WILLIAM LOUIS KRANZ v. STATE OF MARYLAND
Court of Appeals of Maryland, Barbera, June 21, 2018,
Post-Conviction – The limitation to file a post-conviction under the UPPA is determined at the time that it is filed, not the time that it is heard or appealed.

Facts:
In 2009, Kranz was charged with first-degree assault and related charges related to shooting two individuals who drove on his property in Cecil County.
Unbeknownst to Kranz, a Cecil County prosecutor (not the one handling his criminal case) was representing the victims in a civil suit against Kranz related to the incident.
Kranz was convicted of first-degree assault and sentenced to prison followed by probation.
Kranz eventually realized that the lawyer suing him was also a Cecil County prosecutor and filed a post-conviction, arguing that there was a discovery violation in not telling him before the trial.
Kranz’s post-conviction was denied, but his probation concluded on April 7, 2015.
Kranz appealed his post-conviction, arguing that he should be given a new trial.
In 2016, the Court of Special Appeals granted permission for him to appeal. However, the Court of Special Appeals then dismissed the post-conviction because he was no longer imprisoned or on parole/probation.
Kranz requested review by the Court of Appeals, arguing that he filed in time and so it shouldn’t matter that time ran out while his appeal was pending.

Held: The Court of Appeals agreed with Kranz and reversed the Court of Special Appeals, holding that as long as the post-conviction was filed on time it doesn’t matter that the defendant was eventually released.

Post-Conviction – A person convicted of a crime in a Maryland court may only file a post-conviction if he is imprisoned or on parole/probation