State v. Coale
| Decision Date | 31 March 2021 |
| Docket Number | No. 2001, Sept. Term, 2018,2001, Sept. Term, 2018 |
| Citation | 248 A.3d 1058,250 Md.App. 1 |
| Parties | STATE of Maryland v. Scott Corey COALE |
| Court | Court of Special Appeals of Maryland |
Argued by: Todd W. Hesel (Brian E. Frosh, Atty. Gen., on the brief), Baltimore, MD, for Appellant
Argued by: Jonathan P. Heshmatpour, Baltimore, MD, for Appellee
Panel: Fader, C.J., Kehoe, Beachley, JJ.*
Contents
The Interstate Agreement on Detainers
Coale's 2009 convictions
Coale invokes the IAD
Proceedings in Howard County
Proceedings in Anne Arundel County
The post-conviction court proceeding
The petition and the hearing
The post-conviction court's judgment
Timeline
The parties' appellate contentions
The standard of review
In 2007, Scott Corey Coale committed a series of crimes in Howard and Anne Arundel counties. He then went to California, where he was convicted of an unrelated crime and sentenced to prison. While Coale was serving his California sentence, officials in Howard County and Anne Arundel County separately filed detainers against him for the charges pending in their respective jurisdictions. Coale invoked his right under the Interstate Agreement on Detainers (the "IAD") for prompt disposition of those charges. He was extradited to Maryland and, in 2009, resolved the Anne Arundel County charges by means of a plea agreement.
In 2016, Coale filed a petition for post-conviction relief as to the Anne Arundel County convictions, asserting that his trial counsel had provided ineffective assistance by failing to investigate and pursue a motion for dismissal under the IAD. The post-conviction court granted the petition, vacated the convictions and sentences entered against him, and dismissed all of the underlying charges with prejudice. The State filed an application for leave to file an appeal pursuant to Md. Rule 8-204, which this Court granted. State of Maryland v. Scott Coale , ALA No. 0678, 2018 Term.
The State presents one issue on appeal, which we have reworded slightly:
Did the post-conviction court err when it granted Coale's petition for post-conviction relief based upon his trial counsel's alleged failure to investigate and pursue a motion to dismiss the cases pending against him on the grounds that the State had violated the Interstate Agreement on Detainers?1
We will reverse the court's judgment. To prevail in his post-conviction action, Coale must demonstrate that his trial counsel's representation was deficient and that he was prejudiced by his counsel's shortcomings. State v. Syed , 463 Md. 60, 75, 204 A.3d 139, cert. denied ––– U.S. ––––, 140 S. Ct. 562, 205 L.Ed.2d 356 (2019). A defendant satisfies the second requirement when he shows that "but for counsel's unprofessional errors, the result of the proceeding would have been different; or that the result of the proceeding was fundamentally unfair or unreliable." Id. (quoting Newton v. State , 455 Md. 341, 355, 168 A.3d 1 (2017) ). For the purposes of our analysis, we will assume that Coale has satisfied the first criterion. However, any suppositional deficiency in trial counsel's performance neither affected the outcome of the 2009 proceedings nor rendered his convictions unfair or unreliable.
A detainer is "a notification filed with the institution in which a prisoner is serving a sentence, advising that he is wanted to face pending criminal charges in another jurisdiction." White v. State , 223 Md. App. 353, 372 n.14, 116 A.3d 520 (2015) (quoting State v. Jefferson , 319 Md. 674, 678 n.2, 574 A.2d 918 (1990) ). The Interstate Agreement on Detainers, codified in Maryland as §§ 8-402–11 of the Correctional Services Article, "is a congressionally-sanctioned compact among the states designed to facilitate the prompt disposition of a detainer lodged by one state against a person incarcerated in another state." Aleman v. State , 469 Md. 397, 402, 230 A.3d 97, cert. denied , ––– U.S. ––––, 141 S.Ct. 671, 208 L.Ed.2d 278 (2020). Because it is an interstate compact that has been approved by Congress, the IAD is subject to construction by federal courts. Alabama v. Bozeman , 533 U.S. 146, 149, 121 S.Ct. 2079, 150 L.Ed.2d 188 (2001) ; New York v. Hill , 528 U.S. 110, 111, 120 S.Ct. 659, 145 L.Ed.2d 560 (2000). Maryland courts "ordinarily defer to interpretations of the [IAD] provided by the United States Supreme Court." Pitts v. State , 205 Md. App. 477, 487–88, 45 A.3d 872 (2012) (citing State v. Pair , 416 Md. 157, 168, 5 A.3d 1090 (2010) ).
Pending detainers can restrict an inmate's eligibility for training and educational programs, transfers to moderate or minimum-security facilities, and similar measures intended to assist in the rehabilitation of the inmate. See, e.g., Carchman v. Nash , 473 U.S. 716, 730 n.8, 105 S.Ct. 3401, 87 L.Ed.2d 516 (1985) ; Pair , 416 Md. at 160–61, 5 A.3d 1090.2 The legislative purpose of the IAD is to establish uniform procedures for the prompt disposition of such charges. Pair , 416 Md. at 162, 5 A.3d 1090. To this end, the IAD sets out rules and procedures "for the temporary transfer of the prisoner from the state of incarceration to the state in which charges are pending, upon the request of either the prisoner or the prosecuting jurisdiction." Aleman, 469 Md. at 402, 230 A.3d 97. Among those procedures, Article III of the IAD, codified as Corr. Servs. § 8-405, "gives a prisoner incarcerated in one State the right to demand the speedy disposition of any untried indictment, information or complaint that is the basis of a detainer lodged against him by another State[.]" Pair , 416 Md. at 162, 5 A.3d 1090 (quoting Carchman , 473 U.S. at 718–19, 105 S.Ct. 3401 ).
For the purposes of the IAD, member jurisdictions can play two roles: The "receiving state" is one in which a criminal trial is to be held as a result of a detainer filed by prosecutors in that jurisdiction; the "sending state" is the jurisdiction in which the person facing the pending charges is currently incarcerated. See IAD Article II, codified as Corr. Servs. § 8-404(b) and (c). In the present appeal, California and Maryland are respectively the sending and receiving states.
The IAD addresses two scenarios. The one that is relevant to this appeal is when a prisoner in a sending state requests a resolution of the charges which are the basis for the detainers filed by the receiving state. This subject is addressed in Article III of the IAD, codified as Corr. Servs. § 8-405.3 In Pair, the Court summarized the initial stages of the process contemplated by Article III:
Id. at 162–63, 5 A.3d 1090 (some quotation marks, brackets, footnotes and citations omitted).
IAD Article III(a), codified as Corr. Servs. § 8-405(a). The 180-day limit can be extended "for good cause shown in open court, the prisoner or the prisoner's counsel being present[.]" Id.
Two other provisions of the IAD figure in the arguments raised by the parties: First, a prisoner's request for disposition under Article III "operates as a request for final disposition" of all pending charges for which detainers have been issued from the receiving state. See IAD Article III(d), codified as Corr. Servs. § 8-405(d). Second, Article IX of the IAD, codified as Corr. Servs. § 8-411, states that its provisions are to be "liberally construed so as to effectuate its purposes."
The Council of State Governments has promulgated standard forms for the implementation of the IAD. Laster v. State , 313 Md. 548, 551 n.2, 546 A.2d 472 (1988). The then-current versions of the forms are set out in an appendix to the Court's opinion, id . at 562–69, 546 A.2d 472, and the Court looked to language in the forms as a guide to interpretation of the IAD. Id. at 554–58, 546 A.2d 472.5
When it adopted the IAD in 1965, the General Assembly also enacted supplemental statutes (now codified as Corr. Servs. §§ 8-412–17) to assist in the implementation and administration of the compact's provisions. See chapter 627 of the Laws of 1965; Laster v. State , 313 Md. at 571 n.2, 546 A.2d 472 (McAuliffe, J., concurring) ().
Two of these supplemental statutes are relevant to the present case. The first is Corr. Servs. § 8-412, which requires Maryland's courts and government agencies...
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