Kranz v. State, 168 A.3d 986

William Louis Kranz was convicted (jury) of two counts of first‑degree assault and two counts of reckless endangerment for shooting incidents; victims were key witnesses but could not positively identify him.
After conviction but before sentencing Kranz learned the victims had sued him in civil court and had retained Kevin Urick, who was (or had been) an Assistant State’s Attorney in Cecil County; the prosecution did not disclose Urick’s representation to Kranz.
Kranz filed postconviction proceedings alleging a Brady conflict/non‑disclosure; the postconviction court found nondisclosure but denied relief as not ‘‘material’’ (no reasonable probability of a different result).
Kranz applied for leave to appeal the postconviction denial; while that application was pending in the Court of Special Appeals, Kranz completed his sentence and the subsequent probation period.
The State moved to dismiss the appeal, arguing that completion of Kranz’s sentence divested the appellate court of jurisdiction under the custody requirement of the Postconviction Procedure Act.
The Court of Special Appeals granted the State’s motion and dismissed the appeal, holding the custody requirement in CP § 7‑101 governs eligibility for relief (and appellate review) and that completion of the sentence removed jurisdiction.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the Court of Special Appeals retained jurisdiction to consider Kranz’s leave‑to‑appeal after he completed his sentence while the appeal was pending	Kranz: CP § 7‑109 permits an aggrieved person to apply for leave to appeal within 30 days of the court’s order; because he was in custody when the circuit court ruled, the appellate court could grant leave even if he completed his sentence before leave was granted	State: The custody requirement in CP § 7‑101 is jurisdictional and applies to the entire Title 7 (including appeals); completion of the sentence during pendency removed eligibility and appellate jurisdiction	Court: Dismissed appeal — CP § 7‑101’s custody requirement controls Title 7; completion of sentence while appeal pending divested appellate jurisdiction

Agurs v. United States, 427 U.S. 97 (discusses materiality and Brady/Giglio standards for suppressed evidence)
Giglio v. United States, 405 U.S. 150 (false testimony and materiality standard for new trial)
Napue v. Illinois, 360 U.S. 264 (prosecutor’s duty regarding false testimony)
Kyles v. Whitley, 514 U.S. 419 (Brady materiality: reasonable probability of different result)
Yearby v. State, 414 Md. 708 (Maryland articulation of Brady materiality)
McMannis v. State, 311 Md. 534 (interpreting custody requirement as limiting who may file postconviction petitions)
Obomighie v. State, 170 Md. App. 708 (application of custody requirement when petitioner completes sentence during postconviction proceedings)
Douglas v. State, 423 Md. 156 (remedial purpose of Title 7 but limits on available relief)
Moore v. State, 388 Md. 446 (de novo review of statutory construction)
Jamison v. State, 450 Md. 387 (statutory‑interpretation principles)