holding that, for purposes of claims under Maryland Rule 4-215, “meaningful trial proceedings” began with the voir dire process in a criminal trial
How later courts described this case
- holding that, for purposes of claims under Maryland Rule 4-215, “meaningful trial proceedings” began with the voir dire process in a criminal trial
- "[W]e hold th[e] `meaningful trial proceedings' have begun after a trial court has begun the voir dire process in a criminal trial."
- “[T]he proper resolution of this issue is that ‘meaningful trial proceedings’ have begun when a request to discharge counsel is made during voir dire.”
- “We refused to draw a bright line definition delimiting the precise moment that marks the beginning of ‘meaningful trial proceedings!.]’ ”
Written by the judges who cited it.
The opinion
ADKINS, J.,
Concurring and Dissenting.
I agree with the majority that there should be a bright-line test, and that the commencement of voir dire is the appropriate demarcation for the commencement of “meaningful trial proceedings” in a jury trial. Thus, I join Part IV, A and B, of the Majority opinion. I respectfully dissent, however, from the balance of the Majority opinion for the reasons set forth in Section III of the Dissent of Chief Judge Bell, which I join. I agree with him that even without the dictates of Rule 4-215, the trial court failed to make a proper inquiry about Hardy’s claim that his counsel was inadequate. See State v. Brown, 342 Md. 404 , 676 A.2d 513 (1996).