Diggs and Ramsey v. State

973 A.2d 796, 409 Md. 260, 2009 Md. LEXIS 203
CourtCourt of Appeals of Maryland
DecidedJune 12, 2009
Docket110, 147, September Term, 2008
StatusPublished
Cited by24 cases

This text of 973 A.2d 796 (Diggs and Ramsey v. State) 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
Diggs and Ramsey v. State, 973 A.2d 796, 409 Md. 260, 2009 Md. LEXIS 203 (Md. 2009).

Opinions

BATTAGLIA, J.

In this opinion, we are called upon to determine whether Steven Diggs and Damon Lamar Ramsey, Appellants, are [263]*263entitled to new trials, because the judge who presided over their original proceedings acted like a co-prosecutor. It is clear in both of these cases that neither of the prosecutors presented the cases well, nor did the defense attorneys adequately represent their clients. Nevertheless, it is the presiding judge who is the subject of the questions presented. Diggs presents the following question:

1. Was Mr. Diggs deprived of a fair trial because the trial court failed to preserve an attitude of impartiality in his questioning of witnesses?

Diggs v. State, 406 Md. 443, 959 A.2d 792 (2008). In the companion bypass case,1 Ramsey presents the following questions:

1. Did the trial court violate Damon Ramsey’s constitutional right, under the Fifth and Fourteenth Amendments, to a fair trial where the trial judge acted as a second prosecutor and created a hostile courtroom environment for defense counsel in front of the jury, all of which suggested extreme bias against the defense?
2. Did the trial court violate Damon Ramsey’s Sixth Amendment right to confront his accuser when the trial judge prevented defense counsel from challenging the credibility of the only police officer to testify against Damon Ramsey? [2]

Ramsey v. State, 406 Md. 744, 962 A.2d 370 (2008).

I. Background

Steven Diggs was arrested and charged in Baltimore City with possession of marijuana, possession of marijuana with an intent to distribute, operating an unregistered motor vehicle, driving an uninsured vehicle, and driving without a license. [264]*264During the course of trial proceedings that occurred on June 1, 2007, Diggs was tried for possession of marijuana and possession of marijuana with an intent to distribute.3 A jury found Diggs guilty on the charge of possession of marijuana, but was unable to render a unanimous decision on the charge of possession of marijuana with an intent to distribute. Diggs appeals from his conviction, alleging that he was denied a fair trial as a result of judicial bias, premised upon repeated and egregious behavior of the trial judge.

Diggs’ first allegation of bias involves statements made by the judge during the direct examination of Detective John Giganti, who testified that he pulled Diggs’ vehicle over because it had no license plates and thereafter discovered what he believed to be marijuana. When the prosecutor did not adequately lay the foundation for distribution of the marijuana, the judge pursued his inquiry more specifically about the packaging of the marijuana:

[STATE’S ATTORNEY:] Now, based on your expertise and experience, did you draw any conclusion as to the number of ziplock baggies recovered, the thirty-five baggies?
[DETECTIVE GIGANTI:] It was not for personal use. It was for street level distribution.
[STATE’S ATTORNEY]: And what about the money in the console?
THE COURT: Let me stay with that for a second. Why do you say that, sir, that it would be for street level distribution, not for personal use. What is about it—
[DETECTIVE GIGANTI:] Thirty-five bags of marijuana is a lot of personal use.
THE COURT: Okay. How about the individual packages?
[265]*265[DETECTIVE GIGANTE] They are probably worth about ten dollars a piece.
THE COURT: And they’re packaged individually?
[DETECTIVE GIGANTE] They’re packaged individually in small ziplock bags and the money again with small denominations other than a hundred dollar which would be consistent with ten dollar or dime bags as they’re known on the street, of marijuana.

Diggs also contends that the judge interfered during Detective Georgiades’ direct examination, because after Detective Georgiades could not recall telling Detective Giganti that he had previous contact with Diggs or previously had arrested Diggs, the judge allegedly attempted to rehabilitate the officer by stating: “It was over two and a half years ago, right? I mean we’re talking November and the event would have been September '04 so okay.”

Diggs further posits that the judge acted as a co-prosecutor during the direct examination of Diggs’ first witness, Sherienne Diggs, Diggs’ sister. The first instance of bias allegedly arose when Sherienne Diggs failed to recall various details about money and marijuana bags found in her car, and the judge pressed her for details:

[DEFENSE COUNSEL:] Okay. How much money? Did you count the money?
[MS. DIGGS:] Yeah, I counted it.
[DEFENSE COUNSEL:] How much was there?
[MS. DIGGS:] It was $1,800.
[DEFENSE COUNSEL:] Okay.
THE COURT: Do you remember the denominations of the bills?
[MS. DIGGS:] No, not exactly.
THE COURT: Do you remember if there were any hundred dollar bills in there?
[MS. DIGGS:] It might have been.
THE COURT: Not might have been. Do you remember one?
[266]*266[DEFENSE COUNSEL:] Do you remember or don’t? It doesn’t matter.
[MS. DIGGS:] No, I don’t remember.
THE COURT: You’d probably remember a hundred dollar bill, wouldn’t you?
[MS. DIGGS:] Not if you see a lot of them all the time. THE COURT: Did you see a lot of them that day?
[MS. DIGGS:] Later on that day I did.
THE COURT: How about earlier—
[MS. DIGGS:] I don’t remember.
THE COURT: When he handed you the money you remember a lot of hundred dollar bills?
[MS. DIGGS:] I remember a lot of twenties.
THE COURT: A lot of twenties. Do you remember a hundred?
[MS. DIGGS:] I’m not sure. I think so. I’m not sure.
[DEFENSE COUNSEL]: Okay. So you don’t recall?
[MS. DIGGS:] No.

During cross-examination, Diggs points to numerous instances in which the judge allegedly acted inappropriately. When the State questioned Ms. Diggs about her recollection of how long her brother had been staying at her house, she responded “[n]ot long” and “[m]aybe weeks.” The judge intervened and again pressed for details:

THE COURT: Was it weeks or was it days? You have a very good memory on everything else.
THE COURT: Days.
[MS. DIGGS:] Days.
THE COURT: Days.

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Diggs and Ramsey v. State
973 A.2d 796 (Court of Appeals of Maryland, 2009)

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Bluebook (online)
973 A.2d 796, 409 Md. 260, 2009 Md. LEXIS 203, Counsel Stack Legal Research, https://law.counselstack.com/opinion/diggs-and-ramsey-v-state-md-2009.