80 A.3d 242
Md.2013Background
- Miles, a convicted murderer, was sentenced to death by a Maryland jury in 1998 after multiple reviews.
- He filed a second motion to correct illegal sentence in July 2011 alleging his death sentence violates the Maryland Declaration of Rights.
- Miles argues MDR Article 16’s sanguinary laws clause abolishes capital punishment, and MDR Article 24 requires jury verdicts to weigh aggravators beyond a reasonable doubt.
- The State moved to dismiss; the court treated the blood-penalty issue as a potential Rule 4-345(a) challenge and denied relief on the second issue as impermissible under Rule 4-345(a).
- The Court of Appeals affirmed the circuit court’s denial on the sanguinary laws issue and held the second issue cognizable only under Rule 4-345(a) to a limited extent; chapter 156 (2013) repealed the death penalty, but savings provisions preserved the appeal.
- The court conducted a historical/constitutional analysis of the sanguinary laws concept, concluding death by lethal injection for murder is not a cruel or unusual punishment and that Article 16’s sanguinary laws clause did not retroactively abolish capital punishment.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Does MDR Article 16 abolish capital punishment for murder under the sanguinary laws clause? | Miles contends the 1776 sanguinary laws phrase bars the death penalty. | The State contends sanguinary laws apply prospectively to legislative action and do not abolish the existing death penalty for murder. | No retroactive abolition; death for murder remains constitutional under Article 16. |
| Is the weighing procedure for aggravating vs. mitigating factors unconstitutional under MDR Article 24? | Miles argues preponderance review violates Article 24’s right to judgment by peers or the law of the land. | The weighing procedure was not challenged as inherently illegal; procedural error cannot render a lawful sentence illegal under Rule 4-345(a). | Rule 4-345(a) allows latitude for new constitutional interpretations but does not render the sentence illegal on the Article 24 theory. |
Key Cases Cited
- Evans v. State, 396 Md. 256 (Md. 2006) (post-sentencing change in law allows Rule 4-345(a) review for new constitutional interpretations)
- Cunningham v. California, 549 U.S. 270 (U.S. 2007) (Sixth Amendment requires jury finding beyond a reasonable doubt for aggravators?)
- Tshiwala v. State, 424 Md. 612 (Md. 2012) (limits of Rule 4-345(a) in collateral challenges to sentencing)