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JODY LEE MILES v. STATE OF MARYLAND

In this appeal, we are asked to determine whether Maryland’s repeal of the death penalty, 2013 Md. Laws ch. 156 (“Repeal Act”), which became effective on October 1, 2013, retroactively applies to appellant, Jody Lee Miles, who was sentenced to death before the Repeal Act took effect, thus rendering his sentence illegal.  The State contends that Miles’s sentence is not illegal but concedes that “[t]he uncertain enforceability of Miles’s sentence gives rise to a due process claim, which in turn mandates that his death sentence should be vacated.” Thus, the State urges us to remand this matter to the Circuit Court for Queen Anne’s County with instructions to resentence Miles to life imprisonment without the possibility of parole (“LWOP”).

On December 31, 2014, following oral argument in this case, but prior to the issuance of an opinion by this Court, the Governor of Maryland stated his intent to replace Miles’s death sentence with a sentence of LWOP. On January 20, 2015, the Governor formally commuted the sentences of Maryland’s four remaining death row inmates to LWOP.  Accordingly, we hereby dismiss this appeal as moot.

Read the unreported opinion.