Wynn v. State, 388 Md. 423

Summary

The Maryland Court of Appeals held that a trial court lacks inherent authority to dismiss a criminal indictment with prejudice solely because the State violated a post-mistrial scheduling order. The court emphasized the separation of powers and the State's discretion to retry charges after a mistrial caused by a deadlocked jury, distinguishing situations governed by the constitutional speedy-trial guarantee or Maryland's Hicks rule.

Holdings

1. A trial court does not have the authority to dismiss a criminal indictment or other charging document merely because the State violated a scheduling order.
2. The State retained discretion to retry Wynn on the charges on which the jury deadlocked, and retrial was not barred under the circumstances described in the opinion.
3. Dismissal was not supported by the Hicks rule or the constitutional speedy-trial guarantee because Wynn did not contend that either requirement had been violated.

Questions Presented

1. Whether a trial court has inherent authority to dismiss a criminal indictment or other charging document solely because the State violated a post-mistrial scheduling order.
2. Whether the State retained discretion to retry charges on which the jury deadlocked after a mistrial.
3. Whether dismissal would be justified under the constitutional speedy-trial guarantee or Maryland's 180-day Hicks rule.

Disposition

affirmed