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Recent Development: Colvin V. State: Not Polling The Jury Foreperson Individually After Announcing The Jury's Verdict Is A Procedural Error, Which Does Not Rise To The Level Of A Cognizable Claim Under Maryland Rule 4-345(A), Kayla M. Dinuccio
University of Baltimore Law Forum
The Court of Appeals of Maryland held that a motion to correct an illegal sentence can only be granted if the error is based on substantive law. Colvin v. State, 450 Md. 718, 728, 150 A.3d 850, 856 (2016). Not polling the jury foreperson after she announced the jury's verdicts was a procedural error, and thus not one of the limited exceptions to correct an illegal sentence under Maryland Rule 4-345(a). Id. at 726-27, 150 A.3d at 855-56. In 1989, Roderick Colvin ("Colvin") was tried before a jury in the Circuit Court for Baltimore City on numerous charges, including murder …