State v. Daughtry
18 A.3d 60
| Md. | 2011Background
- Affirmed guilty-plea convictions vacated due to insufficient on-record inquiry into knowing and voluntary nature of plea.
- Plea in 2006 to first-degree murder and use of handgun arose from robbery scheme that led to victim Brown’s death.
- Plea colloquy asked only whether respondent talked with counsel; no explicit explanation of elements of first-degree murder.
- Maryland Court of Special Appeals vacated convictions, citing incomplete advisement on elements.
- Maryland Court of Appeals revisits Priet/Henderson framework post-Bradshaw to require on-record discovery of understanding of the charge.
- Court holds the Henderson/Priet presumption cannot supply knowing/voluntary status when record shows only generic discussion with counsel; retroactivity applied to reaffirm totality-of-the-circumstances standard.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Bradshaw effect on Henderson presumption | State argues Bradshaw preserves presumption of counsel explanation | Daughtry argues presumption remains viable post-Bradshaw | Bradshaw does not overrule limited Henderson/Priet presumption; presumption cannot rescue a naked record |
| Must on-record inquiry show understanding of charge | State relies on Priet totality of circumstances | Daughtry argues record insufficient to show understanding of first-degree murder | Yes; on-record examination required; bare representation insufficient |
| Retroactive application of Bradshaw-era limits | State urges prospective application | Daughtry argues retroactivity to prior cases burden | Opinion gives full retrospective effect to reaffirm Priet/Henderson framework |
| Effect of totality-of-circumstances standard | Record could still show understanding through surrounding facts | Totality cannot be satisfied by mere attorney representation | Guilty plea vacated where record lacked explicit understanding of charge |
Key Cases Cited
- Henderson v. Morgan, 426 U.S. 637 (U.S. 1976) (presumption that defense counsel explained the offense may apply in most cases)
- State v. Priet, 289 Md. 267 (Md. 1981) (totality-of-circumstances test for knowing/voluntary plea; no fixed litany required)
- Bradshaw v. Stumpf, 545 U.S. 175 (U.S. 2005) (counsel may inform defendant; judge need not spell out elements on-record; preserves voluntariness)
- Abrams v. State, 176 Md.App. 600 (Md. Ct. Spec. App. 2007) (post-Bradshaw view on whether presumption suffices; requires explicit on-record advisement or counsel acknowledgment)
- Miller v. State, 185 Md.App. 293 (Md. Ct. Spec. App. 2009) (record lacks on-record explanation of elements; totality test governs)
- Gross v. State, 186 Md.App. 320 (Md. Ct. Spec. App. 2009) (on-record statements of discussing elements with counsel can support knowing plea (restricted post-Bradshaw))
- Rivera v. State, 180 Md.App. 693 (Md. Ct. App. 2008) (post-Bradshaw discussion of charges with counsel; later affirmed but not precedential for retroactivity)