State v. Meadows

314 A.3d 395

261 Md.App. 464

STATE of Maryland

v.Robert Lee MEADOWS

No. 1750 September Term, 2022

Appellate Court of Maryland.

April 22, 2024

Circuit Court for Cecil County, Case No. C-07-CR-22-000501, Brenda Sexton, Judge

Argued by Benjamin A. Harris, Asst. Atty. Gen. (Anthony G. Brown, Atty. Gen. of Maryland, Baltimore, MD), on brief, for Appellant.

Argued by Tia L. Holmes, Asst. Public Defender (Natasha M. Dartigue, Public Defender of Maryland, Baltimore, MD), on brief, for Appellee.

Argued before: Arthur, Shaw, J. Frederick Sharer (Senior Judge, Specially Assigned), JJ.

Arthur, J.

The Interstate Agreement on Detainers Act (the "IAD"), Maryland Code (1999, 2017 Repl. Vol.), §§ 8-401 through 8-411 of the Correctional Services Article ("Corr. Servs."), gives prisoners incarcerated in one state the right to request the prompt disposition of charges filed against them in another state.

[1, 2] Once a prisoner invokes the IAD to request the disposition of the charges pending in another state, the charging state has 180 days to commence the trial. The burden of bringing the prisoner to trial falls on the charging state. If that state fails to bring the prisoner to trial within 180 days, the IAD requires that the charges be dismissed with prejudice. However, the court may extend the deadline upon a finding of good cause. And the prisoner may waive the right to have the trial commence within the 180-day deadline.

This case principally concerns whether a prisoner waives the right to have the trial commence within 180 days by remaining silent and not objecting when the court schedules the trial to begin on a date after the 180-day deadline has run. The case also concerns whether the State can avoid the deadline by dismissing the district court charges on which the prisoner has requested to be tried and indicting the prisoner on the same or similar charges in the circuit court.

When confronted with these questions, the Circuit Court for Cecil County dismissed the indictment. For the reasons stated below, we shall affirm.

Factual and Procedural Background

On May 10, 2021, the District Court of Maryland for Cecil County issued a statement of charges and an arrest warrant for appellee Robert Lee Meadows. The statement of charges charged Meadows with first-degree assault, illegal possession of a firearm, possession of a handgun in a vehicle, and other related offenses. At the time, Meadows was incarcerated in Delaware County, Pennsylvania.

On June 15, 2021, the State of Maryland issued a detainer—" ‘a notification filed with the institution in which a prisoner is serving a sentence, advising that he is wanted to face pending criminal charges in another jurisdiction’"¹—against Meadows. On the following day, Meadows received formal notice of the detainer and signed a waiver of extradition, consenting to be transferred to Maryland to face the criminal charges.

On February 17, 2022, Meadows invoked his rights under the IAD to request the final disposition of all untried indictments, informations, or complaints that had been lodged against him by the State of Maryland. See Corr. Servs. § 8-405(a). The Office of the State’s Attorney for Cecil County received Meadows’s IAD request on March 15, 2022. The District Court of Maryland for Cecil County received Meadows’s IAD request on March 25, 2022. The parties agree that under the IAD the State was required to bring Meadows to trial by September 21, 2022—180 days from the date when both the State’s Attorney and the district court had received Meadows’s request. See Corr. Servs. § 8-405(a).

On March 31, 2022, the State’s Attorney requested that a trial be scheduled in the District Court of Maryland for Cecil County within 180 days of February 17, 2022. The district court directed that the case be "[s]et for trial prior to 6/30/22." The district court did not have jurisdiction over several of the felonies with which Meadows was charged.

On May 20, 2022, Meadows was transported to the Cecil County Detention Center.

On May 25, 2022, a grand jury in the Circuit Court for Cecil County indicted Meadows on a total of 24 counts—five counts of first-degree assault, five counts of the use of a firearm in a crime of violence, one count of possession of a regulated firearm after being convicted of a crime of violence, and other related charges. On May 26, 2022, the State’s At- torney informed the district court that the grand jury had indicted Meadows and asked the district court to forward the case to the circuit court and to recall the arrest warrant. On the following day, May 27, 2022, the State entered a plea of nolle prosequi on all of the district court charges. Meadows was arraigned in the circuit court on June 1, 2022.

On June 6, 2022, the circuit court’s assignment office scheduled a status conference on July 19, 2022, a pre-trial hearing on November 14, 2022, and a three-day trial beginning on November 15, 2022. Meadows’s counsel entered his appearance and received notice of the trial dates on June 16, 2022.

Counsel for Meadows and the State attended the status conference on July 19, 2022. At the status conference, the following conversation occurred:

[STATE:] Your Honor, we are here for status conference this morning. This matter is set for trial, sorry, pre-trial conference November 14, trial set for two days, November 16 and 17.

I have provided discovery to the Office of the Public Defender. I understand that they have received it, although [Defense Counsel] is still reviewing it. …

[THE COURT:] So I have pre-trial November 14, and then a three-day trial, 15, 16, 17.

[STATE:] I thought it was two days, 16 and 17….

[THE COURT:] I have November 15, 16, and 17.

[STATE:] —set for three days. …

When counsel for Meadows had the opportunity to address the court, he did not mention the proposed trial date. Instead, he spoke of the amount of discovery that the case would involve:

[COUNSEL FOR MEADOWS:] There [are] five alleged victims, Your Honor. I mean, their statements are relatively short, they are written statements that have been provided so far. I don’t believe there were any actual recorded statements other than the ones in writing. But again, I am reviewing it. Voluminous discovery was disclosed on July 7th, so it has only been a few days to review it. But I will review it with Mr. Meadows and will raise any issues that need to be raised.

At the conclusion of the status conference, the court asked the parties whether they had anything else to bring to the court’s attention:

[THE COURT:] So there aren’t any other issues then, Mr. [Prosecutor]?

[STATE:] Nothing from the State, Your Honor. Thank you.

[THE COURT:] Any other issues, [defense counsel]?

[COUNSEL FOR MEADOWS:] Not at this time. They will be raised by motion.

[THE COURT:] All right. Thank you very much. Then we will see you November 14 at 1:30. Thank you.

[COUNSEL FOR MEADOWS:] Thank you.

The 180-day deadline ran on September 21, 2022. On October 7, 2022, Meadows filed a motion to dismiss, arguing that the State had violated his rights under the IAD by failing to bring him to trial within 180 days of when both the district court and the State’s Attorney had received his request.

On November 14, 2022, the court heard argument on Meadows’s motion to dismiss. In opposing the motion, the State argued that Meadows had waived his rights under the IAD by acquiescing in a trial date that fell beyond the 180-day deadline. The State also argued that the circuit court indictment was a "brand new charging document," separate from (though "similar" to) the statement of charges in the district court. Thus, the State argued that it had disposed of the relevant charges— the charges on which Meadows had requested to be tried—within the 180-day deadline when it dismissed the district court case on May 27, 2022. The court granted Meadows’s motion.

The State noted a timely appeal.²

Question Presented

The State presents one question on appeal: "Did the motions court err when it granted Meadows’s motion to dismiss based on a putative violation of the Interstate Agreement on Detainers?" We perceive no error.

Standard of Review

[3] "The propriety of the Circuit Court’s dismissal of the charges hinges on whether that court correctly interpreted and applied the IAD to the facts before it." State v. Pair, 416 Md. 157, 168, 5 A.3d 1090 (2010). "As the facts are not in dispute, we have only to decide whether the court was legally correct in its interpretation of the law." Id.; accord Pitts v. State, 205 Md. App. 477, 486, 45 A.3d 872 (2012).

Discussion

A. The Interstate Agreement on Detainers

"The IAD, to which Maryland became a signatory in 1965, is a congressionally sanctioned compact among forty-eight states, the Federal Government, Puerto Rico, the U.S. Virgin Islands, and the District of Columbia." State v. Pair, 416 Md. at 160, 5 A.3d 1090. In Maryland the IAD is codified at §§ 8-401 through 8-411 of the Correctional Services Article.³

The IAD consists of nine articles, "which, in Maryland, correspond to sections of the Correctional Services Article of the Maryland Code." Aleman v. State, 469 Md. 397, 406-07, 230 A.3d 97 (2020).

Article I of the IAD⁴ states that "charges outstanding against a prisoner, detainers based on untried indictments, informations, or complaints, and difficulties in securing speedy trial of persons already incarcerated in other jurisdictions, produce uncertainties which obstruct programs of prisoner treatment and rehabilitation." "Accordingly," Article I states, "it is the policy of the party states and the purpose of this Agreement to encourage the expeditious and orderly disposition of such charges[.]" Corr. Servs. § 8-403.

In Carchman v. Nash, 473 U.S. 716, 72930, 105 S.Ct. 3401, 87 L.Ed.2d 516 (1985), the United States Supreme Court explained part of the motivation for the IAD:

Adoption of the Agreement was motivated in part by a practice of filing detainers based on untried criminal charges that had little basis. These

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