Recent Developments: Sharp v. State: Despite Not Formally Objecting, Defense Counsel Properly Preserved the Issue of Whether the Circuit Court Inappropriately Weighed Defendant's Decision Not to Plead Guilty at Sentencing; The Circuit Court Did Not Impermissibly Consider Defendant's Rejection of the Plea Offer at Sentencing.

The Court of Appeals of Maryland held that defense counsel’s statements conveyed an objection to the circuit court’s perceived consideration of the defendant’s decision not to plead guilty at sentencing. Sharp v. State, 446 Md. 669, 113 A.3d 1089 (2016). As a result, the court held that defense counsel sufficiently preserved the issue for appellate review.

Id. at 684, 113 A.3d at 1098. Ultimately, though, the circuit court’s statements at sentencing did not give rise to the inference of an impermissible consideration. Id. at 701, 113 A.3d at 1108.