Blake v. State, 301 A.3d 1

On July 25, 2012, Officer Fabien Laronde arrested William (James) Blake after observing suspected street narcotics activity; during a search incident to arrest Blake squatted and a bag of 41 gel caps/3.5 g heroin fell into his underwear. Officer Laronde was the sole witness at the suppression hearing.
Defense moved to suppress, arguing the search was an unreasonable strip/visual-body-cavity search; the motions court denied the motion, treating the search as a permissible "reach-in" under the Bell factors.
To preserve the suppression issue for appeal, Blake entered a not-guilty plea on an agreed statement of facts and was sentenced to eight years; direct appeal affirmed.
Post-conviction, Blake obtained IAD files and other records (ten misconduct allegations against Laronde, many administratively closed or unsustained, plus a later civil settlement) and argued (1) counsel was ineffective for not moving to compel those IAD files pre-suppression and (2) the State violated Brady by not disclosing impeachment material before the suppression hearing.
The post-conviction court denied relief (except granting leave to file a belated motion for modification of sentence); the Appellate Court certified two questions to the Maryland Supreme Court, which independently reviewed and affirmed the denial.

Issue	Blake's Argument	State's Argument	Held
Whether trial counsel was ineffective for not moving to compel Officer Laronde’s IAD files before the suppression hearing	Counsel knew of allegations about Laronde and should have compelled IAD files to impeach Laronde’s credibility at the suppression hearing	Counsel reasonably pursued a Fourth Amendment challenge to the search (rather than attacking Laronde’s veracity), relied on disclosed civil judgment, and reasonably expected corroboration by another officer; strategic choice	No — counsel’s decision fell within reasonable professional strategy and was not deficient; alternative prejudice not shown
Whether the State violated Brady by failing to disclose impeachment/IAD material before the suppression hearing	Brady impeachment material is constitutionally required at pre-trial proceedings like suppression hearings; nondisclosure was material and prejudicial	Brady impeachment is a trial-related right (Ruiz/Byrd); alternatively, the IAD records were largely inadmissible or would not have changed the outcome	No — assuming Brady applied to suppression hearings, the undisclosed material was not sufficiently material to create a reasonable probability of a different result

Strickland v. Washington, 466 U.S. 668 (establishes two‑prong test for ineffective assistance: deficient performance and prejudice)
Brady v. Maryland, 373 U.S. 83 (prosecution must disclose materially favorable exculpatory or impeachment evidence)
Kyles v. Whitley, 514 U.S. 419 (materiality under Brady requires a "reasonable probability" the result would differ)
Ruiz v. United States, 536 U.S. 622 (impeachment disclosure is a trial-related right and may be waived with plea)
Bell v. Wolfish, 441 U.S. 520 (four-factor balancing test for reasonableness of intrusive searches in pretrial contexts)
Paulino v. State, 399 Md. 341 (visual body‑cavity/strip search in public held unconstitutional without exigent circumstances)
Fields & Colkley v. State, 432 Md. 650 (procedure and defendant’s burden to obtain confidential IAD/personnel records)
Allen v. State, 197 Md. App. 308 (reach‑in search upheld where privacy was reasonably protected)