Background

• Yonga pled guilty in 2006 to a third-degree sexual offense involving a 13-year-old girl after a Baltimore County incident; plea included dismissal of a more serious charge and a 364-day sentence with all but six months suspended, plus sex offender registration.
• The trial judge ensured the plea was voluntary, knowledgeable, and supported by a factual basis, and warned about immigration consequences.
• Six years later, in 2013, Yonga sought a Writ of Actual Innocence under Md. Crim. Proc. § 8-301 based on alleged recantation of the alleged victim, TR, after discovery of new information.
• The circuit court denied relief; the Court of Special Appeals held the writ does not apply to guilty-plea convictions, and certiorari was granted to decide the applicability and scope of § 8-301 to guilty-plea cases.
• The Court of Appeals held that a guilty plea cannot be the basis for a § 8-301 petition; the 8-301 petition framework (and its weight standard) applies only to post-trial convictions, not to guilty pleas; the Court affirmed the Court of Special Appeals' judgment.
• Judgment: Affirmed; costs to be borne by Yonga.

Issues

Key Cases Cited

• Campbell v. State, 373 Md. 637 (2003) (trial judge weighs newly discovered evidence against trial record in post-verdict context)
• Matthews, 415 Md. 286 (2010) (questioned applicability of 8-301 post-enactment; treated as potential writ depending on procedural posture)
• Ar g y r o u v. State, 349 Md. 587 (1998) (standard for weighing new evidence post-trial; credibility and trial context importance)
• Yorke v. State, 315 Md. 578 (1989) (standard for newly discovered evidence in post-trial motions)
• Wilson v. State, 363 Md. 333 (2001) ( Brady violation context informing discovery standards)