State v. Northam
26 A.3d 344
| Md. | 2011Background
- Respondent Kendall I. Northam was charged in Worcester County with second degree murder and first degree assault, following his January 2008 arrest.
- Public defender W. Burton Anderson entered appearance; Respondent later protested ineffective assistance and sought pro bono counsel.
- Respondent submitted letters (Feb 26 and Feb 27, 2008) requesting new counsel and a preliminary hearing, and asserting dissatisfaction with counsel.
- A March 5, 2008 appearance included a colloquy where the court discussed representation and continued counsel; Anderson entered on Respondent’s behalf the next day.
- Motion practice included a July 31, 2008 denial of Respondent’s change-of-venue request; Respondent later moved again for venue and for court-appointed counsel.
- Trial proceeded September 25–26, 2008 with Anderson representing Respondent; Northam challenged admission and the handling of pretrial matters under Md. Rule 4-215(e).
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether Md. Rule 4-215(e) inquiry was triggered by the September 1, 2008 letter. | Northam contends 4-215(e) inquiry was required due to requests to discharge counsel. | State argues there was no meritorious discharge request and 4-215(e) was not implicated. | No 4-215(e) error; no discharge request properly presented. |
| Whether Respondent is entitled to a new trial based on Rule 4-215(e) violation. | Northam argues failure to comply justifies new trial. | State contends no violation occurred and no new trial is warranted. | Reversed on remand; Respondent not entitled to new trial on this ground. |
Key Cases Cited
- White v. State, 23 Md.App. 151 (1974) (motion-to-dismiss context; emphasizes responsibility to raise motions and seek rulings)
- Garner v. State, 414 Md. 372 (2010) (trial-counsel discharge considerations; duties of counsel and court reliance on representations)
- Campbell v. State, 385 Md. 616 (2005) (Md. Rule 4-215 inquiry when defendant expresses wish to discharge counsel)
- Miller v. State, 380 Md. 1 (2004) (omnibus motions and related procedural principles)
- Denicolis v. State, 378 Md. 646 (2003) (analysis of pretrial motions and procedural timing)