In Maryland, previously heard and published criminal cases serve as important precedents for motions to suppress evidence. These cases address various legal standards and rights, including illegal search and seizure, Miranda rights, and other related issues.
Key Cases for Suppressing Evidence
- Miranda v. Arizona (1966):
– Established that individuals must be informed of their rights before custodial interrogation. Evidence obtained without proper Miranda warnings may be suppressed.
- Franks v. Delaware (1978):
– Allows defendants to challenge the validity of search warrants based on false information. If the affidavit supporting the warrant includes intentionally or recklessly false statements, evidence may be suppressed.
- Mapp v. Ohio (1961):
– Incorporated the Exclusionary Rule, which prohibits the use of evidence obtained through illegal searches and seizures in state courts.
- Brady v. Maryland (1963):
– Mandates the prosecution to disclose evidence that may exonerate the defendant. Failure to disclose such evidence can lead to suppression.
- Maryland v. King (2013):
– Addressed the constitutionality of collecting DNA samples without a warrant during arrests, impacting how evidence from such searches is treated.
- State v. Smith (2008):
– Examined the validity of warrantless searches, emphasizing the necessity for probable cause.
Common Reasons to File a Motion to Suppress
- Illegal Search and Seizure:
– Evidence obtained without a valid warrant or probable cause can be challenged under the Fourth Amendment.
- Violation of Miranda Rights:
– Any statements made during custodial interrogation without proper warnings can be suppressed.
- Franks Motion:
– Challenge the legitimacy of a search warrant based on false or misleading information.
Common Reasons for Filing a Motion in Limine
- Preventing Mention of Prior Convictions:
– To avoid undue prejudice against the defendant.
- Preventing Mention of the Defendant’s Decision Not to Testify:
– Protects the defendant’s right against self-incrimination.
- Preventing Mention of Co-Defendant Statements:
– To ensure fair trial rights and avoid hearsay issues.
- Preventing Questionable Scientific Evidence:
– To challenge the admissibility of unreliable expert testimony.
- Requiring Disclosure of Confidential Informants:
– To ensure the defense can assess the credibility of informants used by law enforcement.
Maryland Rule 4-252
This rule outlines the procedure for filing motions to suppress evidence obtained through illegal searches or seizures. It specifies that such motions must be filed within 30 days of the defendant’s first court appearance.
Conclusion
A motion to suppress is a critical aspect of criminal defense in Maryland, allowing attorneys to challenge the legality and reliability of evidence. By referencing established case law and procedural rules, defense attorneys can effectively argue for the exclusion of evidence that could compromise the fairness of a trial.
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