Justia Maryland Supreme Court Opinion Summaries

The case involves a dispute over a parcel of land situated at the border of adjoining properties in Owings Mills, Maryland. Dr. Sharon Saunders owns one property, while Steven and Ellen Gilman own the neighboring property. The Gilmans claimed ownership of the disputed land through adverse possession, having maintained and used the land for several decades. In 2018, the Gilmans constructed a fence on the disputed property, prompting Dr. Saunders to commission a property survey and subsequently file a lawsuit to establish the boundary line and seek damages for trespass and other tort claims.The Circuit Court for Baltimore County ruled in favor of the Gilmans, declaring them the absolute owners of the disputed property by adverse possession. The court ordered the Gilmans to prepare and file an amended deed and plat reflecting their ownership. Dr. Saunders appealed the decision, but the Appellate Court dismissed the appeal, stating that the order was not a final judgment and did not fall under any exceptions allowing for an interlocutory appeal.The Supreme Court of Maryland reviewed the case to determine whether the Appellate Court erred in its decision. The Supreme Court held that the Circuit Court's order declaring the Gilmans as owners by adverse possession and directing the preparation of a deed was immediately appealable under Maryland Code, Courts & Judicial Proceedings Article §§ 12-303(1) and 12-303(3)(v). The Supreme Court reversed the Appellate Court's dismissal and remanded the case for further proceedings to address the merits of Dr. Saunders's appeal. View "Saunders v. Gilman" on Justia Law

Stephen Zimmerman pled guilty to second-degree assault and was sentenced to ten years, with all but the time served in pretrial detention suspended, and placed on three years of supervised probation. In October 2022, Zimmerman was charged with violating his probation. The District Court of Maryland in Frederick County found him in violation, revoked his probation, and imposed a seven-year custodial sentence. Zimmerman appealed de novo to the Circuit Court for Frederick County, which also found him in violation and imposed the same seven-year sentence. Zimmerman’s motion for a new trial was denied, and he subsequently filed a pro se “Motion for Appeal.”The Appellate Court of Maryland docketed Zimmerman’s motion as an application for leave to appeal and directed the State to respond. The State moved to transfer the appeal to the Supreme Court of Maryland, arguing that the Appellate Court lacked jurisdiction. The Appellate Court granted the motion, reasoning that further appellate review of a circuit court decision issued in its appellate capacity must be pursued in the Supreme Court of Maryland.The Supreme Court of Maryland held that the Appellate Court of Maryland lacked jurisdiction to consider Zimmerman’s appeal. Under § 12-305 of the Courts and Judicial Proceedings Article, the Supreme Court has exclusive appellate jurisdiction over final judgments of a circuit court entered in the exercise of its appellate jurisdiction over District Court cases. Therefore, any further review must be sought by petition for a writ of certiorari to the Supreme Court of Maryland. The Court affirmed the Appellate Court’s decision to transfer the case and instructed Zimmerman to file a proper petition for writ of certiorari within 30 days if he sought further review. View "Zimmerman v. State" on Justia Law

Seamus Coyle was convicted of first-degree murder, conspiracy to commit first-degree murder, and use of a handgun in the commission of a crime of violence. He was sentenced to life imprisonment. Due to a conflict of interest, the Office of the Public Defender (OPD) assigned a panel attorney to represent Coyle in his direct appeal to the Appellate Court of Maryland, which affirmed his convictions. The panel attorney discussed filing a petition for a writ of certiorari with Coyle and the OPD and was authorized to file the petition but failed to do so. Coyle then petitioned for postconviction relief, alleging ineffective assistance of counsel.The Circuit Court for Baltimore County denied Coyle’s petition for postconviction relief, finding that the issues raised on appeal were neither novel nor important from a public policy standpoint and that there was no possibility that the Supreme Court of Maryland would have granted certiorari. Coyle’s application for leave to appeal was granted, but the Appellate Court of Maryland affirmed the circuit court’s judgment, concluding that Coyle did not have a right to counsel for filing a petition for a writ of certiorari and thus was not deprived of due process.The Supreme Court of Maryland reviewed the case and held that, based on the plain language of the Maryland Public Defender Act, where an attorney is authorized by the OPD to represent an indigent defendant in filing a petition for a writ of certiorari, the attorney must provide effective assistance of counsel. The Court concluded that the panel attorney’s conduct in failing to file the petition fell below an objective standard of reasonableness and constituted deficient performance under Strickland v. Washington. The Court held that prejudice is established because the defendant was deprived of the opportunity to have the petition considered. The judgment of the Appellate Court was reversed, and Coyle was permitted to file a belated petition for a writ of certiorari. View "Coyle v. State" on Justia Law

Harry Davis, Jr. was convicted by a jury in the Circuit Court for Baltimore City of second-degree murder, two counts of first-degree assault, two counts of second-degree assault, and one count of openly wearing and carrying a dangerous weapon. He was sentenced to 72 years in prison. After sentencing, the judge informed Davis of his right to appeal and to file a motion for modification of sentence within 90 days but did not advise him of his right to counsel for filing such a motion. Davis filed an appeal, which was affirmed by the Appellate Court of Maryland. No motion for modification of sentence was filed on his behalf.Davis later filed a petition for postconviction relief, claiming ineffective assistance of counsel for his trial counsel’s failure to file a motion for modification of sentence. The Circuit Court denied the petition, stating that there was no evidence Davis had asked his counsel to file the motion. Davis appealed, and the Appellate Court granted his application for leave to appeal and certified questions to the Supreme Court of Maryland.The Supreme Court of Maryland held that a defendant can establish ineffective assistance of counsel based on counsel’s failure to file a motion for modification of sentence by demonstrating that counsel failed to consult with the defendant about filing the motion and that this failure was unreasonable. The Court overruled previous decisions that suggested a per se rule either requiring or not requiring a request from the defendant. The Court concluded that Davis’s trial counsel’s failure to consult with him about filing a motion for modification of sentence constituted deficient performance and that Davis was prejudiced by losing the opportunity to have the motion considered. The Court reversed the Circuit Court’s judgment and remanded the case, allowing Davis to file a belated motion for modification of sentence. View "Davis v. State" on Justia Law

Two former police officers, Mark Zukowski and Joshua Ruggiero, were injured in the line of duty and subsequently awarded both accidental disability retirement (ADR) benefits and workers' compensation benefits under Maryland's Workers' Compensation Act. The ADR benefits exceeded the workers' compensation benefits, resulting in an offset that left the officers with only a small portion of the workers' compensation benefits. The officers' attorney sought fees based on the total workers' compensation award before the offset was applied.The Maryland Workers' Compensation Commission awarded attorney's fees based on the reduced amount of workers' compensation benefits after applying the statutory offset. The Circuit Court for Anne Arundel County affirmed the Commission's decision, holding that attorney's fees should be calculated after the offset.The Supreme Court of Maryland reviewed the case and affirmed the lower courts' decisions. The Court held that the terms "benefits" and "compensation" are interchangeable in this context, meaning that attorney's fees should be calculated based on the amount of compensation actually payable to the claimant after applying the statutory offset. The Court emphasized that the attorney's fees are a lien on the compensation awarded, which is defined as the money payable to the injured employee. Therefore, the offset must be applied before calculating the attorney's fees. The Court also rejected the argument that this interpretation was unconstitutional, stating that the attorney voluntarily agreed to the fee arrangement and was aware of the statutory provisions governing attorney's fees. View "Zukowski v. Anne Arundel Cnty." on Justia Law

Fred Cromartie was convicted of second-degree assault and other offenses following an altercation in a parking lot, which was recorded by surveillance cameras. The State alleged that Cromartie was one of the shooters, and his defense was self-defense. During the trial, the defense invoked Maryland Rule 5-615 to exclude witnesses from the courtroom while others testified. The State designated Detective Courtney Moore, a witness, as its representative, allowing him to remain in the courtroom.The Circuit Court for Anne Arundel County allowed the State's designation over the defense's objection. The jury convicted Cromartie of several charges but acquitted him of others. Cromartie appealed, arguing that the circuit court erred in allowing the State to designate Detective Moore as its representative and that Moore's testimony constituted improper lay opinion identification testimony.The Supreme Court of Maryland reviewed the case. The court did not resolve whether the circuit court erred in permitting the State to designate Detective Moore as its representative because any such error was deemed harmless beyond a reasonable doubt. The court found that Moore's testimony was not improperly influenced by other testimony he heard before testifying and that his presence did not improperly bolster the State's case.Regarding the lay opinion testimony, the court concluded that Cromartie did not preserve his argument that Moore's testimony identifying individuals in the video was improper. The court noted that the identity of the individuals was not in dispute and had already been established, including by the defense. Additionally, the defense did not request a continuing objection or object to subsequent similar questions and answers.The Supreme Court of Maryland affirmed the judgment of the Circuit Court for Anne Arundel County. View "Cromartie v. State" on Justia Law

Fred Cromartie was convicted of second-degree assault and other offenses following an altercation in a parking lot, which was recorded by surveillance cameras. The State alleged that Cromartie was one of the shooters, and his defense was self-defense. During the trial, the defense invoked Maryland Rule 5-615 to exclude witnesses from the courtroom while others testified. The State designated Detective Courtney Moore, a witness, as its representative, which the court allowed over the defense's objection.The Circuit Court for Anne Arundel County permitted Detective Moore to sit at the State's counsel table during the trial. The jury heard testimony from Jalen Hayes, who identified Cromartie and others in the video, and from Detective Moore, who testified about his investigation and the crime scene. The jury convicted Cromartie of second-degree assault, possessing a firearm after a disqualifying crime, and carrying a loaded handgun, but acquitted him of other charges.The Supreme Court of Maryland reviewed the case to determine if the circuit court erred in allowing the State to designate Detective Moore as its representative and if his testimony constituted improper lay opinion under Rule 5-701. The court did not resolve the first issue, finding any error harmless beyond a reasonable doubt, as Detective Moore's testimony was not improperly influenced by other testimony. On the second issue, the court found that Cromartie did not preserve his objection to Detective Moore's identification testimony and that any error was harmless beyond a reasonable doubt. The court affirmed the Circuit Court's judgment. View "Cromartie v. State" on Justia Law

Sydney Walton, a fourteen-year-old, suffered a concussion and other head injuries during an indoor soccer practice at a Baltimore County-owned facility. The plaintiffs, her family, alleged that the defendants, including Premier Soccer Club, Inc., its coach, and several Baltimore County employees, were negligent in violating a Maryland statute designed to ensure that parents, players, and coaches in youth sports are informed about the risks of concussions and best practices for preventing and handling them.The Circuit Court for Baltimore County granted summary judgment in favor of the defendants on the negligence claim based on the statutory violation. The court found that the plaintiffs failed to provide evidence that the alleged statutory violations proximately caused Sydney's injuries. The plaintiffs appealed, but the Appellate Court of Maryland affirmed the circuit court's decision, agreeing that the plaintiffs did not establish the necessary causation-in-fact.The Supreme Court of Maryland reviewed the case and affirmed the judgment of the Appellate Court. The court held that to establish a prima facie case of negligence based on a statutory violation, the plaintiff must show that the defendant violated a statute designed to protect a specific class of persons that includes the plaintiff and that the violation proximately caused the plaintiff's injury. The court emphasized that proximate cause requires evidence of both causation-in-fact and legal causation. The plaintiffs failed to provide sufficient evidence to establish that the statutory violations were the cause-in-fact of Sydney's injuries, and thus, the summary judgment in favor of the defendants was upheld. View "Walton v. Premier Soccer Club" on Justia Law

Two former police officers, Mark Zukowski and Joshua Ruggiero, were injured in the line of duty and subsequently awarded both accidental disability retirement (ADR) benefits and workers' compensation benefits. The ADR benefits exceeded the workers' compensation benefits, resulting in an offset of the latter. The key issue in this case was whether attorney’s fees should be calculated before or after applying the statutory offset under Maryland’s Workers’ Compensation Act.The Maryland Workers’ Compensation Commission awarded Zukowski and Ruggiero workers' compensation benefits, but these were largely offset by their ADR benefits. The Commission calculated attorney’s fees based on the reduced, post-offset amount of workers' compensation benefits. Zukowski and Ruggiero argued that attorney’s fees should be calculated based on the total award before applying the offset, contending that the terms "compensation" and "benefits" in the relevant statutes should be interpreted differently.The Circuit Court for Anne Arundel County affirmed the Commission’s decision, agreeing that attorney’s fees should be calculated after applying the offset. The court found no distinction between "compensation" and "benefits" in this context and held that attorney’s fees are a lien on the compensation actually payable to the claimant.The Supreme Court of Maryland reviewed the case and affirmed the lower courts' decisions. The Court held that the terms "compensation" and "benefits" are interchangeable in this context, meaning that attorney’s fees should be calculated based on the amount of workers' compensation benefits payable after applying the statutory offset. The Court emphasized that the attorney’s fees are a lien on the compensation awarded, which is the amount actually payable to the claimant after the offset. The Court also rejected the argument that this interpretation was unconstitutional, noting that attorneys voluntarily enter into contingency fee arrangements and are aware of the statutory framework governing such fees. View "Zukowski v. Anne Arundel Cnty." on Justia Law

Badlia Brothers, LLC, a check-cashing business, cashed 15 checks issued by the State of Maryland. These checks had already been paid by the State before Badlia presented them for payment. Some checks were deposited using a mobile app, creating "substitute checks," and were then fraudulently or negligently presented to Badlia. Others were reported lost or stolen, leading the State to issue stop payment orders and replacement checks, which were also cashed by Badlia. Badlia accepted the checks without knowledge of prior payments and sought payment from the State, which refused.Badlia filed complaints in the District Court of Maryland, claiming the right to enforce the checks as a holder in due course. The court consolidated the cases, ruled that the State enjoyed qualified immunity, and dismissed the cases. The Circuit Court for Baltimore City reversed, holding that a check is a contract, and thus, the State had waived sovereign immunity. On remand, the District Court found that Badlia was a holder in due course entitled to enforce the checks. The Circuit Court affirmed, and the State petitioned for certiorari.The Supreme Court of Maryland reviewed the case and held that a check is a contract for purposes of the State’s waiver of sovereign immunity under § 12-201(a) of the State Government Article. The court affirmed the Circuit Court's decision, concluding that the State has waived sovereign immunity for claims by a holder in due course seeking payment on an authorized State-issued check. View "Comptroller v. Badlia Brothers, LLC" on Justia Law