Justia Maryland Supreme Court Opinion Summaries

The case concerns an automobile accident in Prince George’s County, Maryland, involving George Bowens and a driver named Lisa Daniels, who was at fault. Bowens sustained injuries and held a $50,000 underinsured motorist (UIM) policy with State Farm. Daniels’ insurance had a $30,000 liability limit, which was offered to Bowens as a settlement for his injuries. Following established statutory procedures, Bowens notified State Farm of this offer, State Farm consented and waived subrogation rights, and Bowens accepted the $30,000. Bowens then sought to recover the remaining $20,000 available under his UIM policy from State Farm, which denied the claim.Bowens filed a breach of contract action in the District Court for Prince George’s County, seeking $20,000. State Farm moved to dismiss, arguing that the District Court lacked subject matter jurisdiction because Bowens would have to prove total damages of $50,000—exceeding the court’s $30,000 jurisdictional cap. The District Court agreed and dismissed the case. Bowens appealed to the Circuit Court for Prince George’s County, which affirmed the dismissal, reasoning that the District Court would need to find damages over $30,000 and thus could not grant relief.The Supreme Court of Maryland reviewed the case and held that the District Court’s jurisdiction is determined by the amount the plaintiff seeks from the defendant in the pending action, not by the total underlying damages or prior settlements received from the tortfeasor’s insurer. Since Bowens’ claim against State Farm was for $20,000, the District Court had jurisdiction. The Supreme Court of Maryland reversed the judgment of the circuit court and ordered the case remanded to the District Court for further proceedings. View "Bowens v. State Farm Mut. Auto. Ins." on Justia Law

A jury found the defendant guilty of second-degree assault. At the sentencing hearing, the trial judge initially announced a sentence of one year, suspending all but nine months to be served on home detention, followed by three years of supervised probation. While the judge was advising the defendant of his post-trial rights, the prosecutor questioned whether the sentence properly reflected the intended punishment and raised concerns about the remaining active time if probation was violated. After a brief colloquy and clarification, the judge revised the sentence, increasing it to five years, suspending all but nine months on home detention, and three years of supervised probation.The defendant appealed to the Appellate Court of Maryland, arguing that the trial judge had illegally increased the sentence after it had been imposed, in violation of Maryland Rule 4-345, which restricts modifications to sentences once they are imposed. The Appellate Court rejected this argument, holding that the sentence was not illegally increased because the revision occurred before the sentencing proceeding concluded, and Rule 4-345 was therefore not triggered.On further appeal, the Supreme Court of Maryland affirmed the decision of the Appellate Court. The Supreme Court held that under Maryland law, a sentence is not considered “imposed” under Rule 4-345 until the sentencing proceeding ends. Thus, a trial court retains authority to modify or increase a sentence during an ongoing sentencing hearing. Since the revision to the defendant’s sentence occurred before the conclusion of the sentencing proceeding—while the defendant was still present and the case was not over—Rule 4-345 did not apply, and the increase did not violate double jeopardy protections. The judgment of the Circuit Court for Prince George’s County was affirmed. View "Reyes v. State" on Justia Law

A consumer purchased a used vehicle from a dealership, with the transaction documented in two contracts: a purchase order and a retail installment sale contract (RISC). The purchase order included an arbitration provision for disputes arising from the purchase or financing of the vehicle, while the RISC detailed the financing terms but did not include an arbitration clause. The RISC contained an assignment clause by which the dealership assigned its interest in "this contract" (the RISC) to a third-party lender, and defined the agreement between the buyer and the assignee as consisting "only" of the RISC and any addenda. The consumer later filed a class action against the lender, alleging improper fees under Maryland law.The Circuit Court for Baltimore City found for the lender, ruling that the purchase order and RISC should be read together as one contract for the purposes of the transaction, and that the arbitration agreement was enforceable against the consumer. The court granted the lender’s motion to compel arbitration. On appeal, the Appellate Court of Maryland affirmed, holding that the consumer was bound by the arbitration provision and that the assignee lender could enforce it, even though the consumer did not receive or sign a separate arbitration agreement.The Supreme Court of Maryland reviewed the case, focusing on contract interpretation and the scope of the assignment. The court held that, even if the purchase order’s arbitration provision was binding between the consumer and the dealer, it was not within the scope of the assignment to the lender. The RISC’s assignment language made clear that only the RISC and its addenda, not the purchase order or its arbitration clause, were assigned to the lender. As a result, the Supreme Court of Maryland reversed the judgment of the Appellate Court and remanded the case for further proceedings. View "Lyles v. Santander Consumer USA" on Justia Law

A defendant was found guilty by a jury of second-degree assault. At the sentencing hearing, the trial judge initially announced a sentence of one year, suspending all but nine months to be served on home detention, followed by three years of supervised probation. While the judge was advising the defendant of his post-trial rights, the prosecutor sought clarification about the sentence, noting that the initial announcement did not leave sufficient “backup” time for a probation violation. After a brief colloquy, the judge, realizing a misunderstanding regarding the sentencing guidelines, revised the sentence to five years, suspending all but nine months on home detention, and three years of supervised probation. The defendant remained in the courtroom, and the sentencing proceeding had not ended when the change was made.The defendant appealed to the Appellate Court of Maryland, arguing that the trial court had illegally increased his sentence after it was imposed, in violation of Maryland Rule 4-345, which restricts a court’s ability to modify a sentence once it has been imposed. The Appellate Court determined that the sentence was not illegally increased because the sentencing proceeding had not concluded when the change occurred, and thus, Rule 4-345 did not yet apply.The Supreme Court of Maryland reviewed the case to decide when a sentence is considered “imposed” under Maryland Rule 4-345 and whether the trial court’s increase was illegal. The Court held that a sentence is not imposed until the sentencing proceeding ends, which generally occurs when the judge signals the conclusion of the case, such as by remanding the defendant or calling the next case. Therefore, because the sentence was changed before the proceeding ended, the trial court retained authority to revise it, and Rule 4-345 was not triggered. The Supreme Court of Maryland affirmed the trial court’s judgment. View "Reyes v. State" on Justia Law

After a car accident in Prince George’s County, Maryland, George Bowens, who was injured by the clear negligence of another driver, sought to recover compensation for his injuries. The at-fault driver had $30,000 in liability insurance, which was offered to Bowens in settlement. Bowens, however, had a $50,000 underinsured motorist (UIM) policy with his own insurer, State Farm. After accepting the $30,000 from the at-fault driver’s insurer (with State Farm’s consent and waiver of subrogation rights), Bowens sought the remaining $20,000 from State Farm under his UIM policy, claiming breach of contract when State Farm denied the claim.Bowens filed his action in the District Court of Maryland, which has jurisdiction over contract claims not exceeding $30,000. State Farm moved to dismiss, arguing that to recover the $20,000, Bowens would have to prove total damages of $50,000—an amount above the District Court’s jurisdictional cap. The District Court granted the motion to dismiss for lack of subject matter jurisdiction, and the Circuit Court for Prince George’s County affirmed, reasoning that the court would need to find Bowens’ damages exceeded $30,000, thus exceeding the District Court's authority.The Supreme Court of Maryland reviewed the case and reversed the lower courts. It held that, for purposes of determining the District Court’s jurisdiction under § 4-401(1) of the Courts and Judicial Proceedings Article, the relevant amount is the “debt or damages claimed” in the pleadings—that is, the net recovery sought from the defendant in the action—not the plaintiff’s total damages. Because Bowens sought only $20,000 from State Farm, the District Court had jurisdiction to hear the case. The Supreme Court of Maryland remanded the case for further proceedings consistent with this opinion. View "Bowens v. State Farm Mutual Automobile Insurance Co." on Justia Law

After the divorce of two parents, the mother filed a petition in the Circuit Court for Anne Arundel County seeking protection from child abuse on behalf of their minor children. She alleged threats of violence and mental injury, but did not check boxes for physical abuse nor provide detailed factual allegations in the petition. At an ex parte hearing, she testified about incidents where the father allegedly struck one child and threatened violence, which led the circuit court to grant a temporary protective order. The court referred the matter to the Department of Social Services for investigation and scheduled the final protective order hearing beyond the statutory seven-day period to accommodate the investigation. At the final hearing, both parties appeared, and the court ultimately granted a final protective order, awarding custody to the mother and imposing supervised visitation and other conditions on the father.On appeal, the Appellate Court of Maryland affirmed the circuit court’s grant of the final protective order. It held that the extension of the temporary order for investigative purposes was justified, that the father had received adequate notice of the allegations via the temporary order itself, and that there was sufficient evidence to support the circuit court’s finding of abuse. The appellate court relied primarily on the circuit court’s negative credibility determination of the father’s testimony to uphold the order.The Supreme Court of Maryland reviewed the case. It held that the father did not preserve for appellate review the issue of whether the circuit court erred by not stating on the record whether good cause existed for scheduling the hearing beyond seven days. The court also held that service of a temporary protective order generally satisfies procedural due process requirements; the father’s argument that service of the petition was required was rejected. However, the Supreme Court found the Appellate Court erred in affirming the sufficiency of the evidence solely based on the circuit court’s disbelief of the father’s testimony. That part of the appellate decision was vacated and remanded for further proceedings. View "Clarke v. Gibson" on Justia Law

Tenants of two units in a multi-family residential building filed rent escrow complaints in the District Court of Maryland in Prince George’s County, alleging hazardous conditions such as infestations, water damage, and fire risks. The property lacked a valid rental license due to housing code violations. The tenants sought repairs and a return of rent paid during the unlicensed period, arguing that, under Assanah-Carroll v. Law Offices of Edward J. Maher, P.C., they owed no rent while the property was unlicensed and should not have to pay rent into escrow.The District Court ordered the tenants to pay rent into escrow starting September 2023, and dismissed their complaints when they declined to do so. The tenants appealed to the Circuit Court for Prince George’s County. By the time of the appeal, one tenant had vacated, and the landlord had obtained the necessary license and disclaimed any intent to collect rent from the unlicensed period. The circuit court heard the appeal de novo and dismissed it as moot, noting that the landlord was not seeking rent for the unlicensed period.On further review, the Supreme Court of Maryland concluded that no live controversy remained. The tenants no longer had possession of the units, and the landlord had renounced claims for rent during the unlicensed period. The court rejected arguments that collateral consequences or exceptions to the mootness doctrine applied, finding no judgments of possession or damages had been entered and recent legislative changes had altered the statutory framework. Accordingly, the Supreme Court of Maryland dismissed the appeal as moot. View "Wilson v. Tanglewood Venture" on Justia Law

The case involved a defendant who was charged with attempted first-degree murder and related offenses in the Circuit Court for Montgomery County, Maryland. Before trial, both the defense and prosecution jointly requested a postponement of the trial date due to the resignation of the defendant’s public defender and the need for additional preparation time. During a status hearing, the defendant’s newly assigned counsel informed the court that the defendant wanted to represent himself and keep the original trial date. The matter was referred to the administrative judge, who questioned the defendant about his wishes. The defendant responded that he wanted an attorney but did not want the trial postponed, emphasizing his desire for a speedy trial and expressing frustration about his continued incarceration.After this exchange, the administrative judge postponed the trial date, and the defendant did not further request to discharge counsel or to represent himself. At trial, the defendant was represented by counsel and was convicted by a jury of attempted second-degree murder, armed robbery, and use of a firearm in the commission of a felony or crime of violence. The Appellate Court of Maryland affirmed the conviction, finding that the defendant had not expressed a present intent to discharge counsel or to represent himself, and that the trial court had provided an adequate opportunity for the defendant to clarify his wishes.The Supreme Court of Maryland reviewed whether the trial court violated the defendant’s constitutional and procedural rights by not conducting further inquiry into his alleged request for self-representation. The Supreme Court held that when a court is informed that a defendant may wish to represent himself, it must conduct a reasonable inquiry to determine if the defendant clearly and unequivocally asserts that right and must allow the defendant to explain his reasons for discharging counsel under Maryland Rule 4-215(e). However, if the defendant does not express a clear desire for self-representation or to discharge counsel, the court is not required to question him further. The Supreme Court affirmed the lower court’s judgment. View "Goodrich v. State" on Justia Law

A woman who receives a housing voucher due to her disability applied to rent an apartment in a complex owned by a property management company. The monthly rent for the unit was $1,590, and her voucher would have covered $1,464, leaving her responsible for $126 per month. Her only other income was $841 per month in supplemental security income. The property owner applied its standard policy, requiring all applicants to demonstrate monthly income at least 2.5 times the full rent, aggregating all sources of income, including voucher subsidies. The applicant’s combined income and voucher fell short of the $3,975 threshold, so her application was denied.After the Maryland Commission on Civil Rights found no probable cause for her discrimination claim, the applicant sued in the Circuit Court for Baltimore County, alleging that the owner’s minimum-income requirement constituted impermissible source-of-income discrimination under Maryland’s Housing Opportunities Made Equal (HOME) Act, which prohibits discrimination based on “source of income” in housing. The owner moved for summary judgment, arguing its policy was facially neutral and applied equally to all sources of income. The circuit court granted summary judgment to the owner, finding that the policy did not discriminate based on the source of income, only the amount.On appeal, the Supreme Court of Maryland reviewed the case. The Court agreed with the circuit court that the owner was entitled to summary judgment on the disparate treatment claim, as the policy was facially neutral and applied equally. However, the Supreme Court of Maryland held that the owner was not entitled to summary judgment on the disparate impact claim. The Court explained that a facially neutral policy may still violate the HOME Act if it disproportionately affects voucher holders without a legitimate business justification. The judgment of the circuit court was vacated and the case remanded for further proceedings. View "Hare v. David S. Brown Enterprises" on Justia Law

Erica Hall and Nicholas Houser married in 2012 and have one minor child, C.H., born in 2018. In 2020, both parties sought an absolute divorce. On the trial day, they presented agreements to the Circuit Court for Anne Arundel County, including one to waive child support and arrears. The court requested justification for this waiver, but the parties only argued their fitness as parents and their constitutional rights. The court found the waiver in the parents' best interest, not the child's, and ordered Mr. Houser to pay child support and arrears to Ms. Hall, who had primary custody of C.H.The Appellate Court of Maryland affirmed the circuit court's decision, rejecting the parents' agreement regarding child support and upholding the child support and arrears order. Both parties then petitioned the Supreme Court of Maryland.The Supreme Court of Maryland held that parents cannot waive the issue of child support because it is a legal obligation, and the right to receive support belongs to the child, not the parents. The court also held that a parent's fundamental right to determine the care, custody, and control of their children does not include waiving child support, as it is a parental obligation. The court found that the trial court did not abuse its discretion in rejecting the parents' agreement to waive child support, as the parties failed to provide sufficient justification for the waiver. The Supreme Court of Maryland affirmed the judgment of the Appellate Court, maintaining the child support and arrears order. View "In re: Marriage of Houser" on Justia Law