Justia Maryland Supreme Court Opinion Summaries

After a homeowners association obtained a money judgment against a homeowner for unpaid assessments, it levied the homeowner’s interest in her property and proceeded with a sheriff’s sale. The homeowner did not satisfy the judgment or obtain release of the levy before the sale occurred. A third-party bidder purchased the homeowner’s interest in the property at auction. After the sale but before the court ratified it, the homeowner paid the judgment in full to the association. The association then notified the court of the satisfaction and requested that the sale be vacated, arguing the judgment had been satisfied prior to ratification.The District Court of Maryland, sitting in Prince George’s County, agreed with the association, concluding that the sale could be vacated since the homeowner satisfied the judgment before ratification. On appeal, the Circuit Court for Prince George’s County affirmed, holding a hearing and again ruling that the sale was not complete until ratification and thus could be undone by post-sale satisfaction of the judgment.The Supreme Court of Maryland reviewed the case. It held that a judgment-debtor’s satisfaction of the judgment after a sheriff’s sale, but before ratification, cannot be raised as an exception to the sale under Maryland Rule 14-305(e)(1). Post-sale satisfaction is not an irregularity in the sale and does not void the purchaser’s inchoate equitable interest in the property acquired at auction. The Court emphasized that the judgment-debtor may obtain release of the levy only before sale, and that post-sale options for release are not available. The Court reversed the Circuit Court’s judgment and remanded with instructions to allow the homeowner thirty days to file exceptions to the sale, beginning after remand to the District Court. View "Baltimore XV Props. v. Newsteps' Choice North Homeowners Association, Inc." on Justia Law

A father filed a petition in the District Court of Maryland, sitting in Montgomery County, seeking protection on behalf of his 11-year-old child from the child’s mother. The petition alleged repeated physical abuse, including punching and hitting with objects. Based on the allegations, the District Court entered an interim protective order, then a temporary protective order after finding reasonable grounds to believe abuse occurred, and ultimately a final protective order after a hearing. The final order, effective for one year, was supported by findings of a history of abuse.The mother appealed the District Court’s final protective order to the Circuit Court for Montgomery County, requesting and receiving two continuances. During this time, the circuit court issued intervening protective orders that maintained the previous protections and, at the mother’s request, allowed for a supplemental investigation. After a de novo hearing, the circuit court again entered a final protective order, modifying some conditions, and granted the father physical custody of the child. The mother then appealed to the Appellate Court of Maryland. That court transferred the case to the Supreme Court of Maryland, concluding it lacked jurisdiction because the circuit court had exercised appellate, not original, jurisdiction.The Supreme Court of Maryland held that when a circuit court hears a de novo appeal from a District Court’s final protective order under Maryland’s domestic violence statute, the circuit court has authority to issue intervening protective orders pending the final hearing. Issuing such orders does not convert the proceeding into one under the circuit court’s original jurisdiction, and thus, there is no further right of appeal to the Appellate Court of Maryland. The Supreme Court affirmed the judgment of the Circuit Court for Montgomery County. View "Walston v. Lindsay" on Justia Law

A public utility company that sells electricity to Maryland customers used equipment such as conductors, substations, and transformers to transmit and distribute electricity generated outside Maryland. The transmission process involved “stepping up” and “stepping down” voltage to deliver electricity at a level suitable for customer use. The utility believed that most of its equipment used for these purposes qualified for a state sales and use tax exemption for tangible personal property used directly and predominantly in a production activity, specifically the “processing” of electricity for resale. During an audit period, the utility paid sales and use tax on some, but not all, of its relevant equipment due to an accounting irregularity. Afterward, it requested a refund for the taxes it believed were paid in error.The Comptroller denied both the refund and a related assessment challenge, concluding the exemption did not apply. On appeal, the Maryland Tax Court determined that the conductor, substation, and transformer equipment qualified for the exemption because it was used directly and predominantly for processing electricity, but found that certain support structures and other items did not qualify. The Circuit Court for Anne Arundel County affirmed the Tax Court’s exemption ruling but held that most of the refund claim was untimely under the four-year statute of limitations for tax refund claims. The Appellate Court of Maryland affirmed most of the Tax Court’s rulings and instead applied a 30-day limitations period, making the entire refund claim timely.The Supreme Court of Maryland held that the utility’s transmission and distribution equipment performed “processing” and thus a production activity, qualifying for the exemption. The Court agreed that only the conductor, substation, and transformer equipment qualified and not the support structures. The Court also held that the general four-year limitations period applied, not the 30-day period, and that the utility was entitled to interest on the refunded amounts. The judgment was affirmed in part, reversed in part, and remanded for further proceedings. View "Comptroller v. Potomac Edison" on Justia Law

A mother surrendered her four-day-old twin sons at a hospital in Maryland under the Safe Haven Act, which allows parents to leave unharmed newborns at designated facilities within sixty days of birth without facing criminal or civil liability for the act of surrender. The mother left the infants with basic information but did not identify herself or provide for their ongoing care. The hospital notified the Anne Arundel County Department of Social Services, which took custody of the children and filed Child in Need of Assistance (CINA) petitions, seeking court intervention to ensure the children’s welfare. The mother was later identified and participated in the proceedings, explaining she acted out of concern for domestic violence.After de novo adjudicatory and disposition hearings in the Circuit Court for Anne Arundel County, sitting as a juvenile court, the court found that the mother’s actions constituted “neglect” under the CINA statute—specifically, that leaving the children without a legal custodian or provision for care placed them at a substantial risk of harm. The court denied the mother’s request to award custody to the father at that stage and committed the children to the Department’s custody. The mother appealed, and the Appellate Court of Maryland affirmed the juvenile court’s decision, reasoning that the absence of a legal custodian or care plan for the infants following surrender justified a finding of neglect.The Supreme Court of Maryland reviewed the case and affirmed the Appellate Court’s judgment. The Court held that a parent’s surrender of a newborn under the Safe Haven Act may constitute neglect under the CINA statute if the child is left without a legal custodian or provision for care, thus facing a substantial risk of harm. The Court also held that the Safe Haven Act’s grant of immunity from “civil liability” does not bar a CINA neglect finding, as such a finding is a non-punitive jurisdictional predicate necessary for state intervention and long-term care arrangements. View "In re: B.Cd. & B.Cb." on Justia Law

Several individuals charged with crimes in Maryland were found by circuit courts to be incompetent to stand trial and dangerous due to mental disorders. Under Maryland law, such defendants must be committed to a designated health care facility for treatment, and the Maryland Department of Health is required to admit them within ten business days of receiving the court’s order. In these cases, the Department failed to meet that deadline, resulting in extended detention for the affected individuals in local facilities rather than treatment centers.After the Department’s delays, the defendants sought relief. The Circuit Court for Kent County and the Circuit Court for Baltimore County held hearings and imposed monetary sanctions on the Department under Maryland Criminal Procedure § 3-106(c)(4), which authorizes courts to impose sanctions to compel compliance with the statutory deadline. In four cases, defendants had not yet been transferred by the time of the hearings; in two cases, the Department had admitted the defendants before the hearings, but the courts still imposed sanctions. The Department argued that it was impossible to comply due to full facilities and long waiting lists, and that sanctions could not reasonably compel compliance. The Department also raised a separation of powers argument at one hearing but did not pursue it on appeal.The Appellate Court of Maryland affirmed the imposition of sanctions, holding that the circuit courts did not abuse their discretion. It ordered recalculation of the sanction amounts in some cases and rejected the argument that the Department’s later compliance prevented sanctions.The Supreme Court of Maryland affirmed the Appellate Court’s judgment. It held that trial courts may impose monetary sanctions reasonably designed to compel the Department to admit defendants as soon as possible after the ten-day deadline, including where waiting lists exist. The Court also held that sanctions can be imposed even after a defendant is belatedly admitted. Finally, the Court found no separation of powers violation in the statutory sanctions mechanism. View "Dept. of Health v. Boulden" on Justia Law

A homeowners association obtained a money judgment against a homeowner for unpaid assessments and placed a levy on the homeowner’s property. The homeowner did not satisfy the judgment prior to a sheriff’s auction, and the property was sold to a third-party purchaser. After the auction, but before the court ratified the sale, the homeowner satisfied the judgment by paying the full amount to the association. The association then asked the court to vacate the sale and return the purchase funds to the buyer, arguing that the post-sale satisfaction of the judgment should nullify the auction outcome.The District Court of Maryland sitting in Prince George’s County agreed with the association, finding it proper to vacate the sale since the judgment was satisfied before ratification. On appeal, the Circuit Court for Prince George’s County held a de novo hearing and affirmed the District Court’s decision, maintaining that the sale was not complete until ratified and thus could be undone by satisfaction of the judgment at that stage. The purchaser sought review from the Supreme Court of Maryland.The Supreme Court of Maryland held that a judgment-debtor’s post-sale satisfaction of the judgment cannot be raised as an exception to a sheriff’s sale under Maryland Rule 14-305(e)(1). The Court explained that such satisfaction is not an irregularity with respect to the sale, and that a purchaser acquires an inchoate equitable interest after the auction, with a right to the ratification process. Allowing satisfaction of the judgment after the sale to void the auction would undermine that right and negatively affect the sheriff’s sale system. Accordingly, the Supreme Court of Maryland reversed the Circuit Court’s judgment and remanded the case for further proceedings, permitting the homeowner thirty days to file exceptions to the sale under the proper rule. View "Baltimore XV Props. V. Newsteps' Choice N." on Justia Law

A nonprofit organization seeking to preserve the Sugarloaf Mountain area submitted two requests under the Maryland Public Information Act (MPIA) to Frederick County, seeking records relating to changes in a local land management plan. The County acknowledged receipt but did not produce any documents or respond further for eight months. After the nonprofit filed suit in the Circuit Court for Frederick County, the County provided some documents and withheld others, citing various privileges. Following a bench trial, the Circuit Court ordered most withheld documents to be produced and later conducted an in camera review for a subset of documents, ultimately finding some were properly withheld.After prevailing in obtaining key documents, the nonprofit sought attorneys’ fees. The Circuit Court found the requested fees reasonable under the applicable “lodestar” method but reduced the award from over $48,000 to $25,000, considering factors such as the absence of an “evil motive” by County officials and the burden on County taxpayers. The Circuit Court denied a supplemental fee petition for procedural reasons. On appeal, the Appellate Court of Maryland affirmed the reduced fee award, finding no abuse of discretion, but vacated the denial of the supplemental petition and remanded that issue.On further appeal, the Supreme Court of Maryland held that the Circuit Court abused its discretion in calculating the attorneys’ fees award. The Supreme Court found that the Circuit Court improperly relied on factors not relevant under the lodestar approach set forth in Maryland Rule 2-703(f)(3), such as the officials’ motives and the effect on taxpayers, and failed to explain the basis for the reduction. The Supreme Court of Maryland reversed the Appellate Court’s affirmance of the fee award, remanded with instructions to vacate the award, and directed the Circuit Court to reconsider the petition using the proper legal standards. View "Sugarloaf Alliance v. Frederick Cnty." on Justia Law

Two shareholders brought a derivative action on behalf of two Maryland closed-end investment funds against the funds’ investment adviser and members of the funds’ board of directors. The shareholders alleged that the board’s failure to control the funds’ use of leverage led to substantial losses during a downturn in the energy sector, and that the investment adviser benefited from the increased leverage through higher fees. The board consisted of five directors, four of whom were allegedly independent, and one who was the chief executive officer of the adviser. The board renewed the adviser’s contract and took defensive actions after the losses were realized. The shareholders did not make a pre-suit demand on the board before filing suit, claiming that such a demand would have been futile.The Circuit Court for Baltimore City dismissed the derivative claim with prejudice, finding that the shareholders had not pleaded sufficient facts to excuse the demand requirement under Maryland law. The court reviewed each allegation and concluded that none established demand futility. The Appellate Court of Maryland affirmed, holding that the allegations indicated only that a demand was unlikely to succeed, not that it was futile. The appellate court also rejected the shareholders’ argument that potential personal liability for directors constituted a disabling conflict sufficient to excuse demand.The Supreme Court of Maryland affirmed the lower courts’ decisions. It clarified that under Werbowsky v. Collomb, the futility exception is satisfied only if shareholders clearly and particularly allege that a majority of the board could not consider a litigation demand in accordance with the statutory standard of conduct for directors. The court held that futility depends on the board’s capacity to consider a demand, not on the likelihood of refusal, and that allegations of potential personal liability or hostility to litigation do not excuse the demand requirement. The judgment of the Appellate Court of Maryland was affirmed. View "Nathanson v. Tortoise Capital Advisors" on Justia Law

A married couple insured their vehicles under a Maryland automobile insurance policy with liability limits of $300,000 per person and $300,000 per occurrence. During an accident, the wife negligently drove one of the insured vehicles, resulting in the death of her husband, who was a passenger. Their four adult children, who did not reside in the household, filed wrongful death claims against their mother under Maryland’s wrongful death statute, seeking damages from the insurer.After the children made their claims, the insurance company invoked the policy’s household exclusion provision. That exclusion limited coverage for “bodily injury to any insured, or to any relative of an insured residing in his household” to the statutory minimum of $30,000. The insurer argued that the children’s claims, though brought under the wrongful death statute, were based on the “bodily injury” (death) of an insured and thus subject to the exclusion’s limit.The Circuit Court for Montgomery County granted declaratory judgment in favor of the insurance company, holding that the children’s claims were derivative of their father’s bodily injury, and that coverage was properly limited by the household exclusion. The Appellate Court of Maryland affirmed, relying on the plain language of the policy and prior Maryland case law, including Costello v. Nationwide Mutual Insurance Co., Daley v. United Services Automobile Ass’n, and Valliere v. Allstate Insurance Co., concluding that the household exclusion applied to the adult children’s claims.The Supreme Court of Maryland affirmed the judgment of the Appellate Court. It held that, under the unambiguous language of the policy, the household exclusion applies to limit the insurer’s liability for damages claimed by non-resident adult children under the wrongful death statute when the claim is based on the death of an insured. The Court concluded that the policy’s use of “bodily injury” as the triggering event controls, and the household exclusion limits recovery to $30,000. View "Murphy v. Gov't Employees Insurance Co." on Justia Law

A group of homeowners and their associations opposed amendments to a planned unit development in Baltimore City, actively communicating their disapproval to the Planning Commission. After the Commission approved the amendments, the developer filed suit against the homeowners and associations, seeking damages and alleging breach of contract and tortious interference. The homeowners and associations, believing the suit to be a strategic lawsuit against public participation (SLAPP), moved to dismiss under Maryland’s anti-SLAPP statute, Md. Code Ann., Cts. & Jud. Proc. § 5-807. The Circuit Court for Baltimore City found the lawsuit was a SLAPP and dismissed it, and the Appellate Court of Maryland affirmed the dismissal, citing evidence that the suit was intended to deter the homeowners from exercising their rights.Two years after the Appellate Court affirmed the SLAPP dismissal, the homeowners and associations filed a class action for malicious use of process against the developer, its law firm, and its attorney. They alleged unique injuries, including emotional distress, intimidation, diminished property values, and burdensome discovery demands. The Circuit Court for Baltimore City dismissed the suit, concluding that the plaintiffs had not pleaded the “special injury” required for malicious use of process. The Appellate Court of Maryland affirmed, holding that the alleged injuries were typical of litigation and not “special” as required by Maryland law.The Supreme Court of Maryland reviewed the case and held that the plaintiffs failed to state a claim for malicious use of process because they did not plead a special injury. The Court clarified that litigation expenses, temporary property value diminution, emotional distress, and chilling of constitutional rights are not special injuries under Maryland law. The Court also declined to adopt a rule that victims of a SLAPP inherently satisfy the special-injury requirement. Accordingly, the Supreme Court of Maryland affirmed the judgment of the Appellate Court. View "Millrace Condo. v. Shapiro Sher etc., PA" on Justia Law