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Criminal procedure — Writ of Actual Innocence — Need for a hearing

Following a 2010 bench trial in the Circuit Court for Baltimore City, James Wesley Spriggs, appellant, was convicted of first-degree murder and handgun offenses and thereafter sentenced to life imprisonment. This Court affirmed the judgments. Spriggs v. State, No. 2254, September Term, 2010 (filed February 28, 2012). In 2016, Spriggs filed a petition for writ of actual innocence pursuant to the provisions of Maryland Code (2008 Repl. Vol., 2015 Supp.), Criminal Procedure Article (“C.P.”), § 8-301 and Maryland Rule 4-332. The circuit court found that the “newly discovered evidence” upon which Spriggs based his petition was not, in fact, “newly discovered” and consequently dismissed the petition without a hearing. Spriggs’s sole contention on appeal is that the circuit court erred by dismissing his petition without a hearing.

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