Background
Six Baltimore County defendants were found incompetent to stand trial and dangerous and remained at the Baltimore County Detention Center while awaiting placement in Department of Health facilities. The Department did not admit them within the 10-business-day deadline in Maryland Criminal Procedure § 3-106(c)(2)(i).
The District Court imposed daily reimbursement sanctions. On the Department’s de novo appeal, the Circuit Court for Baltimore County instead ordered nonmonetary sanctions: the Department could not use clinical-acuity screening surveys or require medical records to assess acuity, and it had to admit defendants in chronological order of their commitment orders.
The Court’s Holding
The Supreme Court granted the Department’s petitions, vacated the circuit court’s judgments, and remanded for reconsideration in light of Maryland Department of Health v. Boulden.
Under Boulden, a sanction under § 3-106(c)(4) must be designed to compel the Department to admit the particular defendant before the court as soon as possible after the statutory deadline. The circuit court’s systemwide restrictions and chronological-admission directive did not comply with that defendant-specific requirement. Neither the statute nor Boulden authorizes a court to direct the Department to forgo reliance on acuity or to prioritize acuity in a particular way.
Key Takeaways
- Sanctions for delayed competency placements must target compliance as to the individual defendant before the court.
- Courts may not use § 3-106(c)(4) to impose broad rules governing the Department’s use of clinical acuity.
- The cases return to the circuit court for reconsideration under Boulden.
Why It Matters
The order reinforces that statutory sanctions for missed placement deadlines are coercive, defendant-specific remedies rather than vehicles for restructuring the Department’s statewide admission practices. Trial courts assessing delayed IST placements must focus on whether available steps could have admitted the particular defendant sooner.