Justia Maryland Supreme Court Opinion Summaries

The case arose after a sewage backup occurred in December 2019 in the basement of a home rented by the plaintiffs. Prior to this incident, they had experienced no similar issues, and neither had their neighbors. The backup was traced to a blockage in the City of Baltimore’s main sewage line. The plaintiffs contacted the City’s nonemergency service and, after multiple calls, a crew arrived about 17 hours later and resolved the problem. The plaintiffs’ expert attributed the backup to insufficient cleaning of the sewer line following a prior upstream blockage days earlier, but the court limited the expert’s testimony for lack of factual foundation.At trial in the Circuit Court for Baltimore City, the plaintiffs pursued claims of negligence and private nuisance against the City. The jury found for the City on negligence but found the City liable for private nuisance, awarding damages. The City appealed, arguing that the evidence did not establish a private nuisance under Maryland law. The Appellate Court of Maryland affirmed the lower court, holding the jury could find the backup was a continuous or repetitive interference with the plaintiffs’ use of property.Upon review, the Supreme Court of Maryland determined that Maryland’s common law of private nuisance requires not only a significant invasion of the plaintiff’s use and enjoyment of land but also wrongful conduct by the defendant. Wrongful conduct may be negligent, reckless, abnormally dangerous, or, if not otherwise tortious, must create a continuous or recurring and unreasonable intrusion. The Supreme Court concluded that, viewing the evidence most favorably to the plaintiffs, there was no legally sufficient evidence that the City engaged in wrongful conduct or that the intrusion was continuous or recurring. Accordingly, the Supreme Court of Maryland reversed the Appellate Court’s decision and ordered judgment entered in favor of the City. View "City of Baltimore v. Abel" on Justia Law

The case involved allegations that a father sexually abused his minor daughter, H., over a period of years, and that he also abused her friends and provided them with intoxicating substances when they visited his apartment. The evidence included testimony from H., two of her friends (A.L. and A.B.), and a social worker, describing sexual misconduct and the provision of alcohol, marijuana, and vapes to the minors. The prosecution also introduced evidence that the father showed pornographic material to the girls. The defense denied all allegations and sought to present character witnesses to attest to his honesty.In the Circuit Court for St. Mary’s County, the defendant was convicted by a jury of sexual abuse of a minor, second-degree rape, and third-degree sexual offense. The court admitted the testimony of H.’s friends regarding other alleged abuses and denied the defendant’s motion to exclude this evidence under Maryland Rule 5-404(b). The court also refused to allow the defendant’s character witnesses to testify as to his honesty. Additionally, during cross-examination, the prosecutor asked the defendant why his daughter would lie about the allegations, to which the defense objected.The Appellate Court of Maryland affirmed the convictions, holding that the evidence of other bad acts was admissible to explain the victim’s delayed reporting and to corroborate her testimony, and that the exclusion of character witnesses was proper.The Supreme Court of Maryland affirmed the judgment. It held that the trial court did not err in admitting the other bad acts evidence under the “common scheme or plan” exception to Rule 5-404(b), as the acts were sufficiently connected to show a general plan of abuse involving the daughter and her friends. The Court further held that the prosecutor’s “why-would-she-lie” question was improper but found the error harmless beyond a reasonable doubt. Finally, it concluded that the trial court properly excluded the defendant’s character evidence for honesty, as the charges were not veracity-impeaching offenses and the defense’s proffers lacked specificity. View "Spicuzza v. State" on Justia Law

The case involves the conviction of an individual for two counts of second-degree murder and related firearms offenses following a shooting incident in Prince George’s County, Maryland. The State’s evidence included testimony from a firearms identification expert who opined that bullets and cartridges recovered from the scene were fired from a specific handgun linked to the defendant. The defense initially raised discovery objections concerning the expert’s bench notes and signaled an intent to challenge the reliability of the ballistics methodology but ultimately limited its objection to procedural discrepancies in how the expert conducted the examination, rather than the reliability of the underlying science.Following trial and conviction in the Circuit Court for Prince George’s County, the defendant appealed to the Appellate Court of Maryland. While the appeal was pending, the Supreme Court of Maryland decided Abruquah v. State, 483 Md. 637 (2023), which limited the admissibility of unqualified firearms identification testimony based on the evidentiary record in that case. The defendant raised an Abruquah claim for the first time in his reply brief, arguing that the trial court erred in admitting the expert’s testimony. The Appellate Court reversed the conviction, finding abuse of discretion and concluding the error was not harmless, as the firearms testimony was the primary evidence linking the defendant to the crime.On appeal, the Supreme Court of Maryland addressed whether the Appellate Court erred in applying Abruquah retroactively when the issue was not preserved and no Daubert-Rochkind hearing was held. The Supreme Court held that the defense had expressly waived any challenge to the reliability of firearms identification methodology and failed to file a timely motion as required by Maryland Rule 4-252. Even if treated as unpreserved, the admission of the expert testimony was not plain error, as Abruquah was a case-specific ruling rather than a categorical prohibition. The Supreme Court reversed the Appellate Court’s judgment and remanded for further proceedings. View "State v. King" on Justia Law

After two individuals were found shot to death in a car in Prince George’s County, Maryland, the police recovered a semi-automatic handgun and spent cartridges at the scene. The defendant’s cellphone, containing a picture of the same gun and messages referencing a debt owed by one of the victims, was also found in the car. Surveillance footage and witness testimony placed the defendant at the scene. The defendant was indicted on multiple charges, including second-degree murder and firearms offenses.During pretrial proceedings in the Circuit Court for Prince George’s County, the defense raised discovery issues related to the State’s firearms expert but did not file a motion for a Daubert hearing to challenge the reliability of the firearms identification methodology. At trial, the defense limited its objection to “as-applied” issues—alleging the examiner had not followed proper procedures—rather than contesting the scientific reliability of the methodology. The defense explicitly told the court its concern was “not with the science.” The circuit court allowed the expert’s testimony, and the jury convicted the defendant. On appeal, the Appellate Court of Maryland reversed, relying on the Supreme Court of Maryland’s decision in Abruquah v. State, which restricted unqualified firearms identification testimony.The Supreme Court of Maryland reviewed the case. It held that Abruquah was a case-specific determination under Daubert and Rochkind, not a categorical rule barring all unqualified firearms identification testimony. The Court found the defense had waived any challenge to the methodology’s reliability by expressly disclaiming such an objection and failing to file a proper motion. Even if the claim were merely unpreserved, admission of the testimony was not plain error. Accordingly, the Supreme Court of Maryland reversed the Appellate Court’s judgment and remanded for consideration of remaining appellate issues. View "State v. King" on Justia Law

A minor child, who had been in her grandmother’s custody due to her mother’s intellectual disabilities, became the subject of a child in need of assistance (CINA) case after concerns arose about missed medical appointments and poor academic performance. The Department of Social Services petitioned for CINA status, but the juvenile court initially allowed the child to remain with her grandmother under protective supervision. Over time, further review hearings were held, and eventually a magistrate recommended removing the child from her grandmother’s custody. The child and her grandmother objected, leading to a de novo exceptions hearing.At the exceptions hearing, the Circuit Court for Worcester County, sitting as a juvenile court, excluded the child from the hearing over the objection of her counsel, reasoning generally that it was inappropriate for children under 15, especially those with developmental delays, to attend such contested proceedings. The court later removed the child from her grandmother’s custody and placed her with the Department. The Appellate Court of Maryland affirmed the juvenile court, finding no abuse of discretion, and distinguished this case from prior precedent by concluding the juvenile court had considered the child’s due process rights.The Supreme Court of Maryland reviewed the case and held that, although the appeal was moot because the CINA proceedings had been terminated and custody restored to the grandmother, the case presented an issue of public importance warranting review. The Court held the juvenile court violated the child’s procedural due process rights by excluding her from her own CINA hearing without making individualized findings or balancing her due process interests against any potential harm from her presence. The Court articulated a new test requiring courts to make specific findings and narrowly tailor any exclusion of a child party. The judgment of the Appellate Court of Maryland was reversed. View "In re: K.B." on Justia Law

In 2025, the Frederick County Council enacted legislation establishing a Critical Digital Infrastructure (CDI) Overlay Zone, enabling data centers and related infrastructure to be built on a limited portion of county land. The boundaries and zoning designations of the Overlay Zone were later set by Ordinance 26-01-001 (the CDI Ordinance), which included color maps as exhibits to indicate the precise locations and zoning designations. A group of residents, the Frederick County Data Center Referendum Committee, sought to challenge this ordinance by referendum and gathered sufficient signatures for a petition. However, the petition included only black-and-white reproductions of the ordinance’s maps, which did not clearly show the Overlay Zone boundaries or zoning distinctions.The sufficiency of the petition was initially upheld by the Director of the Frederick County Board of Elections, who found it met requirements as to form, though she did not decide whether the ordinance was a proper subject for referendum. Several parties opposed the referendum, arguing in the Circuit Court for Frederick County that the ordinance was not subject to referendum under the County Charter and that the petition was deficient because it did not include a full and accurate reproduction of the ordinance. The circuit court agreed, finding both that the CDI Ordinance was not a “law” subject to referendum under the Charter and that the petition’s reproduction of the ordinance was insufficient due to the lack of accurate color maps.On direct appeal, the Supreme Court of Maryland affirmed the circuit court’s judgment. The Court held that under the Frederick County Charter, zoning ordinances, such as the CDI Ordinance, are not subject to referendum because the Charter intended to maintain pre-Charter limitations on referenda for such ordinances. Additionally, the Court held that the petition was insufficient because it did not contain a full and accurate reproduction of the ordinance, as the black-and-white maps omitted essential information. View "In re: Frederick Cnty. Data Center Referendum" on Justia Law

The case involved an incident in which the respondent was found at the scene of a single-vehicle accident late at night, standing near a crashed vehicle that had veered off a dry roadway and struck a speed limit sign. Law enforcement arriving at the scene observed that the respondent exhibited multiple signs of intoxication, including bloodshot eyes, slurred and lethargic speech, repeated confusion, and inconsistent statements about his actions. The only key to the vehicle was found in his possession, and there was circumstantial evidence linking him to the vehicle’s operation. The owner of the vehicle confirmed that she was not present and that there was only one key.After being charged with several traffic offenses, including driving under the influence and driving while impaired, the respondent was tried by jury in the Circuit Court for Somerset County and convicted on the relevant counts. He appealed, arguing that the evidence was insufficient to prove he was intoxicated at the time he was driving. The Appellate Court of Maryland agreed, reversing the convictions for the alcohol-related offenses on the grounds that the State did not present “specific evidence” directly linking his intoxication to the period of driving, especially given the time gap between when he was last seen and when law enforcement arrived.On review, the Supreme Court of Maryland clarified that the standard for sufficiency of the evidence in all criminal cases is the “no reasonable trier of fact” standard, as set forth in Jackson v. Virginia and reaffirmed in Smith v. State. Applying this standard, the Court held that the State’s evidence—both direct and circumstantial—was sufficient for a rational jury to infer that the respondent drove the vehicle while intoxicated. The Supreme Court of Maryland reversed the judgment of the Appellate Court and reinstated the convictions. View "State v. Palmer" on Justia Law

A Maryland religious corporation sought to reclaim possession of its real property, used as a parsonage, from the individual who had served as its Bishop. The corporation purchased the property for use by the Bishop, and the respondent resided there with permission. After the Church’s Holy Synod defrocked the respondent and removed him as Bishop, the corporation repeatedly asked him to vacate the property. The respondent refused, arguing that the Synod was illegitimate and that his removal was improper, asserting a right to remain as the rightful Bishop.The District Court of Maryland sitting in Prince George’s County dismissed the corporation’s wrongful detainer action, reasoning that resolving the property dispute would require it to determine the legitimacy of the Synod’s actions under church law, which was barred by the ecclesiastical abstention doctrine. The Circuit Court for Prince George’s County affirmed that dismissal, concluding that determining who was entitled to occupy the property required deciding internal church governance issues.The Supreme Court of Maryland reviewed the case and held that the ecclesiastical abstention doctrine does not apply because the dispute can be resolved using neutral principles of Maryland law, without interpreting religious doctrine or governance. The court found that the corporation held legal title to the property, there was no lease or evidence of tenancy, and the respondent occupied the property as a licensee. A license can be revoked at any time, and the corporation had revoked the respondent’s license to occupy the property. Therefore, the Supreme Court of Maryland reversed the lower courts’ decisions and held that the corporation is entitled to judgment on its claim for wrongful detainer. The case was remanded for further proceedings, including determination of damages and attorney’s fees. View "Ertritrean Orth. Tweahdo Diocese v. Sinoda" on Justia Law

A twelve-year-old child was charged with robbery and four related offenses following an incident in Baltimore City, where a victim’s purses were taken and liquid was thrown at her. Robbery, a crime of violence, anchored the juvenile court’s jurisdiction over the child under Maryland’s Juvenile Justice Reform Act, which restricts jurisdiction for children under thirteen except when charged with a violent crime or an act arising from the same incident. At the adjudicatory hearing, the magistrate found the child not involved in robbery but involved in misdemeanor theft, ruling that the timing of the force element was not established for robbery.After this finding, the child moved to dismiss the theft charge, arguing that jurisdiction was lost when the robbery count—the qualifying offense—was not sustained. The magistrate denied the motion, reasoning that jurisdiction attaches at filing and continues regardless of the adjudicatory outcome, following precedent from the Appellate Court of Maryland in In re J.B. The juvenile court proceeded to disposition, finding the child delinquent and imposing probation. The child’s exceptions and renewed motion to dismiss were also denied by a judge of the Circuit Court for Baltimore City.The Supreme Court of Maryland reviewed the case and held that jurisdiction, once attached by an allegation of a qualifying crime, continues until the child turns twenty-one unless terminated by a specific statutory mechanism. The court clarified that jurisdiction over offenses arising out of the same incident is derivative at filing but durable thereafter, unaffected by a not-sustained finding or dismissal of the anchoring violent charge. Additionally, the court rejected the child’s equal protection claim, finding a rational basis for treating children accused of violent crimes differently from those accused only of misdemeanors. The court affirmed the Circuit Court’s decision. View "In re: D.E." on Justia Law

The case involved charges against a defendant for first-degree murder, second-degree murder, voluntary manslaughter, robbery with a dangerous weapon, and related firearms offenses after the shooting deaths of two individuals during a drug transaction. The defendant, who admitted to the shootings but claimed self-defense, was impeached at trial with a prior custodial statement in which he denied any involvement. The statement was made during a late-night, uncounseled custodial interrogation after the defendant was advised of his Miranda rights.At trial in the Circuit Court for Baltimore City, the defendant requested a jury instruction directing the jury to consider the voluntariness of his custodial statement before using it for impeachment. The trial court declined to give this instruction, finding there was no evidence suggesting the statement was involuntary. The jury acquitted the defendant of first- and second-degree murder but found him guilty of voluntary manslaughter, robbery, and several firearms offenses. He was sentenced to 70 years' imprisonment.The defendant appealed to the Appellate Court of Maryland, arguing he was entitled to the voluntariness instruction. The Appellate Court affirmed the conviction, holding that the instruction was not required since the statement was introduced only for impeachment, was exculpatory, and there was no “some evidence” of involuntariness.Upon further review, the Supreme Court of Maryland disagreed with the Appellate Court’s reasoning that the instruction was unnecessary because the statement was used for impeachment or was exculpatory. However, the Supreme Court determined the defendant failed to present “some evidence” that his statement was involuntary, as required to trigger the instruction. The Court also concluded that, even if it was error to deny the instruction, the error was harmless beyond a reasonable doubt given the nature of the evidence and the jury’s verdict. The Supreme Court of Maryland affirmed the judgment of the Appellate Court. View "Shuler v. State" on Justia Law