Peterson v. State
| Decision Date | 31 March 2020 |
| Docket Number | No. 14, Sept. Term, 2019,14, Sept. Term, 2019 |
| Citation | 467 Md. 713,226 A.3d 246 |
| Parties | Elijah PETERSON v. STATE of Maryland |
| Court | Court of Special Appeals of Maryland |
Argued by Kiran Iyer, Assistant Public Defender (Claire Caplan, Assistant Public Defender and Paul B. DeWolfe, Public Defender of Maryland, Baltimore, MD) on brief, for Petitioner.
Argued by Carrie J. Williams, Assistant Attorney General (Brian E. Frosh, Attorney General of Maryland, Baltimore, MD) on brief, for Respondent.
Argued before: Barbera, C.J., McDonald, Watts, Hotten, Getty, Booth, Greene, Clayton, Jr. (Senior Judge, Specially Assigned), JJ.
Hotten, J. Section 3-110 of the Criminal Procedure Article ("Crim. Proc.") provides defendants the opportunity to plead "not criminally responsible" to a criminal charge. The General Assembly enacted §§ 3-101–123 to outline the process for such a plea. When a defendant is found guilty but "not criminally responsible" ("NCR"), the defendant is committed to the Maryland Department of Health ("the Department") for inpatient care or treatment.1 A court may thereafter authorize "conditional release" for a defendant with specified conditions recommended by the Department, and if the defendant violates those conditions, the defendant may be re-confined to an appropriate facility chosen by the Department. The instant case addresses whether defendants found guilty, but not criminally responsible, may seek post-conviction relief through the Uniform Post-Conviction Procedure Act, a writ of error coram nobis , or a writ of habeas corpus .
Petitioner, Elijah Peterson ("Mr. Peterson"), seeks review of a ruling by the Circuit Court for Prince George’s County that denied both Mr. Peterson’s request for post-conviction relief under the Uniform Post-Conviction Procedure Act ("UPPA") and his Petition for Writ of Error Coram Nobis . The Court of Special Appeals affirmed. We granted certiorari to answer the following three questions:
For reasons discussed below, we affirm the well-reasoned analysis of the Court of Special Appeals on the questions presented. However, given the Court’s recent decision in Sabisch v. Moyer , a circuit court, upon receipt of an appropriate filing, could render a determination regarding whether Maryland’s habeas corpus statute is implicated with respect to Mr. Peterson.
In March 2007, Mr. Peterson, while walking down the middle of the road on Marlboro Pike in Prince George’s County, pointed what appeared to be, a rifle at a police vehicle as it passed. He was subsequently arrested and charged with one count of auto theft, one count of attempted theft over $500, one count of unauthorized use of a motor vehicle, one count of attempted armed carjacking, two counts of first-degree assault, and two counts of second-degree assault. Mr. Peterson entered a plea of not guilty, but through counsel, proceeded to a bench trial on an agreed statement of facts. The bench trial consisted of the following colloquy:
Overall, the circuit court found Mr. Peterson guilty of two counts of second-degree assault, and determined that he was NCR because he lacked substantial capacity to either appreciate the criminality of his conduct or conform his conduct to the requirements of the law. See Crim. Proc. § 3-109(a).2 Thereafter, the circuit court ordered Mr. Peterson to be civilly committed to the Department for inpatient treatment. The court never asked Mr. Peterson whether he was pleading guilty or not guilty. The court never advised Mr. Peterson that he had a right to a jury trial or asked whether he was waiving that right.
On December 5, 2007, the circuit court ordered Mr. Peterson to be conditionally released from the Department for a period of five years, subject to conditions that included mandatory mental health and substance abuse treatment. Mr. Peterson was also required to comply with recommendations from his mental health treatment provider and either reside on hospital grounds or in other housing approved by the Department.3 He was required to voluntarily admit himself to a psychiatric facility as requested by his mental health provider. Mr. Peterson could not own, possess, or use a firearm of any kind or take illicit drugs, use alcohol, or abuse prescription drugs. Between 2008 and 2013, the circuit court issued Mr. Peterson multiple orders for conditional release, in which the circuit court placed similar conditions on Mr. Peterson as the original order in December 2007. In March 2013, the circuit court maintained the previously imposed conditions, but also required Mr. Peterson to refrain from initiating contact with the victim of his crime. Procedural Background
On July 24, 2012, during conditional release, Mr. Peterson filed a pro se petition for post-conviction relief under the Uniform Post-Conviction Procedure Act ("UPPA").4 After securing counsel, Mr. Peterson filed a Supplemental Petition for Post-Conviction Relief, which asserted (1) Mr. Peterson’s NCR plea was the functional equivalent of a guilty plea and was invalid because the record failed to demonstrate that he understood the nature of the charges and (2) Mr. Peterson’s original counsel was ineffective because he did not inform Mr. Peterson of the consequences of pleading NCR.
On June 11, 2013, the circuit court conducted a hearing regarding Mr. Peterson’s post-conviction request. On November 15, 2013, the court denied Mr. Peterson’s request for post-conviction relief and held that Mr. Peterson was neither "confined" nor on "probation or parole," for purposes of the UPPA.
On January 10, 2014, while committed, Mr. Peterson filed a Petition for Writ of Error Coram Nobis and requested a hearing to vacate the 2007 NCR judgment. After a hearing, the circuit court found that Mr. Peterson’s commitment to the Department was a direct consequence of his NCR plea, and, therefore, not a collateral consequence. The court denied Mr. Peterson’s request for coram nobis relief. Mr. Peterson’s subsequent motion for reconsideration was also denied because the court determined that Mr. Peterson was never "convicted" and that he failed to demonstrate significant collateral consequences.
Mr. Peterson timely appealed both the denial of his respective petitions for post-conviction claim and his coram nobis relief to the Court of Special Appeals.
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