Grandison v. State, 38 A.3d 352

Grandison, a death-sentenced inmate, pursued numerous collateral motions after his 1984 murder convictions and re-sentencing, with the circuit court denying all relief in 2010.
He discharged appointed counsel and subsequently sought appointment of counsel for collateral proceedings; the circuit court denied appointing new counsel.
The State moved to dismiss several issues on procedural grounds, including lack of a proper application for leave to appeal.
The Court of Appeals retained jurisdiction over direct appellate matters in death penalty cases and reviewed Grandison’s collateral challenges for potential relief.
The Court ultimately denied Grandison’s motions and held there was no right to counsel for collateral proceedings and that the circuit court did not err in allowing Grandison to proceed pro se.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Right to counsel in collateral motions	Grandison seeks counsel for collateral proceedings.	No right to appointed counsel for collateral motions beyond direct appeal.	No right to counsel; denial affirmed.
Waiver of racial discrimination claim in jury selection	Waiver should be excused due to special circumstances; claim not previously raised.	Waiver due to failure to raise in prior proceedings.	Waiver defense upheld; claim affirmed as waived.
Retroactivity of Crawford v. Washington	Crawford should be retroactive under Article 21.	Crawford is procedural and not retroactive.	Crawford not retroactive; petition denied on this point.
Mitigating factors on sentencing form	Pre-marking mitigators biased jury consideration.	No reversible error; not raised earlier.	Waiver; no relief on this point.
Admissibility of Exhibit 21 (the jury letter) and related evidence	Issue not properly preserved; warrants reconsideration.	Issue finally litigated; cannot relitigate.	Claim finally litigated; affirmed denial.

Crawford v. Washington, 541 U.S. 36 (U.S. 2004) (testimonial statements require prior cross-examination; retroactivity analysis later in Whorton)
Whorton v. Bockting, 549 U.S. 406 (U.S. 2007) (Crawford rule deemed non-retroactive absent watershed ruling)
Pennsylvania v. Finley, 481 U.S. 551 (U.S. 1987) (no right to counsel for collateral attacks; appellate rights limited)
Office of the Public Defender v. State, 413 Md. 411 (Md. 2010) (OPD authority to appoint counsel; distinguishes in this collateral context)
Evans v. State, 396 Md. 256 (Md. 2006) (death sentence not inherently illegal; focus on procedural regulations)
Danforth v. Minnesota, 552 U.S. 264 (U.S. 2008) (retroactivity framework for state-court remedies)