MD Supreme Court affirms denial of sentence reduction in 1982 murder case

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A circuit court has broad discretion to determine whether an individual seeking a sentence reduction is a danger to the public and whether the interests of justice will be served by a reduced sentence, the Maryland Supreme Court held Thursday in affirming the denial of a Maryland man’s motion for sentence reduction under the state’s Juvenile Restoration Act.

In an opinion written by Justice Angela Eaves, the Maryland Supreme Court held the Baltimore County Circuit Court adequately considered each factor under § 8-110 of the Maryland Criminal Procedure Code in denying James Russell Trimble’s motion for sentence reduction in light of state legislators’ passage in 2021 of JUVRA, which allows individuals who committed offenses before turning 18 years old to file a motion for a sentence reduction after serving 20 years of their sentence.

According to court documents, a jury for the Baltimore County Circuit Court convicted Trimble in 1982 of first-degree murder, first-degree rape, kidnapping and sexual assault, from which a judge sentenced him to death. Trimble was later resentenced to a consecutive life sentence that was upheld on appeal.

At the time of the offenses, Trimble was 17 years and 8 months old. At trial, he offered an insanity defense. State prosecutors called a doctor and expert in forensic psychology to testify about Trimble’s antisocial personality disorder diagnosis.

On appeal on his motion for sentence reduction, Trimble argued the circuit court misapplied § 8-110(d)(1) when it found his age at the time of the offense weighed against granting his motion, misapplied § 8-110(d)(5) by not attributing sufficient weight to his rehabilitation evidence, and misunderstood and gave undue weight to his antisocial personality disorder diagnosis.

The high court disagreed, finding the General Assembly intended an individual’s age to be a factor in weighing sentence reduction, but not a factor required to always weigh in favor of a sentence reduction, and finding a circuit court is not required to give greater weight to any one factor.

“So long as the circuit court adhered to CP § 8-110’s requirements, it had the discretion to credit all, part, or none of the evidence regardless of the source and to assess the evidence as it saw fit,” Eaves wrote. “Reading the court’s written decision in its entirety demonstrates that the court adhered to those requirements.”

A spokesperson for the Maryland Office of the Attorney General declined to comment, and a spokesperson for the Maryland Office of the Public Defender did not immediately respond.

A number of advocacy groups submitted an amicus brief in support of Trimble, including the American Civil Liberties Union of Maryland and the Public Justice Center, arguing “Maryland would fall behind the national shift toward justice reform” if it were to not treat Trimble’s age at the time of the offenses as a mitigating factor.

“Research in developmental psychology and neuroscience consistently shows that the human brain does not fully mature until the mid-twenties, particularly in areas governing impulsivity, susceptibility to peer influence, and the capacity for rehabilitation,” amici wrote. “By treating a minor’s age as an aggravating factor, the court would disregard well-established neuroscience — a factor the U.S. Supreme Court has instructed should be considered — while also failing to align with JUVRA’s legislative purpose, including the explicit requirement to consider the diminished culpability of a youth as compared to an adult.”

In a concurring opinion authored by Chief Justice Matthew Fader that Justice Brynja Booth joined, Fader wrote that a better interpretation of § 8-110 is that the factor of an individual’s age at the time of the offense “can either weigh in favor of a reduction in sentence to varying degrees or it can be neutral.” Fader cited developments in psychology and brain science showing juveniles have diminished culpability at the time of their criminal conduct and are more capable of rehabilitation.

In another concurring opinion, Justice Peter Killough wrote the circuit court improperly introduced an article on antisocial personality disorder into the record and cited the article when neither party in fact cited the article. Killough also wrote that the circuit judge’s writing in its decision (“This is a case where the sentence should never be disturbed”) “is problematic” because any future JUVRA petition filed by Trimble is not that judge’s decision to make, where legislators designed the process to be revisited over time.

The high court’s ruling is expected to impact sentence reduction motions and cases filed under the Maryland Second Look Act, which passed by legislators earlier this year and permits people to file for a sentence reduction if they were convicted between the ages of 18 and under 25, and have served at least 20 years of the term of confinement. The law excludes those convicted of killing a first responder in the line of duty from filing for a sentence reduction under the act.