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Criminal procedure — Motion to suppress evidence — Vehicle search

By indictment filed on October 8, 2014, in the Circuit Court for Howard County (“circuit court”), the State of Maryland charged appellant, Ricardo O’Neil Brooks, with armed robbery. On or about October 17, 2014, Brooks filed several motions, including a motion to suppress any evidence taken “as the result of an illegal search and seizure.” Following a motions hearing on February 26, 2015, the circuit court denied Brooks’s request. A jury trial was held from January 6-8, 2016, after which Brooks was found guilty. Immediately after the trial, the circuit court sentenced Brooks to ten years’ incarceration.

On January 15, 2016, Brooks timely appealed, presenting two issues for our review: 1. Did the circuit court err in denying the motion to suppress the evidence found by Howard County police in [Brooks]’s vehicle? 2. Did the [circuit court] err in believing that a ruling by the Circuit Court for Montgomery County procedurally barred it from considering the defense’s motion to suppress [Brooks]’s cell phone and evidence derived from it?

Read the opinion here: