Douglas v. State, 31 A.3d 250

Background

Douglas and Curtis were convicted of serious violent offenses in Baltimore City and later filed pro se petitions for writs of actual innocence under CP § 8-301 after the statute took effect in 2009.
The circuit court denied both petitions without holding a hearing, finding no newly discovered evidence that could affect trial outcomes.
The petitions raised newly discovered evidence theories concerning trial witnesses and related forensic testimony.
The Court of Special Appeals had consolidated the cases and this Court granted certiorari to address (i) whether denial without a hearing is automatically appealable, and (ii) whether CP § 8-301 procedures require a hearing when pleading grounds are asserted.
The Court held that the denial of CP § 8-301 petitions is a final judgment subject to immediate appeal, and that CP § 8-301 requires a pleading burden that can trigger a hearing if grounds are adequately pleaded and requested.
On the merits, the Court remanded Douglas for a hearing on his petition and affirmed Curtis’s denial, noting that Curtis did not present newly discovered evidence.

Issues

Issue	Plaintiff's Argument	Defendant's Argument	Held
Is denial of a CP § 8-301 petition a final appealable judgment?	Douglas/Curtis: denial should be appealable under CJ 12-301 as a final judgment.	State: CP § 8-301 denial is not appealable under existing rules and UPPA.	Yes; denial is a final judgment and appealable.
Does CP § 8-301 require a hearing if pleading grounds are adequately asserted and a hearing is requested?	Douglas/Curtis: pleading alone should trigger a hearing when grounds are adequately pled.	State: hearing is not required if petition fails to assert grounds for relief.	The statute imposes a pleading burden; a hearing must be held if grounds are adequately pleaded and requested.
Does UPPA § 7-107(b)(1) bar appeals of CP § 8-301 denials?	CP § 8-301 claims are beyond UPPA, so appeal should not be barred.	UPPA precludes appeals in these postconviction-like contexts.	UPPA does not apply to CP § 8-301; denials are appealable.
Are CP § 8-301 petition denials subject to CJ § 12-301 final judgment review, given postconviction context?	Final judgment rule should support immediate appeal.	Final judgment rule should be interpreted narrowly in postconviction contexts.	Denials are final judgments under CJ § 12-301.
Did Curtis's petition have newly discovered evidence adequate to trigger a hearing?	Curtis claimed grandmother affidavit was newly discovered evidence affecting identity.	Affidavit was not newly discovered evidence; known before expiration of motions for new trial.	Curtis's claim failed; no hearing required on this basis.

Key Cases Cited

Cubbage v. State, 304 Md. 237, 498 A.2d 632 (1985) (statutory right to appeal in Maryland criminal cases)
Fuller v. State, 397 Md. 372, 918 A.2d 453 (2007) (express appeal right not required when remedy is not under CP § 8-301)
In re Billy W., 386 Md. 675, 874 A.2d 423 (2005) (definition of final judgment and appellate rights)
Sigma Reprod. Health Ctr. v. State, 297 Md. 660, 467 A.2d 483 (1983) (final judgment concept and interlocutory vs final appeals)
Evans v. State, 382 Md. 248, 855 A.2d 291 (2004) (postconviction review as a separate avenue from direct appeal)
Jackson v. State, 358 Md. 612, 751 A.2d 473 (2000) (necessity of hearings in certain postconviction contexts)
Arey v. State, 400 Md. 491, 929 A.2d 501 (2007) (court should hold hearing when factual disputes exist in DNA postconviction context)
Patuxent Inst., 240 Md. 717, 214 A.2d 162 (1965) (exemplary postconviction relief compared to new trial standards)