Miles v. State
Annotate this CaseAfter a jury trial in 1998, Appellant was convicted of murder and sentenced to death. In 2011, Appellant filed a second motion to correct an illegal sentence, claiming that his death sentence was unconstitutional and illegal under Article 16 of the Maryland Declaration of Rights, which provides that "sanguinary Laws ought to be avoided as far as is consistent with the safety of the State[.]" Appellant claimed that at the time the clause was adopted as Article 14 in 1776, a sanguinary law meant the death penalty for any crime, and therefore, Article 14 abrogated capital punishment for any offense that did not impact State security. The circuit court denied Appellant's motion. The Court of Appeals affirmed, holding (1) where death was the common law penalty for murder and the sanguinary laws clause applied only to legislative action, the death penalty was not abrogated by Article 14; and (2) if the sanguinary laws clause was retroactive, it was not intended to include death as a possible penalty for murder.
Some case metadata and case summaries were written with the help of AI, which can produce inaccuracies. You should read the full case before relying on it for legal research purposes.
This site is protected by reCAPTCHA and the Google Privacy Policy and Terms of Service apply.