Bhalla v. State

1 Citing case

  1. Perez v. State

    155 Md. App. 1 (Md. Ct. Spec. App. 2004)   Cited 11 times
    In Perez v. State, 155 Md.App. 1, 841 A.2d 372 (2004), Perez was convicted of two counts of felony murder and related charges.

    quently upheld a hearing court's determination of voluntariness, even with lengthy delays in presentment, based on a consideration of the totality of the circumstances. See Whittington v. State, 147 Md. App. 496, 519, 526, 809 A.2d 721 (2002), cert. denied, 373 Md. 408, 818 A.2d 1107 (2003) (18 hours between arrest and statement and 28 hours between arrest and presentment before commissioner); Hamwright v. State, 142 Md. App. 17, 41, 787 A.2d 824 (2001), cert. denied, 369 Md. 180, 798 A.2d 552 (2002) (11 hours between arrest and statement); Bey v. State, 140 Md. App. 607, 614-622, 781 A.2d 952 (2001), cert. denied, 368 Md. 526, 796 A.2d 695 (2002) (1 to 4 hours between arrest and statement and 21 hours between arrest and presentment before commissioner); Marr v. State, 134 Md. App. 152, 165-66, 759 A.2d 327 (2000), cert. denied, 362 Md. 623, 766 A.2d 147 (2001) (35 hours between arrest and statement and approximately the same time between arrest and presentment before a commissioner); Bhalla v. State, 2000 Md. App. Lexis 168, *68-*72 (2000) (4 hours between arrest and statement and 9 hours between arrest and presentment before a commissioner). In all of these cases, the length of the delay was considered merely as one factor, with the ultimate issue being voluntariness.