Stinchcomb v. State

Citations: 562 A.2d 781; 80 Md. App. 274; 1989 Md. App. LEXIS 161Docket: 1723, September Term, 1988

Court: Court of Special Appeals of Maryland; August 31, 1989; Maryland; State Appellate Court

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In William Stinchcomb v. State of Maryland, the Court of Special Appeals addressed whether a trial judge can mandate "voluntary" commitment to a state mental health facility as a condition of probation. Stinchcomb pled guilty to assault and battery, receiving a three-year sentence that was suspended in favor of five years of probation, which included a requirement to attend outpatient treatment at the Walter P. Carter Center. He later faced probation revocation due to new criminal charges and failure to attend treatment sessions. At the revocation hearing, testimony indicated that Stinchcomb posed a danger to himself and the public, having attempted suicide twice and violated probation conditions. Despite acknowledging Stinchcomb's need for treatment, the court expressed uncertainty about its authority to mandate inpatient treatment, noting that the existing system lacked a mechanism for such an order. Ultimately, the court found Stinchcomb in violation of his probation, revoked it, and reinstated the original sentence. The appeal raised the issue of whether the trial court erred by not allowing for a suspended sentence conditioned on inpatient treatment.

The court sentenced the appellant to three years under the jurisdiction of the Division of Corrections due to concerns over community safety. Discussions highlighted that probation was previously considered, particularly involving treatment at the Walter P. Carter Center, but the appellant was deemed dangerous and unlikely to comply. In Maryland, probation is granted as a matter of grace, contingent on the individual's conduct in relation to societal standards and safety. Upon violating probation, a judge may impose the original sentence or modify probation terms. The trial court has discretion in these matters, and its decisions can be reviewed for abuse of discretion or misinterpretation of probation conditions.

The appellant argued that the court improperly revoked his probation instead of mandating inpatient psychiatric treatment, which he was willing to undergo. The State contended that the court recognized its authority to require treatment but maintained that the appellant’s failure to engage satisfactorily in the program constituted a probation violation. The court's decision to revoke probation was deemed appropriate since it could not impose treatment as a condition equivalent to imprisonment. The case references established legal precedents, emphasizing the court’s discretion and the limitations on probation conditions.

The Court of Appeals determined that a trial court cannot impose imprisonment as a condition of probation, but residing in facilities like Second Genesis or the Carter Center does not equate to being "in custody" under Md. Ann. Code, art. 27, § 638C(a). The court clarified that while it cannot mandate commitment to the Carter Center, it can require voluntary commitment and participation in inpatient therapy as a probation condition. The record does not clarify if the trial court recognized its authority to impose such voluntary commitment. Consequently, the judgment was vacated, and the case was remanded for further proceedings regarding the appellant's punishment for probation violation. The remand does not address the violation itself, which is undisputed, but focuses on the potential modification of probation terms, allowing for the possibility of voluntary commitment or serving the remainder of the sentence in correctional facilities. Costs are to be borne by the Mayor and City Council of Baltimore.