Rodger Wyley, 3253 v. Warden, Maryland Penitentiary

372 F.2d 742, 1967 U.S. App. LEXIS 7828
CourtCourt of Appeals for the Fourth Circuit
DecidedJanuary 10, 1967
Docket10710
StatusPublished
Cited by35 cases

This text of 372 F.2d 742 (Rodger Wyley, 3253 v. Warden, Maryland Penitentiary) is published on Counsel Stack Legal Research, covering Court of Appeals for the Fourth Circuit primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Rodger Wyley, 3253 v. Warden, Maryland Penitentiary, 372 F.2d 742, 1967 U.S. App. LEXIS 7828 (4th Cir. 1967).

Opinion

SOBELOFF, Circuit Judge:

This appeal by a state prisoner attacks on federal constitutional grounds Article XV, section 5 of the Constitution of Maryland which leaves to the jury the final determination of the law as well as the facts in a criminal trial. The provision reads as follows:

In the trial of all criminal cases, the Jury shall be the Judges of Law, as well as of fact, except that the Court may pass upon the sufficiency of the evidence to sustain a conviction.

On November 19, 1953 a jury in the Criminal Court of Baltimore found Rodger Wyley guilty of first degree murder, without capital punishment, and he was thereupon sentenced to prison for life. Wyley’s petition for a writ of federal habeas corpus attacked his conviction on a number of grounds, but the only one which concerns us on this appeal is whether the trial judge’s instruction to the jury, given in accordance with Article XV, section 5, denied defendant due process and equal protection of the laws in violation of the Fourteenth Amendment. 1 While acknowledging “the force of many of the arguments made by counsel for the petitioner,” the District Court dismissed the petition on the basis of *744 Giles v. Maryland, 372 U.S. 767, 83 S.Ct. 1102, 10 L.Ed.2d 137 (1963). In that case, the constitutionality of section 5 had been brought into question,- but the Supreme Court dismissed the appeal “for want of a substantial federal question.”

Appellant objects that charging that “in a criminal case the jury are the judges of the law as well as of the facts” permits them to apply any concept of law they see fit to his case, and that this amounts to a deprivation of due process of law. He further argues that the instruction permits the jury to reach a different legal conclusion in his case from that which they might reach in another case presenting identical facts, and so denies him the equal protection of the law.

Every time the issue has been raised in the Court of Appeals of Maryland it has affirmed the constitutionality of section 5 without qualification. In 1949, this provision was attacked on due process grounds in Slansky v. State, 192 Md. 94, 63 A.2d 599 (1949). After a comprehensive and thorough analysis, tracing the historical development of the rule, the court concluded that although section 5 was “anachronistic,” it was not unconstitutional. More recently, in Giles v. State, 229 Md. 370, 183 A.2d 359 (1962), the Maryland court again had occasion to consider this provision. Reviewing its decision in Slansky, the court found no reason for overturning it, on either due process or equal protection grounds.

The Maryland court has pointed out that juries in criminal cases are in reality not as unrestricted as the appellant suggests. The powers of the jury are hedged in a number of ways. Certain restraining powers lodged in the hands of the judges serve as a counterpoise. See Giles v. State, 229 Md. 370, 383-385, 183 A.2d 359, 365-366 (1962).

And it is doubtful whether in actuality juries vary in their application of legal principles more widely than judges vary among themselves. Traditionally, this constitutional provision has been understood as permitting the trial judge to determine the admissibility of evidence and the competency of witnesses, Rasin v. State, 153 Md. 431, 138 A. 338 (1927); Jules v. State, 85 Md. 305, 36 A. 1027 (1897), and in 1950 an amendment to section 5 of Article XV explicitly empowered the court to pass on the legal sufficiency of the evidence. Yanch v. State, 201 Md. 296, 93 A.2d 749 (1953). 2 If the jury’s view of the law has led them to a verdict of guilty and the court is of the opinion that the verdict is against the law, the trial judge may set the verdict aside and grant a new trial. An even more significant limitation is the acknowledged power of the court to take a case from the jury and direct a verdict of acquittal. In Chisley v. State, 202 Md. 87, 95 A.2d 577 (1953), decided the same year that our defendant was tried, the State argued that if there is any evidence of murder, there can be no determination by the trial court, as a matter of law, that the evidence was insufficient to prove first degree murder. The Court of Appeals, however, rejected this argument. It declared that the 1950 amendment to section 5, providing that “the Court may pass upon the sufficiency of the evidence to sustain a conviction,” not only gives the trial judge the power to direct an acquittal on the charge of murder, when there is no evidence of murder, but also empowers him to direct a verdict for the defendant even where there is some evidence of murder, but in the judge’s understanding of the law the evidence is insufficient to go to the jury on the question of first degree murder.

Although a trial judge was always permitted to give advisory instructions, 3 *745 prior to 1950, he could not be required to give them, and a refusal to do so upon request of counsel was held not erroneous. Slansky v. State, 192 Md. 94, 63 A.2d 599 (1949); Esterline v. State, 105 Md. 629, 66 A. 269 (1907); Bloomer v. State, 48 Md. 521 (1878); Broil v. State, 45 Md. 356 (1876); Wheeler v. State, 42 Md. 563 (1875). But Rule 756, section b, of the Maryland Rules of Procedure, originally promulgated in 1950, now provides that the court must give advisory instructions if requested to do so by counsel. 4 See Giles v. State, 229 Md. 370, 183 A.2d 359 (1962); Hardison v. State, 226 Md. 53,172 A.2d 407 (1961).

Oddly, it has always been held that while juries are the judges of the law, a jury may not pass on the constitutionality of a statute. Bell v. State, 57 Md. 108 (1881); Franklin v. State, 12 Md. 236 (1858).

Not only has the validity of Article XV, section 5 been repeatedly upheld by the state court, but the Supreme Court of the United States has had occasion to consider it, and failed to intimate any doubt of its constitutionality. In Giles v. Maryland, 372 U.S. 767, 83 S.Ct. 1102, 10 L.Ed.2d 137 (1963), the Court dismissed an appeal, which raised this issue along with others, for want of a substantial federal question. In Brady v. State of Maryland, 373 U.S. 83, 83 S.Ct. 1194, 10 L.Ed. 2d 215 (1963), in connection with a collateral matter, the Supreme Court again dealt with section 5.

Free access — add to your briefcase to read the full text and ask questions with AI

Related

State v. Adams
912 A.2d 16 (Court of Special Appeals of Maryland, 2006)
Gonzalez v. State
757 N.E.2d 202 (Indiana Court of Appeals, 2001)
State v. Hatori
990 P.2d 115 (Hawaii Intermediate Court of Appeals, 1999)
Jenkins v. Smith
43 F. Supp. 2d 556 (D. Maryland, 1999)
Fuquay v. State
583 N.E.2d 154 (Indiana Court of Appeals, 1991)
In Re Petition for Writ of Prohibition
539 A.2d 664 (Court of Appeals of Maryland, 1988)
Ennis v. State
510 A.2d 573 (Court of Appeals of Maryland, 1986)
United States v. Francis P. Desmond
670 F.2d 414 (Third Circuit, 1982)
Stevenson v. State
423 A.2d 558 (Court of Appeals of Maryland, 1980)
State v. Hunter
586 S.W.2d 345 (Supreme Court of Missouri, 1979)
Isaacs v. State
358 A.2d 273 (Court of Special Appeals of Maryland, 1976)
Jones v. State
348 A.2d 55 (Court of Special Appeals of Maryland, 1975)
Wilkins v. State of Maryland
402 F. Supp. 76 (D. Maryland, 1975)
Arshack v. United States
321 A.2d 845 (District of Columbia Court of Appeals, 1974)
State v. Willis
218 N.W.2d 921 (Supreme Court of Iowa, 1974)
Bremer v. State
307 A.2d 503 (Court of Special Appeals of Maryland, 1973)
Wilkins v. State
300 A.2d 411 (Court of Special Appeals of Maryland, 1973)
United States v. Dougherty
473 F.2d 1113 (D.C. Circuit, 1972)

Cite This Page — Counsel Stack

Bluebook (online)
372 F.2d 742, 1967 U.S. App. LEXIS 7828, Counsel Stack Legal Research, https://law.counselstack.com/opinion/rodger-wyley-3253-v-warden-maryland-penitentiary-ca4-1967.