Savoy v. State
22 A.3d 845
| Md. | 2011Background
- Savoy was convicted in Baltimore City Circuit Court of involuntary manslaughter, use of a handgun in the commission of a crime of violence, and carrying a handgun.
- The State presented evidence that Savoy shot Marvin Watts on May 28, 1993.
- At trial, the court instructed the jury on beyond a reasonable doubt using language including “to a moral certainty” and “convincing grounds of probability.”
- Savoy did not object to the instruction at trial.
- On direct appeal, he challenged only the handgun-merger issue; later post-conviction relief led to belated direct appeal challenging the reasonable-doubt instruction as plainly erroneous.
- The Court of Special Appeals affirmed; the Court of Appeals granted review and held the instruction contained constitutional, structural error warranting a new trial.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether the trial court’s reasonable doubt instruction was constitutionally deficient | Savoy argued the instruction lowered the prosecution’s burden | Savoy contends the instruction was structural error under Sullivan | Yes; the instruction was constitutionally deficient and structural. |
| Whether plain error review should be used to address unpreserved structural error | Savoy urged plain error review to obtain relief despite no objection | State argued plain error review only applies in limited circumstances | Yes; the Court exercised plain-error review and ordered a new trial. |
| Whether the error warranted automatic reversal or discretionary review | Savoy sought automatic reversal due to structural error | State urged discretionary review under Rule 4-325(e) | The Court elected discretionary plain-error review and remanded for a new trial. |
| Whether Ruffin and subsequent precedents govern prospective application to Savoy’s case | Savoy relied on prospective Ruffin effects | State argued prospective impact limited | Ruffin’s prospective effect did not bar review here; court treated case under applicable plain-error framework. |
Key Cases Cited
- Sullivan v. Louisiana, 508 U.S. 275 (U.S. 1993) (structural error for deficient reasonable-doubt instruction; not harmless)
- Cage v. Louisiana, 498 U.S. 39 (U.S. 1990) (deficient reasonable-doubt instruction; reversal)
- Victor v. Nebraska, 511 U.S. 1 (U.S. 1994) (contextual review; aids cure via accompanying definition)
- Himple v. State, 101 Md.App. 579, 647 A.2d 1240 (Md. Ct. App. 1994) (instruction mirroring Savoy’s; plain-error review used)
- Merzbacher v. State, 346 Md. 391, 697 A.2d 432 (Md. 1997) (absence of ‘without reservation’ language not always fatal)
- Wills v. State, 329 Md. 370, 620 A.2d 295 (Md. 1993) (reasonableness of doubt explanation evaluated in context)