Coleman v. State, 100 A.3d 1234

Coleman pled guilty in 1999 in Anne Arundel County Circuit Court to possession with intent to distribute cocaine; sentenced to five years with all but ten days suspended and five years’ supervised probation.
In 1998–1999, Coleman was charged with several offenses; initial appearance included a district court certification that he was informed of offenses and penalties.
The circuit court information echoed the charges and noted a penalty for possession with intent to distribute of 20 years and $25,000.
At the Jan 21, 1999 plea hearing, the State described a plea agreement with Gow to plead guilty to possession with intent to distribute and nol pros remaining counts, with a lengthy mostly-suspended sentence and SAT testing.
The court advised Coleman regarding his rights and that it could depart from the State’s recommendations; Coleman acknowledged understanding and entered a knowing, voluntary plea.
Following sentencing, Coleman did not file a direct appeal or post-conviction relief; in 2011 he later pled guilty federally and, in 2012, sought coram nobis relief in Maryland, which the circuit court denied.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Retroactivity/waiver of coram nobis right	Coleman—8-401 retroactively bars waiver by lack of appeal filing	State—no retroactive effect or waiver; proper coram nobis standards apply	8-401 retroactive; no waiver by failure to file appeal
Knowingly voluntary plea and awareness of consequences	Coleman—maximum penalty and elements not advised; defective plea	State—factos and bargain show understanding; harmless error under King and Bryant distinctions	Plea knowingly and voluntarily; record supports understanding and the bargain; not reversible

Holmes v. State, 401 Md. 429 (2007) (waiver presumption when no appeal filed after guilty plea)
Graves v. State, 215 Md. App. 339 (2013) (retroactivity of 8-401; coram nobis relief not waived by failure to appeal)
State v. King, 71 Md. App. 229 (1987) (harmless error when bargained sentence well below maximum; maximum not magic wand)
Bryant v. State, 47 Md. App. 551 (1981) (maximum penalty disclosure required when no bargained-for sentence near max)
United States v. Morgan, 346 U.S. 502 (1954) (final judgments; extraordinary remedy rare and equitable)
Skok v. State, 361 Md. 52 (2000) (grounds for coram nobis are constitutional/fundamental; require significant circumstances)
State v. Daughtry, 419 Md. 35 (2011) (total record evidence; Rule 4-242 considerations; extrinsic evidence sometimes limited)
United States v. George, 676 F.3d 249 (2012) (credit to holistic, discretionary coram nobis analysis; final judgments require justice)