Bivens v. Clark

CourtCourt of Appeals of Maryland
DecidedJuly 11, 2025
Docket48/24
StatusPublished

This text of Bivens v. Clark (Bivens v. Clark) is published on Counsel Stack Legal Research, covering Court of Appeals of Maryland primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Bivens v. Clark, (Md. 2025).

Opinion

Carlos D. Bivens v. Amondre Clark, No. 48, September Term, 2024, Opinion by Booth, J.

TIME SERVED CREDIT FOR VACATED SENTENCES ARISING FROM VACATED CONVICTIONS—MARYLAND CODE ANN., CRIMINAL PROCEDURE ARTICLE (“CP”) § 6-218(d)

When a criminal defendant’s term of confinement consists of multiple sentences, and one or more convictions underlying those sentences is vacated, but at least one valid, active sentence remains, the defendant is entitled to receive credit for time served required by CP § 6-218(d) when the conviction is vacated and commencing on the date of the first invalidated sentence. This interpretation of CP § 6-218(d) is consistent not only with its plain and unambiguous language, but also with the statute’s purpose of eliminating “dead time”—time spent in custody that will not be credited to any valid sentence. It also ensures a one-for-one method of awarding time-served credits.

TIME SERVED CREDIT WHEN A DEFENDANT IS REPROSECUTED OR RETRIED—CP § 6-218(c)

Where CP § 6-218(d) has already been applied, and a criminal defendant is reprosecuted or retried after his or her conviction is vacated, and the proceeding results in a new conviction, CP § 6-218(c) applies to the extent that there is leftover credit remaining after credit has been given under CP § 6-218(d) for time spent in custody on the invalidated judgment(s) at the time those judgments were stricken.

NEW SENTENCE ARISING FROM NEW CONVICTION—LAST CHAIN IN THE SENTENCING SEQUENCE AND IN THE BATTING ORDER

Where a reprosecution or retrial results in a new conviction, the new sentence is in last place in a chain of consecutive sentences, and the sentencing judge who imposes the new sentence is in last place in the sentencing batting order. In that case, the sentencing judge may make the new sentence(s) consecutive or concurrent to any then-existing sentences.

SENTENCING COURT’S DISCRETIONARY SENTENCING AUTHORITY

In this case, the sentencing record does not reflect whether the sentencing judge, in exercising his sentencing discretion, accounted for remaining valid consecutive sentences when he announced the time served sentence arising from the new conviction. Given the many disconnects in the record, the Supreme Court of Maryland vacated the judgment of the habeas court, and remanded the case to the habeas court with instructions to: (1) vacate the sentence entered on April 17, 2024; and (2) remand the matter to the sentencing court to enable the sentencing court to exercise its discretion with a full and complete understanding of the status of the valid sentences. Circuit Court for Baltimore City Case No.: C-24-CV-24-000761 Argued: June 5, 2025

IN THE SUPREME COURT

OF MARYLAND

No. 48

September Term, 2024

CARLOS D. BIVENS

v.

AMONDRE CLARK

Fader, C.J., Booth, Biran, Gould, Eaves, Killough, Getty, Joseph M., (Senior Justice) Specially Assigned,

JJ.

Opinion by Booth, J.

Filed: July 11, 2025

Pursuant to the Maryland Uniform Electronic Legal Materials Act (§§ 10-1601 et seq. of the State Government Article) this document is authentic.

2025.07.11 '00'04- 14:27:34 Gregory Hilton, Clerk This appeal arises from the successful petition for writ of habeas corpus filed by

Appellee, Amondre Clark, and his release from the custody of the Division of Correction

(“Division”). As we discuss more fully herein, after several of Mr. Clark’s convictions

were vacated on October 20, 2023, the Division did not execute the next valid sentences

under Mr. Clark’s term of confinement and apply credit for time served under the vacated

convictions. Instead, the Division tolled his next valid consecutive sentences and waited

to see if the State’s reprosecution would result in a new conviction.

When Mr. Clark pled guilty to one of the charges against him on April 17, 2024, the

sentencing judge sentenced him to a new “time served” sentence. The record of the

sentencing hearing reflects that the court and the parties expected Mr. Clark to be

immediately released. However, the Division refused to release Mr. Clark. The Division

did not treat the April 17, 2024 time served sentence as a new sentence, but instead

considered it a “replacement sentence” for one of the sentences that had been vacated when

Mr. Clark’s convictions were invalidated. The Division then tacked on the consecutive

sentences that it had tolled pending reprosecution. The Division’s sentence restructuring

was based upon an informal policy change to the manner in which it interpreted subsections

(c) and (d) of § 6-218 of the Criminal Procedure (“CP”) Article of the Maryland Code

(2018 Repl. Vol., 2024 Supp.) and this Court’s decision in Scott v. State, 454 Md. 146

(2017). The result of the restructuring was that Mr. Clark received no credit for the time

he served on the vacated convictions against the convictions that were never vacated.

Mr. Clark filed a petition seeking habeas relief in the Circuit Court for Baltimore

City, asserting that the Division incorrectly interpreted the provisions of CP § 6-218(c) and (d). The habeas court agreed and ordered his immediate release. The Division appealed

to the Appellate Court of Maryland. While this case was pending in the Appellate Court,

we granted Mr. Clark’s petition for a writ of certiorari to answer the following question,

which we have slightly rephrased:

Whether the habeas court correctly concluded that, upon the vacatur of an individual’s convictions, the Division must: (1) immediately execute any remaining valid sentence in the individual’s term of confinement and apply credit for time served under the vacated conviction pursuant to CP § 6- 218(d); and (2) treat any new conviction imposed upon reprosecution as a new, separate judgment rather than a modification of sentence.

We agree with the habeas court’s legal conclusions as they are phrased above.

However, as discussed below, the sentencing record does not reflect whether the sentencing

judge, in exercising his sentencing discretion, accounted for remaining valid consecutive

sentences when he announced the time served sentence arising from the new conviction.

Given the many disconnects in the record, we vacate the judgment of the habeas court, and

remand this case to the habeas court with instructions to: (1) vacate the sentence entered

on April 17, 2024; and (2) remand the petition to the Circuit Court for Montgomery County

in case number 127950C for the sentencing court to exercise its discretion with a full and

complete understanding of the status of the valid sentences.

I

Underlying Convictions

On January 7, 2016, Mr. Clark was sentenced in the Circuit Court for Montgomery

County, in case numbers 127869C, 127950C, and 128051C, for firearm- and burglary-

related convictions, as follows:

2 • -869C: 10 years with all suspended but 5 years without parole;

• -950C: 8 years with all suspended but 5 years, consecutive to -869C; and

• -051C: 8 years with all suspended but 3 years, consecutive to -869C and -950C

In these cases, Mr. Clark was sentenced to a 26-year total term, with all but 13 years

suspended.

On February 18, 2016, Mr. Clark was sentenced for a violation of probation in the

Circuit Court for Montgomery County in case number 123587C, Count I (Third Degree

Burglary), to 3 years and 6 months, to be served consecutive to the sentences imposed in

case numbers -869C, -950C and -051C.

On October 20, 2022, Mr. Clark was sentenced in the Circuit Court for Washington

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