Defending Your Rights Through Criminal Appeals & Post-Conviction Relief

Free Consultations

Proudly serving clients throughout Maryland

Questions? Call us at:
(443) 863-8428

We’re By Your Side When You Need Help With:

Strategic representation for criminal appeals and post-conviction cases designed to protect your future and pursue every available legal option.

About Our Firm

We are dedicated to helping individuals navigate the complexities of criminal appeals and post-conviction matters with clarity, honesty, and care. Drawing on experience across multiple sides of the legal system, our team understands how these cases are evaluated and works to guide clients through what can often feel like an overwhelming process.

Every case begins with a thoughtful and thorough review. Clients receive straightforward feedback about their options and realistic expectations about next steps. When viable legal claims exist, the firm approaches advocacy with focus and determination, working diligently to pursue fair outcomes and protect clients’ rights.

Above all, our firm prioritizes communication, respect, and trust, ensuring that each client feels informed, supported, and confident in the representation they receive.

Andy Cryan, Esq.

I’ve handled all varieties of post-conviction cases and criminal appeals for nearly a decade. I spent over 4 years in private practice obtaining new trials and sentencing modifications for my clients in multiple counties throughout Maryland while winning cases before both the Appellate Court of Maryland and the Supreme Court of Maryland. I was a Post-Conviction Litigation Unit Prosecutor in Baltimore City for 1.5 years. I also clerked for the Honorable Melissa Phinn in the Circuit Court for Baltimore City and worked in both the Circuit Court for Howard County and the Circuit Court for Anne Arundel County. I understand how the defense, prosecution, and most importantly, the court approaches post-conviction case sand criminal appeals. I thoroughly review my clients' cases to determine whether they have any meritorious claims. If they can’t, I tell them straight. When they do, I fight to bring them justice.

© Copyright 2026. The information on this website is for general information purposes only. Nothing on this site should be taken as legal advice for any individual case or situation. This information is not intended to create, and receipt or viewing does not constitute, an attorney-client relationship.  443-781-6313

Do I Have a Case?

• Not moving to dismiss a specific charge(s) on the indictment. 
• Not attempting to exclude evidence before your trial begins. 
• Not requesting a necessary question for the trial court to ask the pool of potential jurors to prevent you from being tried by a biased juror(s). 
• Not objecting to an improperly selected juror(s). 
• Not objecting to juror misconduct, including inattentiveness or sleeping during trial. 
• Sleeping during a substantial part of your trial (yes, that has happened. See e.g., United States v. Ragin, 820 F. 609 (4th Cir. 2016) (as a matter of first impression, the defendant's right to counsel was violated when his counsel was asleep during a substantial portion of the trial, and, prejudice was presumed). 
• Not requesting a mistrial after evidence presented by the prosecution is so unfairly prejudicial that such prejudice cannot be cured (the bell cannot be unrung). 
• Not presenting a witness(s) to testify in your defense when there is a “substantial possibility” – see below for more on this term – would  have prevented the State from meeting its burden of “proof beyond a reasonable doubt.” 
• Not presenting evidence during your trial when there is a “substantial possibility” – see below for more on this term – that doing so would have prevented the State from meeting its burden of “proof beyond a reasonable doubt.” 
• Not objecting to inadmissible evidence during your trial. 
• Not requesting a necessary jury instruction(s) or not objecting to an improper jury instruction(s). 
• Not objecting to the miscalculation of your sentence. 
• Disregarding your request to file any of the following: 
• Motion for a new trial within 10 days of your verdict. 
• Motion for modification of sentence within 90 days of your sentencing hearing. 
• An application for a three-judge panel review of your sentence within 30 days of your sentencing hearing. 
• A notice of appeal within 30 days of your sentencing hearing. 
• Not consulting you about any of those filings. 
• Your (appellate) attorney failing to present your best argument on appeal. 
• Your (post-conviction) attorney failing to present your best argument on post-conviction (yes, you can post-convict your post-conviction attorney. For more information on this, please see the “motion to reopen post-conviction proceedings page”).
  

You may be entitled to relief from your attorney(s) mistake(s), including, but not limited to your attorney:

The specific relief that you may be entitled to from these mistake(s) include:

• A new trial. 
• A new appeal. 
• Having your guilty plea vacated. 
• The right to file a belated motion for modification of sentence. 
• The right to file a belated application for a three-judge panel sentencing review. 
• The right to file a belated motion for a new trial. 
• Having your sentence for one or more charges removed. 
• Having your sentence for one or more charges modified. 
• Being re-sentenced on one or more charges.

Obtaining this relief requires proving both:

1. Deficient performance, meaning that no reasonable competent attorney in the position of you attorney would have made the same mistake(s). Stated alternatively, the mistake violates prevailing professional norms. The mistake(s) must be considered in the context of all actions taken by your attorney. You cannot simply cherry-pick one or two mistakes and have a meritorious claim of deficient performance. You must also show that your attorney’s action or inaction was not part of a reasonable trial strategy. For example, you have to show that your attorney’s decision to present a particular defense, theory, or argument over another was unreasonable. 
   
   
2. Prejudice, meaning that the mistake(s) your attorney made are so severe that they prevented you from receiving a fair trial or guilty plea hearing. This generally requires considering every piece of evidence admitted against you at trial or, if you pled guilty, presented to the court in the statement of facts. The only exception is when prejudice is presumed, which occurs when there is a/n: 
   
   
3. "Actual" / "complete" denial of counsel during a "critical stage" of the criminal proceedings. Common examples are your attorney: not being in the courtroom, being prevented from communicating with you or being otherwise prevented from assisting you in your defense. 
   
   
4. Constructive denial of counsel. This occurs when your attorney IS present (at least physically) and not denied from assisting you during a "critical stage" of the criminal proceedings, but the circumstances of her or his in/action(s) still amount to the denial of the assistance of counsel. Examples are: failing to subject the State's case (or, if you're in federal court, the Government's case) to "meaningful adversarial testing", expressly telling or strongly inferring to the jury or judge that you are guilty, sleeping during your trial, and failing to challenge ANY of the evidence presented by the State or Government throughout ALL of trial and/or sentencing, not simply neglecting to challenge it at specific points during the trial or sentencing. 
   
   
5. Conflict of interest. For example, your attorney is representing both you and your co-defendant in a joint trial where you are both charged with committing the same crime and the defense that your attorney makes for your co-defendant could harm your case or vice-versa.

Additional procedural requirements for a successful post-conviction petition:

1. The petition must be filed within 10 years from the date of your sentencing hearing unless there is “extraordinary cause” for not meeting that deadline. Md Code, Criminal Procedure § 7-103. Extraordinary cause is normally limited to the petitioner’s post-conviction counsel (public defender or private counsel) not filing a timely petition. 
   
   
2. It must be your first petition. As of October 1st, 1995, petitioners are only permitted to file ONE post-conviction petition. Thus, you must present all meritorious arguments in one petition or they will be waived.

Clark v. State

Damien Gary Clark v. State of Maryland -- 485 Md. 674 (2023)
Supreme Court of Maryland

Experience You Can Rely On
Clients seeking post-conviction or appellate relief benefit from representation familiar with the complexity and stakes of higher-court litigation, where careful analysis and strategic advocacy are essential.