Williams v. State
208 Md. App. 622
Md. Ct. Spec. App.2012Background
- Williams was convicted in Harford County Circuit Court of possession of cocaine and resisting arrest, sentenced as a subsequent offender to eight years with four suspended for possession and two years with one suspended for resisting arrest.
- The incident occurred Sept. 15, 2008, involving deputies Krulock and Schultz who observed Williams with his left hand in his shorts in a high crime area and a bag fell from his hand.
- Williams fled when deputies attempted to detain him; a bystander held him until deputies arrived and he continued to resist, leading to a taser deployment and handcuffing.
- During arrest, a plastic bag in Williams’ wallet yielded cocaine; in transport, another search revealed cocaine and marijuana with fecal material on the package.
- Williams testified he found a bag while visiting a recovery house and panicked, explaining his flight as a desire to escape confinement.
- Trial occurred May 2011 after delays largely due to competency assessments.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Discharge of counsel under Rule 4-215(e) | Williams asserted the court failed to address his pro se request to discharge counsel. | Williams' letter sufficiently notified the court of desire to change counsel triggering Rule 4-215(e). | Rule 4-215(e) not triggered; no waiver due to lack of on-record request. |
| Sufficiency of the evidence for resisting arrest | State contends the force against the bystander and timing supported resistance. | Appellant argues initial flight lacked sufficient force; only bystander’s restraint mattered. | Evidence supported resisting arrest based on known arrest attempt and force used against the bystander; flight alone insufficient but later force satisfied the element. |
Key Cases Cited
- Pinkney v. State, 427 Md. 77 (Md. 2012) (mandatory compliance with Rule 4-215(e))
- State v. Davis, 415 Md. 22 (Md. 2010) (triggering Rule 4-215(e) when present intent to seek new counsel)
- Northam, 421 Md. 195 (Md. 2011) (waiver when not brought to court’s attention on the record)
- Garner v. State, 414 Md. 372 (Md. 2010) (courts may rely on counsel’s representation for purposes of Rule 4-215)
- White v. State, 23 Md.App. 151 (Md. 1974) (defining duty to bring undecided motions to the trial court)