217 A.3d 72
Md. Ct. Spec. App.2019Background
- In 2016 Aleman fatally stabbed his former landlord in Baltimore County; he was serving an 11-year sentence in Ohio (felonious assault) when Maryland lodged a detainer.
- Aleman invoked the Interstate Agreement on Detainers (IAD), was transferred to Maryland for prosecution, and signed an agreement consenting to return to Ohio after disposition.
- In Maryland Aleman pleaded guilty to second-degree murder; a jury found him not criminally responsible (NCR) for the offense.
- Maryland statute CP § 3-112 normally requires commitment to the Department of Health after an NCR verdict; local officials instead prepared to return Aleman to Ohio under the IAD.
- Aleman filed habeas petitions seeking commitment in Maryland and argued the IAD ceased to apply under Article VI(b) once he was adjudged NCR; the circuit court ordered return to Ohio and Aleman appealed.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether CP § 3-112 (mandatory commitment after NCR) prevents return under the IAD | Aleman: CP § 3-112 is mandatory ("shall") and thus overrides IAD; he must be committed to Dept. of Health in Maryland | State: Maryland acquired only temporary custody under the IAD limited to prosecution, so it lacked authority to apply CP § 3-112 and must return Aleman | Held: IAD gave Maryland only temporary custody for prosecution; CP § 3-112 did not apply because Maryland lacked custodial/jurisdictional authority to effect commitment |
| Whether IAD Article VI(b) (no IAD for person "adjudged to be mentally ill") is triggered by a post-transfer NCR verdict about past insanity | Aleman: The Article VI(b) exclusion applies to him because the jurys NCR verdict implies ongoing mental illness or renders IAD inapplicable | State: Article VI(b) applies only where the prisoner is adjudged currently mentally ill (at time of transfer or while in sending state); it does not free a receiving state from its IAD return obligations after it prosecutes the charges | Held: Article VI(b) speaks in present tense and targets contemporaneous mental illness; an NCR verdict about past mental state does not trigger Article VI(b), so the IAD still governed return to the sending state |
Key Cases Cited
- State v. Pair, 416 Md. 157 (2010) (explains detainer and IAD triggering and procedures)
- Carchman v. Nash, 473 U.S. 716 (1985) (discusses problems caused by unresolved detainers and rationale for IAD)
- Clipper v. State, 295 Md. 303 (1983) (identifies IAD's dual purposes: expeditious disposition and interstate cooperation)
- State v. Beauchene, 541 A.2d 914 (Me. 1988) (interprets Article VI(b) as protecting those presently mentally ill from transfer)
- Jones v. United States, 463 U.S. 354 (1983) (addresses inferences from an insanity acquittal regarding current mental illness)
- Lynch v. Overholser, 369 U.S. 705 (1962) (due process challenges to mandatory commitment after insanity verdict)
- Stewart v. State, 275 Md. 258 (1975) (discusses constructive custody concepts relevant to IAD custody allocation)
- Baker v. Marbury, 216 Md. 572 (1958) (jurisdictional limits where custody is not within state borders)