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47 Maryland opinions name it 2 courts 1963–2025 4 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 |
|---|---|---|
Hof v. Stategreen2 sentences2023Our analysis, therefore, is shaped mainly by two overarching precepts: (1) that the jury (or factfinder) must determine the voluntariness of a defendant’s statement to law enforcement if the issue is generated at trial; and (2) only “some evidence” of involuntariness is required to generate a voluntariness instruction. 48 First, the voluntariness of a defendant’s statement is evaluated under Maryland’s “two-tiered approach” articulated in Hof v. State, 337 Md. 581, 604 (1995). 2023According to the State, Hof v. State, 337 Md. 581, 604 (1995), requires that a voluntariness challenge must be litigated before the court in a pretrial suppression motion. | 3 | 4 |
State v. Raithelgreen2 sentences1989We rest our decision solely on Maryland nonconstitutional law because of the well-settled principle ‘that courts should not decide constitutional issues unnecessarily.’ State v. Raithel, 285 Md. 478, 484 , 404 A.2d 264, 267 (1979). 1989We rest our decision solely on Maryland nonconstitutional law because of the well-settled principle ‘that courts should not decide constitutional issues unnecessarily.’ State v. Raithel, 285 Md. 478, 484 , 404 A.2d 264, 267 (1979). | 2 | 2 |
Hillard v. Stategreen2 sentences1993No Maryland decision has ever pointed to a single difference between the common law voluntariness test as applied here and as applied by the Supreme Court. 2 Hillard v. State, 286 Md. 145 , 406 A.2d 415 (1979), to be sure, chose to operate on the unsubstantiated assumption that there might be some difference, but eschewed any effort to make the comparison: “We in no way attempt in this case to evaluate whether federal or Maryland constitutional law establishes the same voluntariness test as that enunciated in this opinion.” 286 Md. at 150 n. 1, 406 A.2d 415 . 1993No Maryland decision has ever pointed to a single difference between the common law voluntariness test as applied here and as applied by the Supreme Court. 2 Hillard v. State, 286 Md. 145 , 406 A.2d 415 (1979), to be sure, chose to operate on the unsubstantiated assumption that there might be some difference, but eschewed any effort to make the comparison: “We in no way attempt in this case to evaluate whether federal or Maryland constitutional law establishes the same voluntariness test as that enunciated in this opinion.” 286 Md. at 150 n. 1, 406 A.2d 415 . | 1 | 3 |
Abeokuto v. Stategreen2 sentences2013As to the voluntariness prong, the court held that Valonis did not allege “a triggering fact or information which suggests [he] was coerced or induced to waive his rights[,]” or “that the absence of a voluntariness inquiry at his trial was error.” Thus, the intermediate appellate court held, in consideration of our holding in Abeokuto v. State, 391 Md. 289, 320-21 , 893 A.2d 1018, 1036 (2006), Valonis’s waiver was knowing and voluntary. 2013As to the voluntariness prong, the court held that Valonis did not allege “a triggering fact or information which suggests [he] was coerced or induced to waive his rights[,]” or “that the absence of a voluntariness inquiry at his trial was error.” Thus, the intermediate appellate court held, in consideration of our holding in Abeokuto v. State, 391 Md. 289, 320-21 , 893 A.2d 1018, 1036 (2006), Valonis’s waiver was knowing and voluntary. | 1 | 2 |
Tibbs v. Stategreen2 sentences2013We note that with regard to the examination, the trial judge is required to do more than merely “go through the motions.” See Tibbs, 323 Md. at 32 , 590 A.2d at 551 (noting that “[i]t is not sufficient that an accused merely respond affirmatively to a naked inquiry ... ”); see also Patton v. U.S., 281 U.S. 276, 312-13 , 50 S.Ct. 253, 263 , 74 L.Ed. 854, 870 (1930), overruled on other grounds by Williams v. Florida, 399 U.S. 78 , 90 S.Ct. 1893 , 26 L.Ed.2d 446 (1970) (noting that “the duty of the trial court ... is not to be discharged as a mere matter of rote, but with sound and advised discre 2013We note that with regard to the examination, the trial judge is required to do more than merely “go through the motions.” See Tibbs, 323 Md. at 32 , 590 A.2d at 551 (noting that “[i]t is not sufficient that an accused merely respond affirmatively to a naked inquiry ... ”); see also Patton v. U.S., 281 U.S. 276, 312-13 , 50 S.Ct. 253, 263 , 74 L.Ed. 854, 870 (1930), overruled on other grounds by Williams v. Florida, 399 U.S. 78 , 90 S.Ct. 1893 , 26 L.Ed.2d 446 (1970) (noting that “the duty of the trial court ... is not to be discharged as a mere matter of rote, but with sound and advised discre | 1 | 2 |
Martinez v. Stategreen2 sentences2005Although we recognize that “this is the preferable practice,” id. at 134 n. 11, 522 A.2d 950 , we are nevertheless instructed by the Court of Appeals that “[t]he trial judge need not follow a specific ritual or fixed litany in determining the voluntariness of the defendant’s election to waive his jury right.” Id. 1990“Whether there is an intelligent waiver must depend on the unique facts and circumstances of each case.” Martinez at 134, 522 A.2d 950 . *91 This appeal turns on the voluntariness of the waiver of Stewart’s right to a jury trial. | 1 | 2 |
Carder v. Stategreen2 sentences1998See also State v. Kidd, 281 Md. 32, 35-36 , 375 A.2d 1105, 1108 (1977) (“For a statement to be the free and voluntary act of an accused, it must be obtained without force applied, coercion used, hope *178 held out or promise made on the part of the authorities.”) (emphasis added); Carder v. State, 5 Md.App. 531, 539 , 248 A.2d 495, 500 (1968) (holding that the voluntariness test does not apply to a civilian witness who was not associated with the police and whose only purpose was to assist the injured defendant). 1998See also State v. Kidd, 281 Md. 32, 35-36 , 375 A.2d 1105, 1108 (1977) (“For a statement to be the free and voluntary act of an accused, it must be obtained without force applied, coercion used, hope *178 held out or promise made on the part of the authorities.”) (emphasis added); Carder v. State, 5 Md.App. 531, 539 , 248 A.2d 495, 500 (1968) (holding that the voluntariness test does not apply to a civilian witness who was not associated with the police and whose only purpose was to assist the injured defendant). | 1 | 2 |
Nicholson v. Stategreen2 sentences1993Nicholson v. State, 38 Md. 140 .” Watts v. State, 99 Md. 30, 35-36 , 57 A. 542 (1904), is interesting not so much because it reversed a conviction for *260 the failure of the State to prove that the confession in issue was “freely and voluntarily made” but for the authorities it cites. 1993More than a century ago, in Nicholson v. State, 38 Md. 140,153 (1873) this Court said that ‘it is very clear upon all the authorities, that if the confession of the [accused] had been induced by any threat of harm, or promise of worldly advantage held out to him ... it ought to be excluded.’ ” (emphasis supplied). | 1 | 2 |
Metheny v. Stategreen1 sentence2020App. at 255 ; see Metheny, 359 Md. at 600 (“[T]he factual basis requirement . . . is closely associated with the due process mandate that a defendant enter a guilty plea voluntarily.”). | 1 | 1 |
Patton v. United Statesred2 sentences2013We note that with regard to the examination, the trial judge is required to do more than merely “go through the motions.” See Tibbs, 323 Md. at 32 , 590 A.2d at 551 (noting that “[i]t is not sufficient that an accused merely respond affirmatively to a naked inquiry ... ”); see also Patton v. U.S., 281 U.S. 276, 312-13 , 50 S.Ct. 253, 263 , 74 L.Ed. 854, 870 (1930), overruled on other grounds by Williams v. Florida, 399 U.S. 78 , 90 S.Ct. 1893 , 26 L.Ed.2d 446 (1970) (noting that “the duty of the trial court ... is not to be discharged as a mere matter of rote, but with sound and advised discre 2013We note that with regard to the examination, the trial judge is required to do more than merely “go through the motions.” See Tibbs, 323 Md. at 32 , 590 A.2d at 551 (noting that “[i]t is not sufficient that an accused merely respond affirmatively to a naked inquiry ... ”); see also Patton v. U.S., 281 U.S. 276, 312-13 , 50 S.Ct. 253, 263 , 74 L.Ed. 854, 870 (1930), overruled on other grounds by Williams v. Florida, 399 U.S. 78 , 90 S.Ct. 1893 , 26 L.Ed.2d 446 (1970) (noting that “the duty of the trial court ... is not to be discharged as a mere matter of rote, but with sound and advised discre | 1 | 1 |
Williams v. Floridagreen2 sentences2013We note that with regard to the examination, the trial judge is required to do more than merely “go through the motions.” See Tibbs, 323 Md. at 32 , 590 A.2d at 551 (noting that “[i]t is not sufficient that an accused merely respond affirmatively to a naked inquiry ... ”); see also Patton v. U.S., 281 U.S. 276, 312-13 , 50 S.Ct. 253, 263 , 74 L.Ed. 854, 870 (1930), overruled on other grounds by Williams v. Florida, 399 U.S. 78 , 90 S.Ct. 1893 , 26 L.Ed.2d 446 (1970) (noting that “the duty of the trial court ... is not to be discharged as a mere matter of rote, but with sound and advised discre 2013We note that with regard to the examination, the trial judge is required to do more than merely “go through the motions.” See Tibbs, 323 Md. at 32 , 590 A.2d at 551 (noting that “[i]t is not sufficient that an accused merely respond affirmatively to a naked inquiry ... ”); see also Patton v. U.S., 281 U.S. 276, 312-13 , 50 S.Ct. 253, 263 , 74 L.Ed. 854, 870 (1930), overruled on other grounds by Williams v. Florida, 399 U.S. 78 , 90 S.Ct. 1893 , 26 L.Ed.2d 446 (1970) (noting that “the duty of the trial court ... is not to be discharged as a mere matter of rote, but with sound and advised discre | 1 | 1 |
| United States v. Capersgreen | 1 | 1 |
| Dempsey v. Stategreen | 1 | 1 |
| Maryland State Fair & Agricultural Society, Inc. v. Leegreen | 1 | 1 |
| Mirabal v. Stategreen | 1 | 1 |
| Commonwealth v. Coopergreen | 1 | 1 |
| State v. Carrollgreen | 1 | 1 |
| People v. Seymourgreen | 1 | 1 |
| State v. Kiddgreen | 1 | 1 |
| State v. McCulloughgreen | 1 | 1 |
| State v. Bowegreen | 1 | 1 |
| Darghty v. Stategreen | 1 | 1 |
| Arizona v. Fulminantegreen | 1 | 1 |
| Davis v. North Carolinagreen | 1 | 1 |
| Case | Negative | Cited |
|---|---|---|
| No negative-treatment citations attached to this issue in Maryland. Read the followed side critically anyway. | ||
| Case | Cited | Years |
|---|---|---|
Miranda v. Arizona
green
2 sentences2001Further, the confession must conform with Miranda v. Arizona, 384 U.S. 436 , 86 S.Ct. 1602 , 16 L.Ed.2d 694 (1966), and those cases interpreting it. 1969There the confessions were invalid, not because they were coerced, but because they were made in the absence of requested counsel and without effective warnings of the constitutional right to remain silent, the Court having decided in Gideon v. Wainwright, 372 U. S. 355 (1963) that an accused has the right to counsel in all criminal cases. 5 Questions left unanswered in Escobedo were resolved in Miranda v. Arizona, 384 U. S. 436 (1966). 6 It enunciated procedural guidelines and exclusionary rules if they were not followed, but it did not discard the old voluntariness test entirely. 7 *300 It i | 3 | 1969–2001 |
Culombe v. Connecticut
green
2 sentences1980Concluding that "the voluntariness standard is a hopelessly inadequate means of safeguarding a defendant's right of prompt presentment," id. at 325 , Johnson declined to follow the majority view. 1980Concluding that "the voluntariness standard is a hopelessly inadequate means of safeguarding a defendant’s right of prompt presentment,” id. at 325 , Johnson declined to follow the majority view. | 3 | 1963–1996 |
State v. Thornton
green
2 sentences2020Accordingly, “[t]he factual basis requirement is inextricably linked to the voluntariness requirement.” Thornton, 73 Md. 1991We observed, at 73 Md.App. at 255-256 , 533 A.2d 951 : “The factual basis requirement is inextricably linked to the voluntariness requirement. | 2 | 1991–2020 |
Williams v. State
green
2 sentences2010The Williams case involved a delay of forty-seven hours between arrest and presentment, a clear violation of the twenty-four-hour requirement embodied in Maryland Rule 4-212. 375 Md. at 414, 825 A.2d 1078 . 2003As Judge Wilner explained in Williams v. State, 375 Md. 404 , 825 A.2d 1078 (2003): The test under the statute, and under the Constitution, remains voluntariness. | 2 | 2003–2010 |
Schneckloth v. Bustamonte
green
2 sentences2010If the appellant either 1) was not subject to any Fourth Amendment detention of his person or 2) was subject to lawful detention, the voluntariness standard of Schneckloth v. Bustamonte, 412 U.S. 218 , 93 S.Ct. 2041 , 36 L.Ed.2d 854 (1973), would apply. 2010If the appellant either 1) was not subject to any Fourth Amendment detention of his person or 2) was subject to lawful detention, the voluntariness standard of Schneckloth v. Bustamonte, 412 U.S. 218 , 93 S.Ct. 2041 , 36 L.Ed.2d 854 (1973), would apply. | 2 | 1990–2010 |
Hof v. State
green
2 sentences2002In Hof v. State, 97 Md.App. 242, 285-94 , 629 A.2d 1251 (1993), rev'd on other grounds, 337 Md. 581 , 655 A.2d 370 (1995), this Court analyzed in some depth why the satisfaction of Miranda is almost always an ipso facto satisfaction of the voluntariness test embodied in the Fifth and Fourteenth Amendments. 13 . 2002In Hof v. State, 97 Md.App. 242, 285-94 , 629 A.2d 1251 (1993), rev'd on other grounds, 337 Md. 581 , 655 A.2d 370 (1995), this Court analyzed in some depth why the satisfaction of Miranda is almost always an ipso facto satisfaction of the voluntariness test embodied in the Fifth and Fourteenth Amendments. 13 . | 2 | 1995–2002 |
Colorado v. Connelly
green
2 sentences1998Again, as he has conceded that there is no State action in this case, we agree that such an argument is foreclos *677 ed. See, e.g., Reynolds v. State, 327 Md. 494, 504 , 610 A.2d 782 (1992); Colorado v. Connelly, 479 U.S. 157, 164 , 107 S.Ct. 515, 520 , 93 L.Ed.2d 473 (1986). 3 Rather, Pappas concedes that the only basis upon which his confession could possibly be suppressed is under Maryland’s common law doctrine of voluntariness. 1998Again, as he has conceded that there is no State action in this case, we agree that such an argument is foreclos *677 ed. See, e.g., Reynolds v. State, 327 Md. 494, 504 , 610 A.2d 782 (1992); Colorado v. Connelly, 479 U.S. 157, 164 , 107 S.Ct. 515, 520 , 93 L.Ed.2d 473 (1986). 3 Rather, Pappas concedes that the only basis upon which his confession could possibly be suppressed is under Maryland’s common law doctrine of voluntariness. | 2 | 1998–1998 |
Linkins v. State
green
2 sentences1993In the 1940’s, common law voluntariness was the basis for decision in Lubinski v. State, 180 Md. 1, 4-8 , 22 A.2d 455 (1941) (inducement of “It will help you a lot”); Taylor v. State, 187 Md. 306, 310-312 , 49 A.2d 787 (1946) (threat of violence and claim of actual beating); Jones v. State, 188 Md. 263, 268-271 , 52 A.2d 484 (1947) (suspect held under arrest and without counsel; threat of mob violence); Smith v. State, 189 Md. 596, 603-606 , 56 A.2d 818 (1948) (claim of threatened beating); and Cox v. State, 192 Md. 525, 531-537 , 64 A.2d 732 (1949) (defendant not taken promptly before committ 1993In the 1940’s, common law voluntariness was the basis for decision in Lubinski v. State, 180 Md. 1, 4-8 , 22 A.2d 455 (1941) (inducement of “It will help you a lot”); Taylor v. State, 187 Md. 306, 310-312 , 49 A.2d 787 (1946) (threat of violence and claim of actual beating); Jones v. State, 188 Md. 263, 268-271 , 52 A.2d 484 (1947) (suspect held under arrest and without counsel; threat of mob violence); Smith v. State, 189 Md. 596, 603-606 , 56 A.2d 818 (1948) (claim of threatened beating); and Cox v. State, 192 Md. 525, 531-537 , 64 A.2d 732 (1949) (defendant not taken promptly before committ | 2 | 1993–1995 |
Kier v. State
green
2 sentences1993In the 1940’s, common law voluntariness was the basis for decision in Lubinski v. State, 180 Md. 1, 4-8 , 22 A.2d 455 (1941) (inducement of “It will help you a lot”); Taylor v. State, 187 Md. 306, 310-312 , 49 A.2d 787 (1946) (threat of violence and claim of actual beating); Jones v. State, 188 Md. 263, 268-271 , 52 A.2d 484 (1947) (suspect held under arrest and without counsel; threat of mob violence); Smith v. State, 189 Md. 596, 603-606 , 56 A.2d 818 (1948) (claim of threatened beating); and Cox v. State, 192 Md. 525, 531-537 , 64 A.2d 732 (1949) (defendant not taken promptly before committ 1993In the 1940’s, common law voluntariness was the basis for decision in Lubinski v. State, 180 Md. 1, 4-8 , 22 A.2d 455 (1941) (inducement of “It will help you a lot”); Taylor v. State, 187 Md. 306, 310-312 , 49 A.2d 787 (1946) (threat of violence and claim of actual beating); Jones v. State, 188 Md. 263, 268-271 , 52 A.2d 484 (1947) (suspect held under arrest and without counsel; threat of mob violence); Smith v. State, 189 Md. 596, 603-606 , 56 A.2d 818 (1948) (claim of threatened beating); and Cox v. State, 192 Md. 525, 531-537 , 64 A.2d 732 (1949) (defendant not taken promptly before committ | 2 | 1968–1993 |
Keller v. State
green
2 sentences1993To be voluntary, a statement cannot be “extracted by any sort of threats or violence, nor obtained by any direct or implied promises, however slight, nor by the exertion of any improper influence.” ’ Keller v. State, 2 Md.App. 628, 626-627 [ 236 A.2d 313 (1967) ], quoting Malloy v. Hogan, 378 U.S. 1, 7 , [ 84 S.Ct. at 1493 ].” (emphasis supplied). 1969“The basic standard governing the admissibility of an extrajudicial statement is whether, considering the totality of the circumstances, the statement was voluntary * * * To be voluntary, a statement cannot be ‘extracted by any sort of threats or violence, nor obtained by any direct or implied promises, however slight, nor by the exertion of any improper influence.’ ” Keller v. State, 2 Md. | 2 | 1969–1993 |
Dennis v. Warden, Maryland Penitentiary
green
2 sentences1993The regular cross-referencing and cross-fertilization between the Supreme Court and the Court of Appeals over the decades, moreover, reinforces this identity- Indeed, far from being a bold assertion, it may merely be a recognition of the wisdom of Judge Orth, a quarter of a century ago, in Dennis v. Warden, 6 Md.App. 295, 300 , 251 A.2d 909 (1969): *284 “It is clear that the rule established in this State is in accord with the voluntariness test followed by the Supreme Court. ‘The basic standard governing the admissibility of an extrajudicial statement is whether, considering the totality of t 1993The regular cross-referencing and cross-fertilization between the Supreme Court and the Court of Appeals over the decades, moreover, reinforces this identity- Indeed, far from being a bold assertion, it may merely be a recognition of the wisdom of Judge Orth, a quarter of a century ago, in Dennis v. Warden, 6 Md.App. 295, 300 , 251 A.2d 909 (1969): *284 “It is clear that the rule established in this State is in accord with the voluntariness test followed by the Supreme Court. ‘The basic standard governing the admissibility of an extrajudicial statement is whether, considering the totality of t | 2 | 1977–1993 |
Bean v. State
green
2 sentences1987Similarly, in Bean v. State, 234 Md. 432 , 199 A.2d 773 (1964), there was no request to see a parent by the juvenile, and the Court specifically considered this fact, as well as the juvenile’s age and mental ability, in determining the voluntariness of the waiver and subsequent confession. 1987Similarly, in Bean v. State, 234 Md. 432 , 199 A.2d 773 (1964), there was no request to see a parent by the juvenile, and the Court specifically considered this fact, as well as the juvenile’s age and mental ability, in determining the voluntariness of the waiver and subsequent confession. | 2 | 1987–1993 |
Pablo Carreon v. United States
green
2 sentences1991In Carreon v. United States, 578 F.2d 176 (7th Cir.1978), the appellate court found the trial court had violated the factual basis requirement of Rule 11 by relying on counsel’s statement that the defendant had been informed about possible defenses. 1987In Carreon v. U.S., 578 F.2d 176 (7th Cir.1978), the appellate court found the trial court had violated the factual basis requirement of Rule 11 by relying on counsel’s statement that the defendant had been informed about possible defenses. | 2 | 1987–1991 |
McNabb v. United States
green
2 sentences1981Despite the array of contrary authority, we were convinced in Johnson that the view we there adopted, following the lead of the United States Supreme Court in Mallory v. United States, 354 U.S. 449 , 77 S.Ct. 1356 , 1 L.Ed.2d 1479 (1957), and McNabb v. United States, 318 U.S. 332 , 63 S.Ct. 608 , 87 L.Ed. 819 (1943), was the sound position. [6] The Supreme Court thus stated in Miranda (394 U.S. at 444-445, emphasis supplied): "As for the procedural safeguards to be employed, unless other fully effective means are devised to inform accused persons of their right of silence and to assure a conti 1981Despite the array of contrary authority, we were convinced in Johnson that the view we there adopted, following the lead of the United States Supreme Court in Mallory v. United States, 354 U.S. 449 , 77 S.Ct. 1356 , 1 L.Ed.2d 1479 (1957), and McNabb v. United States, 318 U.S. 332 , 63 S.Ct. 608 , 87 L.Ed. 819 (1943), was the sound position. [6] The Supreme Court thus stated in Miranda (394 U.S. at 444-445, emphasis supplied): "As for the procedural safeguards to be employed, unless other fully effective means are devised to inform accused persons of their right of silence and to assure a conti | 2 | 1963–1981 |
Mallory v. United States
green
2 sentences1981Despite the array of contrary authority, we were convinced in Johnson that the view we there adopted, following the lead of the United States Supreme Court in Mallory v. United States, 354 U.S. 449 , 77 S. Ct. 1356 , 1 L. 1981Despite the array of contrary authority, we were convinced in Johnson that the view we there adopted, following the lead of the United States Supreme Court in Mallory v. United States, 354 U.S. 449 , 77 S. Ct. 1356 , 1 L. | 2 | 1963–1981 |
Aguilera v. State
green
1 sentence2023Rather, in the absence of a trigger, the court is permitted to make its voluntariness determination based on the defendant’s demeanor, without asking any specific questions about voluntariness.” Aguilera, 193 Md. | 1 | 2023–2023 |
Forman v. Motor Vehicle Administration
green
2 sentences2018Evaluating the voluntariness of the waiver In addressing the voluntariness of any consent to testing, this Court has stated, "a person detained for drunk driving must be capable of making a knowing and voluntary decision to refuse the alcohol concentration test." Forman v. Motor Vehicle Administration , 332 Md. 201 , 218, 630 A.2d 753 , 762 (1993). 2018Evaluating the voluntariness of the waiver In addressing the voluntariness of any consent to testing, this Court has stated, "a person detained for drunk driving must be capable of making a knowing and voluntary decision to refuse the alcohol concentration test." Forman v. Motor Vehicle Administration , 332 Md. 201 , 218, 630 A.2d 753 , 762 (1993). | 1 | 2018–2018 |
Valonis v. State
green
2 sentences2014Valonis, 431 Md. at 567 , 66 A.3d at 670 . 2014Valonis, 431 Md. at 567 , 66 A.3d at 670 . | 1 | 2014–2014 |
State v. Daughtry
green
2 sentences2012Judge Harrell described the voluntariness standard in State v. Daughtry, 419 Md. 35, 79-80 , 18 A.3d 60 (2011): Our decision in the present case in no way “overrules prior law and declares a new principle of law.” The law of this State with respect to the voluntariness of guilty pleas has been the same over the past thirty years since we decided Piiet (if not longer): “[WJhether, considering the record as a whole, the trial judge could fairly determine that the defendant understood the nature of the charge to which he pleaded guilty.” ... 2012Judge Harrell described the voluntariness standard in State v. Daughtry, 419 Md. 35, 79-80 , 18 A.3d 60 (2011): Our decision in the present case in no way “overrules prior law and declares a new principle of law.” The law of this State with respect to the voluntariness of guilty pleas has been the same over the past thirty years since we decided Piiet (if not longer): “[WJhether, considering the record as a whole, the trial judge could fairly determine that the defendant understood the nature of the charge to which he pleaded guilty.” ... | 1 | 2012–2012 |
| Rountree v. Lerner Development Co. green | 1 | 2011–2011 |
| Florida v. Royer green | 1 | 2010–2010 |
| Facon v. State green | 1 | 2010–2010 |
| Zylanz v. State green | 1 | 2006–2006 |
| Kang v. State green | 1 | 2006–2006 |
| Thornton v. State neutral | 1 | 2006–2006 |
| People v. Collins green | 1 | 2003–2003 |
| Beck v. Mangels green | 1 | 2002–2002 |
| Ohio v. Robinette green | 1 | 2002–2002 |
| Ferris v. State green | 1 | 2002–2002 |
| Scott v. State green | 1 | 1998–1998 |
| Reynolds v. State green | 1 | 1998–1998 |
| Mullaney v. Wilbur green | 1 | 1995–1995 |
| White v. State green | 1 | 1993–1993 |
| Wiggins v. State green | 1 | 1993–1993 |
| Combs v. State green | 1 | 1993–1993 |
| Mercer v. State green | 1 | 1993–1993 |
| Miller v. State green | 1 | 1993–1993 |
| Cox v. State green | 1 | 1993–1993 |
| Lubinski v. State green | 1 | 1993–1993 |
| Jones v. State green | 1 | 1993–1993 |
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.