Jones v. State
126 A.3d 1162
Md.2015Background
- Jones pled guilty in 1999 in Baltimore City Circuit Court to a drug offense with multiple counts; some charges were dismissed or closed at plea time.
- The 1999 plea transcript and related materials raised questions about whether Jones pled to possession with intent to distribute or use of a minor for distribution; counsel stated Jones was pleading to possession with intent to distribute.
- In 2012 Jones filed a coram nobis petition challenging the voluntariness of the 1999 plea based on the alleged lack of element/nature understanding; the petition was met with laches arguments by the State.
- Circuit Court granted coram nobis relief in 2013, but Court of Special Appeals reversed in 2014, holding laches barred the petition; certiorari followed to this Court.
- The Court addresses (a) whether laches may bar coram nobis relief, (b) when delay begins for laches analysis, and (c) whether prejudice includes reprosecution, not just defense, for coram nobis petitions.
- The Court ultimately holds that laches may bar coram nobis relief, delay begins when the petitioner knew or should have known the facts underlying the error (here, 1999), and prejudice includes the State’s ability to reprosecute as well as defend.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Can laches bar coram nobis relief? | Jones argues laches does not apply to coram nobis in this case. | State contends laches can bar coram nobis relief generally and here. | Yes; laches may bar coram nobis relief in this case. |
| When does delay begin for laches analysis? | Delay begins at facially valid coram nobis petition filing date. | Delay begins when the petitioner knew or should have known the underlying facts. | Delay begins when the petitioner knew or should have known the underlying facts (1999). |
| What constitutes prejudice for laches in coram nobis? | Prejudice is limited to the State’s ability to defend against the petition. | Prejudice includes the State’s ability to reprosecute the petitioner. | Prejudice includes both the State’s ability to defend and to reprosecute. |
| Should Smith/Waiver-style considerations affect laches analysis here? | Smith’s retroactivity of CP 8-401 favors not waiving rights; laches should be separate. | State emphasizes consistency with Smith and distinctions from laches. | Laches analysis remains independent of waiver; Smith supports retroactivity but not reduce laches applicability. |
| Did the delay here unreasonably prejudice the State? | Delay was not unreasonable given circumstances. | Thirteen-year delay harmed the State’s ability to defend and reprosecute due to lost witnesses and records. | Yes; the thirteen-year delay was unreasonable and prejudicial to the State. |
Key Cases Cited
- State Ctr., LLC v. Lexington Charles Ltd. P’ship, 438 Md. 451 (Md. 2014) (laches framework; prejudice and reasonableness must be weighed)
- Liddy v. Lamone, 398 Md. 233 (Md. 2007) (prejudice and unreasonable delay definitions in laches)
- Holmes v. State, 401 Md. 429 (Md. 2007) (latches as equitable defense; dissent discusses scope)
- Smith v. State, 443 Md. 572 (Md. 2015) (CP § 8-401 retroactive to pending coram nobis petitions)
- Skok v. State, 361 Md. 52 (Md. 2000) (grounds for coram nobis; distinctions from laches when immigration-related)
- Moguel v. State, 184 Md. App. 465 (Md. App. 2009) (laches defense to coram nobis actions)
- Berman v. Leckner, 193 Md. 177 (Md. 1949) (knowledge or means of knowledge as essential element of laches)
- Frederick Rd. Ltd. P’ship v. Brown & Sturm, 360 Md. 76 (Md. 2000) (notice/knowledge as prerequisite to laches)