Peterson v. State
226 A.3d 246
Md.2020Background
- In 2007 Peterson was found guilty (two counts of second-degree assault) but adjudged not criminally responsible (NCR) and committed to the Maryland Department of Health for inpatient treatment.
- The court never canvassed him about a jury trial waiver or whether he knowingly pleaded guilty; the court ordered civil commitment rather than a criminal prison sentence.
- Peterson was repeatedly conditionally released with stringent treatment- and residency-related conditions and was sometimes re-confined for violations.
- While on conditional release he filed a pro se post-conviction petition under the Uniform Post-Conviction Procedure Act (UPPA) and later a petition for writ of error coram nobis; both were denied by the circuit court and the Court of Special Appeals affirmed.
- The Court of Appeals affirmed: UPPA relief does not extend to NCR defendants who are civilly confined or on conditional release; coram nobis was unavailable because his confinement and conditional-release orders were direct (not collateral) consequences of the NCR finding; but habeas relief may be available post-Sabisch and a circuit court could consider an appropriate habeas petition.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether UPPA post-conviction relief applies to a defendant convicted but found NCR and civilly confined or on conditional release | Peterson: UPPA should cover NCR defendants on conditional release because they are "convicted" and suffer substantial restraints; otherwise no adequate collateral remedy exists | State: UPPA applies only to those "confined under sentence of imprisonment" or "on parole or probation"; conditional release and civil commitment are not parole/probation or imprisonment | Held: UPPA does not apply; plain language limits relief to those imprisoned or on parole/probation and civil commitment/conditional release are not equivalent to criminal imprisonment or parole/probation |
| Whether writ of error coram nobis is available to an NCR defendant on conditional release | Peterson: coram nobis should be available to correct constitutional or fundamental defects in the conviction/NCR process | State: coram nobis is extraordinary and requires significant collateral consequences arising from the conviction; his commitment/conditional release are direct consequences, not collateral | Held: Denied — petitioner failed element requiring significant collateral consequences because commitment and conditional release were direct consequences of the NCR disposition |
| Whether habeas corpus relief may be available to an NCR defendant who is civilly committed or on conditional release | Peterson: habeas should be available to challenge confinement/restraints on liberty following an NCR finding | State: historically argued habeas required physical custody, but conceded relief might follow if physical-custody requirement removed | Held: Circuit courts may entertain habeas petitions post-Sabisch; civil commitment and conditional-release restraints fall within statute’s language and can present a sufficient restraint to trigger habeas review |
Key Cases Cited
- Jones v. State, 445 Md. 324 (2015) (sets five-element coram nobis standard)
- Anderson v. Dep’t of Health & Mental Hygiene, 310 Md. 217 (1987) (civil commitment is the disposition following guilty verdict + insanity-type finding)
- Sabisch v. Moyer, 466 Md. 327 (2019) (held physical custody not always required for habeas eligibility under Maryland statute)
- Harrison-Solomon v. State, 442 Md. 254 (2015) (conditional release and commitment are protective, not punitive)
- Pouncey v. State, 297 Md. 264 (1983) (distinguishes punishment for guilty defendants from disposition of NCR defendants)
- Addington v. Texas, 441 U.S. 418 (1979) (civil commitment is a significant deprivation of liberty requiring due process)
- O’Connor v. Donaldson, 422 U.S. 563 (1975) (involuntary commitment is a liberty deprivation)
- Vitek v. Jones, 445 U.S. 480 (1980) (recognizes constitutional concerns in civil confinement)
- Yoswick v. State, 347 Md. 228 (1997) (distinguishes direct v. collateral consequences of conviction)