635, 643, 641 (1987), the Court of Special Appeals had an opportunity to discuss this topic, and held that a defendant’s Alford plea 15 was involuntary where, “[r]ather than merely approving or rejecting a | 3 | 3 |
Rudman v. Maryland State Board of Physiciansgreen2 sentences2021State Bd. of Physicians, 414 Md. 243, 262 (2010) (finding that the Board lacked the authority to revoke the defendant’s license where the defendant entered an Alford plea, was not found guilty of a crime and had not admitted to committing any criminal offense). 2016An Alford plea results in a criminal conviction, but it does not always carry the same collateral consequences as an admission of guilt.1 For example, in Rudman v. State Board of Physicians, 414 Md. 243 (2010), a physician accused of assaulting a patient had 1 The Majority cites Bishop v. State, 417 Md. 1, 20 (2010) for the proposition that an Alford plea is the “functional equivalent” of a guilty plea. | 2 | 3 |
Jackson v. Stategreen2 sentences2023“In an Alford plea . . . the 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.” Franklin v. State, 470 Md. 154 , 168 n.1, 235 A.3d 1 , 8 n.1 (2020) (citing Jackson v. State, 448 Md. 387 , 391 n.3, 139 A.3d 976 , 978 n.3 (2016)); see also Smith, 468 Md. at 438 n.6, 227 A.3d at 596 n.6. 2023“In an Alford plea . . . the 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.” Franklin v. State, 470 Md. 154 , 168 n.1, 235 A.3d 1 , 8 n.1 (2020) (citing Jackson v. State, 448 Md. 387 , 391 n.3, 139 A.3d 976 , 978 n.3 (2016)); see also Smith, 468 Md. at 438 n.6, 227 A.3d at 596 n.6. | 1 | 5 |
Mannan v. District of Columbia Board of Medicinegreen2 sentences2010In that case, the District of Columbia Court of Appeals noted that an Alford plea “lies somewhere between a plea of guilty and a plea of nolo contendere, where the defendant, while not admitting guilt, agrees not to contest the alleged acts for the purpose of the criminal case only and the judge accepting the plea has no obligation to determine whether there is a strong evidence of actual guilt.” Mannan, supra, 558 A.2d at 336 . 2010In that case, the District of Columbia Court of Appeals noted that an Alford plea “lies somewhere between a plea of guilty and a plea of nolo contendere, where the defendant, while not admitting guilt, agrees not to contest the alleged acts for the purpose of the criminal case only and the judge accepting the plea has no obligation to determine whether there is a strong evidence of actual guilt.” Mannan, supra, 558 A.2d at 336 . | 1 | 3 |
Faulkner v. State Smith v. Stategreen2 sentences2023“In an Alford plea . . . the 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.” Franklin v. State, 470 Md. 154 , 168 n.1, 235 A.3d 1 , 8 n.1 (2020) (citing Jackson v. State, 448 Md. 387 , 391 n.3, 139 A.3d 976 , 978 n.3 (2016)); see also Smith, 468 Md. at 438 n.6, 227 A.3d at 596 n.6. 2023“In an Alford plea . . . the 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.” Franklin v. State, 470 Md. 154 , 168 n.1, 235 A.3d 1 , 8 n.1 (2020) (citing Jackson v. State, 448 Md. 387 , 391 n.3, 139 A.3d 976 , 978 n.3 (2016)); see also Smith, 468 Md. at 438 n.6, 227 A.3d at 596 n.6. | 1 | 2 |
Foy v. Giant Food Incorporatedgreen2 sentences2010Foy v. Giant Food, Inc., 298 F.3d 284 (2002). 2009In entering his Alford plea, Rudman pleaded guilty to violating section 3-203 of the Criminal Law Article of the Maryland Code (2002), assault in the second degree, which “involves an intentional, harmful physical con *21 tact with the victim that is not legally justified.” Foy v. Giant Food, Inc., 298 F.3d 284, 290 (2002) (citing Cooper v. State, 128 Md.App. 257, 265 , 737 A.2d 613 (1999)). | 1 | 2 |
Tolson v. Stategreen1 sentence2026Caples was subsequently charged with murder and entered an Alford plea.13 Following the entry of the plea, the court found Caples guilty of first- 11 Sinai staff indicated that this progress note was a “corrected result[.]” 12 This fact is not contained in the body of the complaint however is found in the Janofsky Attachment. 13 An Alford plea is a guilty plea “containing a protestation of innocence.” Tolson v. State, 201 Md. | 1 | 1 |
Boykin v. Alabamagreen2 sentences2025The court also confirmed that Davis understood the rights he was waiving by entering an Alford plea, Boykin v. Alabama, 395 U.S. 238, 243 (1969), and intended to enter his plea voluntarily. 2025The court also confirmed that Davis understood the rights he was waiving by entering an Alford plea, Boykin v. Alabama, 395 U.S. 238, 243 (1969), and intended to enter his plea voluntarily. | 1 | 1 |
Ward v. Stategreen1 sentence2025Ward v. State, 290 Md. 76, 83 (1981). 3 The term “Alford plea” is a legal eponym drawn from the United States Supreme Court case, North Carolina v. Alford, 400 U.S. 25 (1970). | 1 | 1 |
Smith v. Stategreen1 sentence2023Smith v. State, 484 Md. 1, 23-24 (2023). 5 the child’s injuries were diagnosed, that K.O. cried when with Mr. Browne, that she had observed Mr. Browne holding K.O. by the ribs, and that she had also observed Mr. Browne handling the child’s leg shortly before she noticed that it was swollen. | 1 | 1 |
| Moore v. Stategreen | 1 | 1 |
| Berger v. United Statesgreen | 1 | 1 |
| Attorney Grievance Commission v. Greenleafgreen | 1 | 1 |
| Holmes v. Stategreen | 1 | 1 |
| Desrosier v. Bissonnettegreen | 1 | 1 |
| Katz v. Pratt Street Realty Co.green | 1 | 1 |
| State v. Zuninogreen | 1 | 1 |
| State v. Baileygreen | 1 | 1 |
| State v. Haynesgreen | 1 | 1 |
| Corbett v. Commonwealthgreen | 1 | 1 |
| Case | Negative | Cited |
|---|---|---|
| No negative-treatment citations attached to this issue in Maryland. Read the followed side critically anyway. | ||
| Case | Cited | Years |
|---|---|---|
Pennington v. State
green
2 sentences2017An " Alford plea," which derives its name from North Carolina v. Alford , 400 U.S. 25 , 91 S.Ct. 160 , 27 L.Ed.2d 162 (1970), "is 'a guilty plea containing a protestation of innocence.' Marshall v. State , 346 Md. 186 , 189 n. 2, 695 A.2d 184 , 185 n. 2 (1997), citing Pennington v. State , 308 Md. 727 , 728 n. 1, 521 A.2d 1216 , 1216 n. 1 (1987)." Silver v. State , 420 Md. 415 , 424 n.4, 23 A.3d 867 (2011). 2017An " Alford plea," which derives its name from North Carolina v. Alford , 400 U.S. 25 , 91 S.Ct. 160 , 27 L.Ed.2d 162 (1970), "is 'a guilty plea containing a protestation of innocence.' Marshall v. State , 346 Md. 186 , 189 n. 2, 695 A.2d 184 , 185 n. 2 (1997), citing Pennington v. State , 308 Md. 727 , 728 n. 1, 521 A.2d 1216 , 1216 n. 1 (1987)." Silver v. State , 420 Md. 415 , 424 n.4, 23 A.3d 867 (2011). | 4 | 1990–2017 |
Marshall v. State
green
2 sentences2017An " Alford plea," which derives its name from North Carolina v. Alford , 400 U.S. 25 , 91 S.Ct. 160 , 27 L.Ed.2d 162 (1970), "is 'a guilty plea containing a protestation of innocence.' Marshall v. State , 346 Md. 186 , 189 n. 2, 695 A.2d 184 , 185 n. 2 (1997), citing Pennington v. State , 308 Md. 727 , 728 n. 1, 521 A.2d 1216 , 1216 n. 1 (1987)." Silver v. State , 420 Md. 415 , 424 n.4, 23 A.3d 867 (2011). 2017An " Alford plea," which derives its name from North Carolina v. Alford , 400 U.S. 25 , 91 S.Ct. 160 , 27 L.Ed.2d 162 (1970), "is 'a guilty plea containing a protestation of innocence.' Marshall v. State , 346 Md. 186 , 189 n. 2, 695 A.2d 184 , 185 n. 2 (1997), citing Pennington v. State , 308 Md. 727 , 728 n. 1, 521 A.2d 1216 , 1216 n. 1 (1987)." Silver v. State , 420 Md. 415 , 424 n.4, 23 A.3d 867 (2011). | 4 | 2008–2017 |
State v. Nelson
green
2 sentences2022Id. at 560-61 . 2022Id. at 560-61 . | 3 | 2022–2022 |
Vitek v. Jones
green
2 sentences2019In Vitek , 445 U.S. at 480 , 100 S.Ct. 1254 , the Supreme Court held that there is a protected liberty interest at stake in freedom from involuntary transfer to a mental hospital. 2019In Vitek , 445 U.S. at 480 , 100 S.Ct. 1254 , the Supreme Court held that there is a protected liberty interest at stake in freedom from involuntary transfer to a mental hospital. | 3 | 2019–2019 |
Abrams v. State
green
2 sentences2010As to Petitioner’s argument that his Alford plea did not constitute a guilty plea for purposes of H.O. § 14-404(b)(l), the CSA stated: An Alford plea, under Maryland law, is a guilty plea, albeit a “ ‘specialized type of guilty plea where the defendant, although pleading guilty, continues to deny his or her guilt, but enters the plea to avoid the threat of greater punishment.’ ” Abrams v. State, 176 Md.App. 600 , 603 n. 1, 933 A.2d 887 (2007) (quoting Ward v. State, 83 Md.App. 474, 478 , 575 A.2d 771 (1990)). 2010As to Petitioner’s argument that his Alford plea did not constitute a guilty plea for purposes of H.O. § 14-404(b)(l), the CSA stated: An Alford plea, under Maryland law, is a guilty plea, albeit a “ ‘specialized type of guilty plea where the defendant, although pleading guilty, continues to deny his or her guilt, but enters the plea to avoid the threat of greater punishment.’ ” Abrams v. State, 176 Md.App. 600 , 603 n. 1, 933 A.2d 887 (2007) (quoting Ward v. State, 83 Md.App. 474, 478 , 575 A.2d 771 (1990)). | 3 | 2009–2010 |
Hudson v. State
green
2 sentences1990North Carolina v. Alford, 400 U.S. 25, 37 , 91 S.Ct. 160, 167 , 27 L.Ed.2d 162 (1970); Hudson v. State, 286 Md. 569, 597-98 , 409 A.2d 692 (1979), cert. denied, 449 U.S. 845 , 101 S.Ct. 128 , 66 L.Ed.2d 53 (1980). 1990North Carolina v. Alford, 400 U.S. 25, 37 , 91 S.Ct. 160, 167 , 27 L.Ed.2d 162 (1970); Hudson v. State, 286 Md. 569, 597-98 , 409 A.2d 692 (1979), cert. denied, 449 U.S. 845 , 101 S.Ct. 128 , 66 L.Ed.2d 53 (1980). | 2 | 1988–1990 |
Hudson v. Maryland
green
2 sentences1990North Carolina v. Alford, 400 U.S. 25, 37 , 91 S.Ct. 160, 167 , 27 L.Ed.2d 162 (1970); Hudson v. State, 286 Md. 569, 597-98 , 409 A.2d 692 (1979), cert. denied, 449 U.S. 845 , 101 S.Ct. 128 , 66 L.Ed.2d 53 (1980). 1988Hudson v. State, 286 Md. 569, 598-99 , 409 A.2d 692 (1979), cert. denied, 449 U.S. 845 , 101 S.Ct. 128 , 66 L.Ed.2d 53 (1980). 2 . | 2 | 1988–1990 |
Brown v. Mitchell
green
2 sentences1990North Carolina v. Alford, 400 U.S. 25, 37 , 91 S.Ct. 160, 167 , 27 L.Ed.2d 162 (1970); Hudson v. State, 286 Md. 569, 597-98 , 409 A.2d 692 (1979), cert. denied, 449 U.S. 845 , 101 S.Ct. 128 , 66 L.Ed.2d 53 (1980). 1988Hudson v. State, 286 Md. 569, 598-99 , 409 A.2d 692 (1979), cert. denied, 449 U.S. 845 , 101 S.Ct. 128 , 66 L.Ed.2d 53 (1980). 2 . | 2 | 1988–1990 |
Annicaro v. Florida
green
2 sentences1990North Carolina v. Alford, 400 U.S. 25, 37 , 91 S.Ct. 160, 167 , 27 L.Ed.2d 162 (1970); Hudson v. State, 286 Md. 569, 597-98 , 409 A.2d 692 (1979), cert. denied, 449 U.S. 845 , 101 S.Ct. 128 , 66 L.Ed.2d 53 (1980). 1988Hudson v. State, 286 Md. 569, 598-99 , 409 A.2d 692 (1979), cert. denied, 449 U.S. 845 , 101 S.Ct. 128 , 66 L.Ed.2d 53 (1980). 2 . | 2 | 1988–1990 |
Parker v. State
green
2 sentences2025Parker, 160 Md. 2025Parker, 160 Md. | 1 | 2025–2025 |
United States v. Fitzgerald
green
1 sentence2023App. at 569, 283 A.3d at 737. 17 In Fitzgerald, 615 F.Supp.2d at 1158 , the Court of Appeals for the Ninth Circuit had affirmed the District Court’s order granting Fitzgerald a new trial on a ground unrelated to the Brady violation, and, on remand, Fitzgerald moved to dismiss based on the Brady issue. 18 In Lang, 2019 WL 1673317 at *1, 23, upon finding that the government recklessly failed to disclose exculpatory material prior to trial, the trial court granted a motion to dismiss the indictment after the jury had returned a verdict of guilty on bank robbery and conspiracy charges. - 22 - Alfo | 1 | 2023–2023 |
Cain v. State
green
2 sentences2023“An Alford plea arises when a defendant maintains his or her innocence, but concedes that the State could adduce enough evidence to prove him or her guilty of the crime charged[.]” Cain v. State, 386 Md. 320 , 326 n.7, 872 A.2d 681 , 684 n.7 (2005). 2023“An Alford plea arises when a defendant maintains his or her innocence, but concedes that the State could adduce enough evidence to prove him or her guilty of the crime charged[.]” Cain v. State, 386 Md. 320 , 326 n.7, 872 A.2d 681 , 684 n.7 (2005). | 1 | 2023–2023 |
Franklin v. State
green
2 sentences2023With an Alford plea, a defendant maintains innocence but “agrees to a proffer of stipulated evidence or to an agreed statement of facts that provides a factual basis for a finding of guilt.” Franklin v. State, 470 Md. 154 , 168 n.1, 235 A.3d 1 , 8 n.1 (2020) (citation omitted); see also Md. 2023With an Alford plea, a defendant maintains innocence but “agrees to a proffer of stipulated evidence or to an agreed statement of facts that provides a factual basis for a finding of guilt.” Franklin v. State, 470 Md. 154 , 168 n.1, 235 A.3d 1 , 8 n.1 (2020) (citation omitted); see also Md. | 1 | 2023–2023 |
Attorney Grievance Commission v. Smith
green
2 sentences2023App. at 569, 283 A.3d at 737. 17 In Fitzgerald, 615 F.Supp.2d at 1158 , the Court of Appeals for the Ninth Circuit had affirmed the District Court’s order granting Fitzgerald a new trial on a ground unrelated to the Brady violation, and, on remand, Fitzgerald moved to dismiss based on the Brady issue. 18 In Lang, 2019 WL 1673317 at *1, 23, upon finding that the government recklessly failed to disclose exculpatory material prior to trial, the trial court granted a motion to dismiss the indictment after the jury had returned a verdict of guilty on bank robbery and conspiracy charges. - 22 - Alfo 2023App. at 569, 283 A.3d at 737. 17 In Fitzgerald, 615 F.Supp.2d at 1158 , the Court of Appeals for the Ninth Circuit had affirmed the District Court’s order granting Fitzgerald a new trial on a ground unrelated to the Brady violation, and, on remand, Fitzgerald moved to dismiss based on the Brady issue. 18 In Lang, 2019 WL 1673317 at *1, 23, upon finding that the government recklessly failed to disclose exculpatory material prior to trial, the trial court granted a motion to dismiss the indictment after the jury had returned a verdict of guilty on bank robbery and conspiracy charges. - 22 - Alfo | 1 | 2023–2023 |
Smith v. State
green
2 sentences2022He stated that, “in exchange for his testimony against appellant and his agreement to enter an Alford plea to the crime of involuntary manslaughter for his role in Ms. Wilford’s murder, the prosecutor would recommend that he be sentenced to five years.” Smith, 233 Md. 2022App. at 387 .8 He testified, however, “that he had not been promised any financial reward or incentive to testify.” Id. at 388 . | 1 | 2022–2022 |
Tabassi v. Carroll County Department of Social Services
green
1 sentence2018Id. at 83 . | 1 | 2018–2018 |
| Jackson v. State green | 1 | 2017–2017 |
| Silver v. State green | 1 | 2017–2017 |
| Strickland v. Washington green | 1 | 2016–2016 |
| Attorney Grievance Commission v. Coppock green | 1 | 2015–2015 |
| Attorney Grievance Commission v. Thompson green | 1 | 2015–2015 |
| Attorney Grievance Commission of Maryland v. Thomas green | 1 | 2012–2012 |
| Rios v. State green | 1 | 2010–2010 |
| Cooper v. State green | 1 | 2009–2009 |
| State v. Priet green | 1 | 2009–2009 |
| Tomlin v. State green | 1 | 2009–2009 |
| State v. Harned green | 1 | 2009–2009 |
| Parren v. State green | 1 | 2007–2007 |
| Apprendi v. New Jersey green | 1 | 2005–2005 |
| Pennington v. State neutral | 1 | 1990–1990 |
| Yanes v. State green | 1 | 1990–1990 |
| Williams v. State green | 1 | 1987–1987 |
Counted by distinct opinions that both name this issue and are annotated to the section; sections every opinion cites regardless of issue are not filtered here, so read the counts against the total above.
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.