Justia Maryland Supreme Court Opinion Summaries

A man was charged with drug offenses after his car was stopped by police officers in Hagerstown, Maryland. The officers initiated the stop after observing the driver manipulating or pressing the screen of a cell phone mounted to the vehicle’s windshield while the car was in motion. The officers did not provide further details about the driver’s conduct beyond noting these interactions with the phone. The driver was not charged with a mobile phone or texting violation, but he moved to suppress evidence obtained as a result of the stop, arguing that the stop itself was unlawful.The Circuit Court for Washington County denied the suppression motion, holding that simply seeing someone manipulate a phone while driving constituted reasonable articulable suspicion of a mobile phone violation, since the conduct could easily be texting. After a jury trial, the defendant was convicted of fentanyl possession and related charges. On appeal, the Appellate Court of Maryland reversed, finding that the officers’ observations were of innocuous conduct and did not provide reasonable suspicion of illegal activity under Maryland’s statutes governing mobile phone use while driving.The Supreme Court of Maryland reviewed the case and affirmed the Appellate Court’s decision. The Court held that when an officer observes conduct consistent with both lawful and unlawful mobile phone use, the Fourth Amendment requires the officer to identify specific, articulable facts which, together with rational inferences, reasonably indicate a violation of the relevant statutes. Merely seeing a driver manipulate, touch, or press a phone screen, without more, is insufficient to justify a traffic stop. The Court thus concluded that the stop was not supported by reasonable suspicion and that the evidence should have been suppressed. View "State v. Stone" on Justia Law

In this case, an individual was charged and later convicted of multiple sexual offenses and assault after allegations involving his then-girlfriend’s eight-year-old granddaughter. The key evidence included a sexual assault forensic examination (SAFE) kit, from which DNA samples were collected. At trial, questions arose about the chain of custody for the kit, particularly because a perianal swab was included in the kit despite the nurse testifying she did not recall collecting it. The defense argued this discrepancy undermined the reliability and authenticity of the evidence, seeking to exclude the entire DNA report or, alternatively, to redact references to the disputed swab. The court admitted a redacted version of the report, and the jury found the defendant guilty on most counts.Following his conviction and unsuccessful direct appeal—where the Appellate Court of Maryland held that he had not preserved his chain of custody objection for appellate review—the defendant filed a motion in the Circuit Court for Howard County for a new trial under Maryland’s postconviction DNA testing statute, Criminal Procedure Article § 8-201. He contended that the DNA evidence was unreliable due to the alleged chain of custody defects. The circuit court denied the motion without a hearing. The defendant appealed, and the Appellate Court of Maryland transferred the appeal to the Supreme Court of Maryland.The Supreme Court of Maryland held that the defendant’s claim was not cognizable under CP § 8-201 because he challenged the authenticity and admissibility of the DNA evidence, not the scientific reliability of the testing itself. The court explained that § 8-201 provides relief only for claims of scientific unreliability, not for chain-of-custody or evidentiary issues that could have been raised at trial or on direct appeal. The court affirmed the circuit court’s denial of the motion for a new trial. View "Tarpley v. State" on Justia Law

A mother filed a petition for protection from child abuse on behalf of her two minor children against their father, following allegations of threats, mental injury, and physical abuse. An ex parte hearing in the Circuit Court for Anne Arundel County resulted in a temporary protective order and referral to the Department of Social Services (DSS) for investigation. The DSS report, completed before the final hearing, corroborated the children’s accounts of abusive behavior. At the final hearing, the mother was unrepresented and the father had counsel; after hearing testimony, the court granted a final protective order awarding custody to the mother and supervised visitation to the father.The Appellate Court of Maryland affirmed the circuit court’s grant of the final protective order. It found that the circuit court had sufficient basis to extend the temporary protective order pending the DSS investigation, that the father’s right to procedural due process was not violated by not being served with the petition, and that the circuit court’s negative credibility determination of the father’s testimony was enough to support the finding of abuse by a preponderance of the evidence.The Supreme Court of Maryland reviewed three issues. First, it held that the father did not preserve for appellate review the question of whether the circuit court erred by not stating on the record whether good cause existed to set the final hearing beyond seven days of service of the temporary order. Second, the Court held that service of a temporary protective order, which includes factual allegations and notice of the hearing, generally satisfies procedural due process requirements; thus, the father was not entitled to service of the petition in addition. Third, the Court held that the Appellate Court erred by affirming the final protective order solely on the basis of the circuit court’s negative credibility finding; lack of credibility alone does not satisfy the petitioner’s burden of proof. The judgment was affirmed in part, vacated in part, and remanded for further proceedings. View "Clarke v. Gibson" on Justia Law

Sanjeev Varghese was injured when he rode his bicycle into a steel cable stretched between two bollards on Pier 5 at Baltimore’s Inner Harbor. The barrier was located between a vehicular access road and a pedestrian promenade. The City of Baltimore had approved the design of the access road and its barriers, with changes for safety and aesthetics implemented in 2005. In 2017, a similar bicycle accident occurred, and the City received notice of that incident. In 2018, Varghese crashed into the barrier and subsequently sued the City for negligence, claiming the barrier was hazardous and that the City failed to address a known danger.The Circuit Court for Baltimore City allowed Varghese’s claims to proceed to a jury, which found the City negligent and awarded damages. The City moved for judgment notwithstanding the verdict, arguing it was entitled to governmental immunity based on the discretionary nature of its design decisions. The circuit court denied this motion. On appeal, the Appellate Court of Maryland affirmed the judgment, concluding that the City was not immune from liability for failing to fix a known hazard.The Supreme Court of Maryland reviewed the case and held that the City’s decisions regarding the design and placement of the barrier were discretionary governmental functions. The court reaffirmed that municipalities are immune from tort liability for such discretionary design decisions unless the condition created is so obviously dangerous that no reasonable person could disagree. The court found that this exception did not apply here, as the barrier was not shown to be obviously dangerous. Therefore, the Supreme Court of Maryland reversed the judgment of the Appellate Court and instructed that judgment be entered in favor of the City. View "May. & City Cncl. Of Baltimore v. Varghese" on Justia Law

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