David Triggs, Jr. v. State of Maryland

David Triggs (defendant) physically, sexually, and verbally abused Pamela Triggs throughout their seven-and-a-half-year marriage. Prior to the Triggses’ divorce, Pamela obtained a protective order against David, which prohibited David from contacting her. David was arrested and charged by the state of Maryland (plaintiff) for violating the order. While he was in jail waiting for his trial, he sent threatening letters to the Triggses’ three children. David was convicted for violating the order. David was sentenced to a brief time in jail and then probation. While on probation, David continued to have visitation with the children. Beginning on September 16, 2001, while the children were staying with David, David began obsessively calling Pamela. David left messages on Pamela’s phone threatening to kill the children. David was arrested again for violating the protective order. The state charged David with multiple offenses, including multiple counts of harassment and telephone threats and 18 counts of violating the protective order. David was convicted and sentenced to imprisonment for each harassment, telephone-threat, and protective-order-violation conviction. In total, David’s sentence was more than 26 years’ imprisonment. David appealed the sentence. The Maryland Court of Special Appeals found that the rule of lenity required that the harassment and telephone-threat sentences be merged with each other because the convictions were based on the same conduct. However, the court affirmed the 18 separate sentences for the 18 different protective-order violations. David appealed the decision regarding the protective-order violations. The Maryland Supreme Court granted certiorari to consider whether David could be sentenced to 18 consecutive one-year sentences for the 18 protective-order violations of which he was convicted.