Carroll v. State, 1818/24

Background

Carroll drove an untraceable Honda while two backseat passengers shot and killed Jermaine Reed after Carroll stopped beside Reed’s parked car. 1
Carroll was charged and convicted of murder, assault, firearm, and conspiracy counts as an accomplice and co-conspirator. 2
Carroll’s initial one-day trial date was postponed beyond his Hicks date for good cause because the case required more than one day. 3
Soon after that postponement, Carroll sought a competency evaluation and later withdrew the competency issue before trial. 4
Carroll moved for judgment of acquittal on intent grounds and later moved to dismiss under Hicks; both motions were denied. 5
The circuit court also proceeded with a scheduling conference without Carroll present. 6

Issues

Issue	Plaintiff's Argument	Defendant's Argument	Held
Was the evidence sufficient for accomplice and conspiracy convictions? 7	Carroll lacked proof he intended Reed be killed or assaulted.	The State proved shared lethal intent through coordinated conduct and circumstantial evidence.	Yes; sufficient evidence supported all convictions. 8
Did the Hicks postponement require dismissal? 9	The nine-month continuance beyond Hicks caused inordinate delay.	Good cause supported the continuance, and competency proceedings independently delayed trial.	No; no Hicks violation. 10
Was Carroll denied the right to be present at the scheduling conference? 11	The conference was a critical stage held in his absence.	Counsel acquiesced in Carroll’s absence, waiving the right.	No reversible error; the right was waived. 12

Key Cases Cited

State v. McGagh, 472 Md. 168 (Md. 2021) (sufficiency review asks whether any rational trier of fact could find guilt beyond a reasonable doubt 13)
State v. Manion, 442 Md. 419 (Md. 2015) (sufficiency standard incorporates direct and circumstantial evidence 14)
Jackson v. Virginia, 443 U.S. 307 (U.S. 1979) (constitutional sufficiency standard 15)
State v. Hicks, 285 Md. 310 (Md. 1979) (Maryland’s 180-day speedy-trial rule 16)
Tunnell v. State, 466 Md. 565 (Md. 2020) (explains Hicks good-cause and inordinate-delay analysis 17)
Rosenbach v. State, 314 Md. 473 (Md. 1989) (a good-cause postponement can still become inordinate 18)
State v. Brown, 355 Md. 89 (Md. 1999) (only the initial postponement past the Hicks date matters for inordinate-delay analysis 19)
Peaks v. State, 419 Md. 239 (Md. 2011) (due process bars trial of an incompetent defendant 20)
Sangster v. State, 312 Md. 560 (Md. 1988) (procedures must protect the right not to be tried while incompetent 21)
Kennedy v. State, 436 Md. 686 (Md. 2014) (competency issue must be resolved before trial proceeds 22)
State v. Hart, 449 Md. 246 (Md. 2016) (defendant has a common-law right to be present at critical stages 23)
Williams v. State, 292 Md. 201 (Md. 1981) (counsel may waive a defendant’s presence in some circumstances 24)
State v. Robb, 269 Md. App. 343 (Md. App. 2026) (recent discussion of waiver of presence rights 25)
Commonwealth v. Gonzalez, 56 N.E.3d 1271 (Mass. 2016) (mere presence or motive was insufficient to prove shared lethal intent on those facts 26)
Cooley v. State, 157 Md. App. 101 (Md. App. 2004) (driving shooters to and from the scene supported accomplice liability 27)