Justia Maryland Supreme Court Opinion Summaries

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

The decedent died intestate in 2021, leaving no close relatives. The decedent had a stepdaughter, Karen Ellis, who claimed she was equitably adopted by the decedent and sought to inherit his estate. Ellis alleged a father-daughter relationship with the decedent, who had been involved in her life since she was four years old. She claimed the decedent treated her as his daughter, referred to her children as his grandchildren, and made statements indicating she would inherit his estate.The Orphans’ Court for Montgomery County denied Ellis’s initial petition but later allowed her to refile. The court denied a motion for summary judgment by the decedent’s intestate heirs and transmitted seven issues to the Circuit Court for Montgomery County for a jury trial, including whether Ellis was equitably adopted.The Appellate Court of Maryland vacated the Orphans’ Court’s order, holding that a claimant must prove that the decedent intended to treat them as their own child and that the intent element is not necessarily an intent to adopt pursuant to the adoption statute. The court concluded that the orphans’ court should not have transmitted six of the seven issues to the circuit court, as they were factual in nature.The Supreme Court of Maryland reversed the Appellate Court’s judgment, holding that a claimant may establish the right to inherit under the doctrine of equitable adoption by demonstrating clear and convincing proof of the decedent’s intent to adopt and that the decedent acted in accord with that intent. The case was remanded to the Orphans’ Court for Montgomery County for further proceedings based on this standard. View "In re: Estate of Schappell" 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 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 then cashed by the original payees with Badlia. Badlia, unaware of the prior payments, presented the checks for payment, which the State 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 held that the State has waived sovereign immunity for claims by a holder in due course seeking payment on an authorized State-issued check. The court affirmed the decision of the Circuit Court for Baltimore City, concluding that a check is a formal contract and that the State's waiver of sovereign immunity under § 12-201(a) of the State Government Article applies to such contracts. View "Comptroller of Md. v. Badlia Bros." on Justia Law

The case involves a seventeen-year-old named M.Z., who was adjudicated as a child in need of assistance (CINA) by the Circuit Court for Baltimore County due to behavioral issues and her mother's inability to manage her. M.Z. was placed in a therapeutic youth group home and later returned to her mother's custody. The Baltimore County Department of Social Services sought to terminate the CINA case, but M.Z.'s mother objected, citing ongoing behavioral concerns and the need for additional services.The Circuit Court for Baltimore County terminated the CINA case over the mother's objection, finding that the mother could adequately care for M.Z. and that the Department had exhausted its services. The mother appealed to the Appellate Court of Maryland, which dismissed the appeal, holding that the mother was not "aggrieved" by the termination since her custodial rights were restored.The Supreme Court of Maryland reviewed the case to determine whether a parent is entitled to appeal the termination of a CINA case over their objection. The court held that a parent is an "aggrieved party" entitled to appeal if they have not obtained the full relief sought in the juvenile court. The court emphasized that the CINA statute's purpose extends beyond parental rights to include the child's safety and well-being. The court found that the mother's interest in ensuring M.Z.'s safety and receiving necessary services was sufficient to make her an aggrieved party.The Supreme Court of Maryland reversed the judgment of the Appellate Court of Maryland and remanded the case for further proceedings to resolve the merits of the mother's appeal. View "In re M.Z." on Justia Law

In 1992, Abras Sandy Q. Morrison was convicted in the Circuit Court for Carroll County of first-degree murder, kidnapping, robbery, and related conspiracy charges. He was sentenced to life imprisonment without the possibility of parole for first-degree murder, with additional concurrent sentences for the other charges. The prosecutor had filed a notice of intent to seek a life without parole sentence more than thirty days before the trial. The court considered the facts, including Morrison's detailed confession and the pre-sentence report, before imposing the sentence.Morrison's convictions were affirmed by the Appellate Court of Maryland in 1993. He later filed two petitions for postconviction relief, which were denied by the circuit court in 1999. His application for leave to appeal was also denied. In 2023, Morrison filed a pro se petition for postconviction DNA testing under CP § 8-201, seeking to test a hair and a blood-stained towel, claiming the results could produce mitigating evidence regarding his sentence. The circuit court denied the petition without a hearing, and Morrison appealed.The Supreme Court of Maryland reviewed the case and affirmed the circuit court's decision. The court held that there was no reasonable probability that DNA testing of the hair would produce exculpatory or mitigating evidence relevant to Morrison's claim of wrongful sentencing. The court noted that Morrison's detailed confession and other evidence established his participation in the crime, and DNA testing would not negate his culpability. The court concluded that the circuit court did not err in denying the petition for DNA testing. View "Morrison v. State" on Justia Law