State v. Logan
| Decision Date | 01 September 2006 |
| Docket Number | No. 100, September Term, 2005.,100, September Term, 2005. |
| Citation | 394 Md. 378,906 A.2d 374 |
| Parties | STATE of Maryland v. James Ramiah LOGAN. |
| Court | Court of Special Appeals of Maryland |
Glenn F. Ivery, Special Asst. Atty. Gen. (J. Joseph Curran, Jr., Atty. Gen., Edward J. Kelley, Asst. Atty. Gen., on brief), for petitioner/cross-respondent.
Gary E. Bair (Fred Warren Bennett, Bennett & Bair, LLP, Greenbelt, on brief), for respondent/cross-petitioner.
Argued before BELL, C.J., RAKER, WILNER, CATHELL, HARRELL, BATTAGLIA and GREENE, JJ.
We granted review to consider two issues in this case. We granted the State's petition for certiorari to consider whether the trial court acted within its discretion in refusing to pose Logan's multi-part voir dire questions regarding the defense of not criminally responsible (NCR) and the potential effect of pretrial publicity. We granted Logan's cross-petition to consider whether the trial court's error in admitting into evidence his confession in violation of Miranda v. Arizona, 384 U.S. 436, 86 S.Ct. 1602, 16 L.Ed.2d 694 (1966), was harmless error.
James Ramiah Logan was indicted by the Grand Jury for Prince George's County for two counts of first-degree premeditated murder and two counts of use of a handgun during the commission of a crime of violence. He entered a plea of not guilty and not criminally responsible. The jury found him guilty of two counts of second-degree murder and two counts of the handgun offense. He was also found criminally responsible. The Circuit Court sentenced Logan to a total term of incarceration of one hundred years.
On or around August 25, 2003, Logan began behaving in a manner that alarmed his family. He went to Prince George's County Hospital for an evaluation and while there, admitted to past use of PCP. His blood tested positive for cocaine. Logan's family requested that Logan admit himself voluntarily to a hospital, but Logan refused to do so. On August 29, 2003, Logan's wife and his mother obtained a court order directing the Prince George's County Sheriff's Office to transport Logan for the purpose of conducting an emergency psychiatric evaluation. That day, Logan smoked several "bowls" of marijuana and then went to his parents' house with two friends to conduct a bible study. On the evening of August 29, 2003, Deputies James Arnaud and Elizabeth Magruder went to Logan's parents' home to enforce the emergency order for psychiatric evaluation. The deputies went to the basement where Logan was participating in the bible study. Logan fled upstairs and the deputies pursued him. As they were standing outside of his bedroom door, Logan shot and killed both of them.
Logan was arrested by the Prince George's County Police for the murder of the two deputies. He was transported to police headquarters, where he was interviewed by Prince George's County homicide Detective Vincent Canales for approximately three and one half hours. Prior to reading Logan his Miranda rights, the detective assured Logan repeatedly that he was not going to harm him, that they were "just talking," and that he would not allow any harm to come to Logan's parents about whom Logan had expressed concern. During the discussion of Miranda rights, Detective Canales assured Logan that his role was not to hurt him, and that he would be "one hundred percent" truthful with Logan, if Logan would be the "same way." Immediately before Logan said he would waive his Miranda rights, the detective told Logan that the only way he would be "jeopardized" was if he did not tell the truth. Logan said he would waive his rights, and then admitted shooting Deputies Arnaud and Magruder. Logan explained to the detective that he had intended to kill the deputies, stating as follows:
Logan filed a motion to suppress his confession to Detective Canales on the ground that the police violated Miranda. The Circuit Court denied the motion. Logan entered a plea of not guilty and not criminally responsible. The State filed a notice of its intent to seek the death penalty.1 At trial, Logan requested that the judge ask specific questions on voir dire to the venire regarding the NCR defense and pretrial publicity surrounding the case, which the trial judge refused to do.
At trial, Logan's counsel conceded that Logan shot Deputies Arnaud and Magruder, but claimed that Logan was not criminally responsible for his actions. He presented expert testimony that Logan was suffering from paranoid schizophrenia at the time of the shootings, which prevented him from appreciating the criminality of his conduct or conforming his conduct to the requirements of the law. In response, the State presented expert testimony that Logan's behavior was caused by his voluntary ingestion of drugs. The jury found Logan guilty of two counts of second degree murder and found him criminally responsible for the murders.
Logan noted a timely appeal to the Court of Special Appeals. In a reported opinion, the Court of Special Appeals reversed. Logan v. State, 164 Md.App. 1, 882 A.2d 330 (2005). The court held that the admission of Logan's confession was in violation of Miranda, but that the error was harmless beyond a reasonable doubt. Id. at 52, 882 A.2d at 359. With respect to the voir dire issues, the court concluded that the trial court abused its discretion by failing to probe for bias regarding the NCR defense, even if Logan's proposed questions were improper. In addition, the court held that the question on pretrial publicity posed by the trial judge to the venire was contrary to Dingle v. State, 361 Md. 1, 759 A.2d 819 (2000), because that query sought only to uncover the jurors' own bottom-line conclusions as to their impartiality. The intermediate appellate court concluded that the trial court should have inquired whether jurors exposed to pretrial publicity had formed an opinion regarding the case due to such exposure. Logan, 164 Md.App. at 72-73, 882 A.2d at 369-71.
We granted the State's petition for certiorari to decide the following question:
"Did the Court of Special Appeals err when it vacated Logan's convictions on the basis that the trial court failed to formulate and pose additional questions to the venire panel regarding the defense of not criminally responsible and the issue of pretrial publicity?"
State v. Logan, 390 Md. 284, 888 A.2d 341 (2005).
In addition, we granted Logan's conditional cross-petition for certiorari to decide the following question:
We address the harmless error issue first. In his cross-petition, Logan argues that the Court of Special Appeals erred in ruling that the admission of his confession obtained in violation of Miranda was harmless error. In Maryland, error is harmless if "a reviewing court, upon its own independent review of the record, is able to declare a belief, beyond a reasonable doubt, that the error in no way influenced the verdict." Dorsey v. State, 276 Md. 638, 659, 350 A.2d 665, 678 (1976).
The intermediate appellate court found the error to be harmless. As to the guilt/innocence determination, the court held that, because at trial petitioner conceded criminal agency, the admission of his confession was not prejudicial with respect to the identity of the murderer. Logan, 164 Md.App. at 50, 882 A.2d at 358. As to the impact on the NCR defense, the court held that because the defense relied heavily on Logan's statements to Detective Canales to support the NCR defense, there was no prejudice. See id. at 50-52, 882 A.2d at 358-59.
Logan argues that the admission of his confession was not harmless error because the State used the confession in two ways to bolster its claim that Logan was criminally responsible: first, that the State's experts considered the confession in forming their opinion that Logan was criminally responsible, and second, that the prosecutor used the confession repeatedly in closing argument to show that he was responsible. As to the defense's use of the confession, Logan responds that once the confession had been admitted into evidence, he had no choice but to make the best of a bad situation and try to rebut or explain the evidence.
Before this Court, the State does not dispute the holding of the Court of Special Appeals that the trial court erred in finding a waiver of Miranda. The State argues that the jury verdict rejecting the NCR defense was not impacted by the introduction of petitioner's confession.
We hold that the error was not harmless. The confession undisputedly was taken by the police in violation of Miranda and was admitted improperly into evidence. Experts for both parties testified that they considered the videotape confession in arriving at their opinion regarding Logan's criminal responsibility. In closing argument, the State urged the jury to reject the NCR defense, pointed to the videotape of the confession, and argued as follows:
...
To continue reading
Request your trial
-
Kazadi v. State
.... For example, twenty-five years after jury instructions were declared binding in Montgomery , the Court, in State v. Logan , 394 Md. 378, 398-99, 906 A.2d 374 (2006) (some internal citations omitted), invoked Twining in holding that a voir dire question proposed by the defensewas not a pro......
-
Warren v. State
...and internal quotation marks omitted).Miranda Waivers In Logan v. State, 164 Md.App. 1, 41, 882 A.2d 330 (2005), aff'd, 394 Md. 378, 906 A.2d 374 (2006), this Court discussed what constitutes a waiver of the Miranda rights: Although an express written or oral statement of waiver of the righ......
-
Burris v. State, 1970
...It is well settled that a trial court's rulings as to voir dire are reviewed under an abuse of discretion standard. State v. Logan, 394 Md. 378, 396–97, 906 A.2d 374 (2006). The Court of Appeals has stated: The scope of voir dire and the form of questions propounded rest firmly within the d......
-
Muhammad v. State
...beyond a reasonable doubt that such error was harmless. Fields v. State, 395 Md. 758, 763-64, 912 A.2d 637 (2006); State v. Logan, 394 Md. 378, 388, 906 A.2d 374 (2006); Brown v. State, 364 Md. 37, 42, 770 A.2d 679 (2001); Rubin v. State, 325 Md. 552, 578-79, 602 A.2d 677 (1992); Dorsey v. ......
-
Right To An Impartial Jury
...Constitution and Article 21 of the Maryland Declaration of Rights guarantees to a fair and impartial jury will be honored. State v. Logan, 394 Md. 378, 395 (2006); Curtin v. State, 393 Md. 593, 600 (2006); White v. State, 374 Md. 232, 240 (2003); Dingle, 361 Md. at 9. "Without adequate voir......
-
Miranda V. Arizona and Its Progeny
...and knowingly relinquish a constitutional right." Moran, 475 U.S. at 422. However, in Logan v. State, 164 Md. App. 1 (2005), aff'd, 394 Md. 378 (2006), the Court of Special Appeals held that defendant's waiver of Miranda was not knowing, intelligent, and voluntary when police told the defen......
-
Harmless Error
...to pay restitution to medical providers. Id. 6. Admission of the defendant's confession in violation of Miranda In State v. Logan, 394 Md. 378 (2006), trial court denied the defendant's motion to suppress his confession that he killed two officers and, after the State played the entire tape......
-
Voir Dire Questions
...stated rules of law. See Twining v. State, 234 Md. 97, 100, 198 A.2d 291, 293 (1964). The Court applied this principle in State v. Logan, 394 Md. 378, 398-99, 906 A.2d 374, 386 (2006). There, the defendant was convicted of murder and, on appeal, contended that the trial court improperly ref......