Justia Maryland Supreme Court Opinion Summaries

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

A woman was charged with murder and child abuse resulting in the death of her newborn after delivering the baby at home without her husband's knowledge. She claimed the baby was stillborn, while the State argued the baby died of asphyxiation at her hands. The woman had conducted internet searches about terminating her pregnancy months before the delivery and did not seek prenatal care.A jury in the Circuit Court for Howard County convicted the woman of second-degree murder and child abuse resulting in death, sentencing her to 30 years for murder and a concurrent 20 years for child abuse. The Appellate Court of Maryland affirmed the conviction, finding the evidence of internet searches and lack of prenatal care relevant to her intent and motive.The Supreme Court of Maryland reviewed the case to determine the relevance and prejudicial impact of the internet searches and lack of prenatal care. The Court held that the internet searches were irrelevant to show intent to kill or harm a newborn, as contemplating a legal abortion does not support an inference of intent to harm a person. Similarly, the Court found that the decision to forgo prenatal care was not probative of intent to harm a live child, as women forgo prenatal care for various reasons unrelated to criminal intent.The Court reversed the judgment of the Appellate Court and remanded the case to the circuit court for a new trial, emphasizing the need to carefully weigh the probative value against the potential prejudicial effects of such evidence. View "Akers v. State" on Justia Law

The decedent, Michael Gerard Schappell, died intestate in 2021, leaving no close relatives. He had a stepdaughter, Karen Ellis, who had been part of his life since she was four years old. Ellis claimed that she had a father-daughter relationship with the decedent and sought to be recognized as his heir under the doctrine of equitable adoption. She petitioned the Orphans’ Court for Montgomery County to be named the sole heir to the decedent’s estate.The Orphans’ Court denied Ellis’s initial petition but later allowed her to refile. The court then denied a motion for summary judgment filed by other potential heirs and transmitted seven issues to the Circuit Court for Montgomery County for a jury trial, including whether Ellis was equitably adopted by the decedent. The Appellate Court of Maryland vacated the Orphans’ Court’s order, holding that only the issue of equitable adoption should be transmitted to the circuit court, as it involved a mixed question of fact and law.The Supreme Court of Maryland reviewed the case and established a two-step test for equitable adoption. First, a claimant must demonstrate by clear and convincing evidence the decedent’s intent to adopt, which can be shown through an unperformed express agreement or other acts indicating intent. Second, the claimant must show that the decedent acted in accordance with this intent by treating the claimant as a natural or legally adopted child and representing this to the public.The Supreme Court reversed the judgment of the Appellate Court of Maryland and remanded the case to the Orphans’ Court for Montgomery County for further proceedings based on the new standard for equitable adoption. View "In re: Estate of Schappell" on Justia Law

The case involves two homebuyers, Wynton Sanders and Tosha Lindsey, who entered into contracts with SM Landover, LLC and SM Parkside, LLC, respectively, for the purchase of new homes. Both contracts included provisions for deferred water and sewer charges and a one-year statute of limitations for bringing any claims related to the contracts. The homebuyers later filed class action complaints alleging that the sellers failed to disclose required information about the deferred charges, as mandated by Maryland law.The Circuit Court for Prince George’s County consolidated the cases for pretrial purposes and dismissed the complaints with prejudice. The court found that the sellers did not need to register as home builders because Stanley Martin Companies, LLC, a registered home builder, was also a party to the contracts. The court also concluded that the homebuyers’ claims accrued at the time of contracting, making them time-barred under the one-year contractual limitations period.The Appellate Court of Maryland affirmed in part and reversed in part. It held that the one-year contractual limitations period was reasonable and that the homebuyers’ claims accrued at the time of settlement, not contracting. Therefore, the claims were timely. However, the court also held that the sellers did not need to register as home builders because a registered home builder was a party to the contracts.The Supreme Court of Maryland reviewed the case and held that the homebuyers’ claims accrued at the time of contracting. The court also held that the sellers were required to register as home builders under Maryland law, even though a registered home builder was a party to the contracts. Consequently, the sellers could not enforce the one-year contractual limitations period, making the homebuyers’ claims timely. The court affirmed in part and reversed in part the judgment of the Appellate Court of Maryland. View "SM Landover LLC v. Sanders" on Justia Law

The case involves three consolidated appeals concerning the constitutionality of the Child Victims Act of 2023, which retroactively eliminated the statute of limitations for child sexual abuse claims. The plaintiffs, who are alleged survivors of childhood sexual abuse, filed lawsuits against various institutions, including the Roman Catholic Archbishop of Washington, the Board of Education of Harford County, and The Key School, Inc. The defendants argued that the 2023 Act unconstitutionally abrogated their vested rights by reviving claims that were previously time-barred.In the Circuit Court for Prince George’s County, the court denied the Archbishop’s motion to dismiss, determining that the relevant statute was a statute of limitations, not a statute of repose, and thus did not create vested rights. The Circuit Court for Harford County reached a similar conclusion regarding the Board of Education of Harford County. In the United States District Court for the District of Maryland, the court certified the question of the 2023 Act’s constitutionality to the Supreme Court of Maryland without ruling on The Key School’s motion to dismiss.The Supreme Court of Maryland held that the 2017 statute, which the 2023 Act amended, was a statute of limitations rather than a statute of repose. The court reasoned that the statute of limitations is a procedural device that does not create vested rights, whereas a statute of repose creates substantive rights that cannot be retroactively abrogated. The court concluded that the 2023 Act did not retroactively abrogate vested rights and was constitutional as applied to the defendants. The court applied heightened rational basis review and found that the 2023 Act bore a real and substantial relation to addressing the problem of delayed reporting of child sexual abuse and the need for justice for survivors. The judgments of the lower courts were affirmed, and the certified question was answered in the negative. View "Archbishop of Washington v. Doe" on Justia Law

The case involves a proposed charter amendment in Baltimore City, known as the Baby Bonus Amendment, which would mandate a one-time payment of at least $1,000 to every eligible city resident upon the birth or adoption of a child. The Maryland Child Alliance, Inc. sponsored the petition for this amendment, which was certified by the Baltimore City Board of Elections for inclusion on the ballot for the November 2024 Presidential General Election.The Mayor and City Council of Baltimore, along with other city officials, filed a lawsuit in the Circuit Court for Baltimore City against the Baltimore City Board of Elections and the State Board of Elections, seeking judicial review, a writ of mandamus, declaratory judgment, and an injunction to prevent the Baby Bonus Amendment from being placed on the ballot. The circuit court granted the City’s motion for summary judgment, declaring the Baby Bonus Amendment unconstitutional as it violated Article XI-A, § 3 of the Maryland Constitution by removing meaningful discretion from the City over an area within its legislative purview and being legislative in nature rather than proper charter material.The Supreme Court of Maryland reviewed the case and affirmed the circuit court’s decision. The Court held that the Baby Bonus Amendment did not concern the form or structure of government and encroached upon the City’s police or general welfare powers, thus violating Article XI-A, § 3 of the Maryland Constitution. The Court also declined to sever the mandatory payment provision from the amendment, concluding that the dominant purpose of the amendment would not be achieved without the $1,000 payment provision, which abrogated the City’s law-making authority in violation of the Constitution of Maryland. View "Baltimore City Board of Elections v. Mayor and City Council of Baltimore" on Justia Law

Bonnie Campbell, a federal employee, and Michael Campbell, her ex-husband, entered into a divorce property settlement agreement in which Mr. Campbell waived his rights to Ms. Campbell's Thrift Savings Plan (TSP) account. Despite this agreement, Ms. Campbell did not remove Mr. Campbell as the beneficiary of her TSP account before her death. After her death, Mr. Campbell received the balance of the TSP account. The estate of Ms. Campbell (the Estate) sued Mr. Campbell for breach of contract to enforce the terms of the divorce settlement agreement.The Circuit Court for Montgomery County granted summary judgment in favor of the Estate on its breach of contract claim, awarding money damages. The court rejected Mr. Campbell's argument that the Federal Employees’ Retirement System Act of 1986 (FERSA) preempted the Estate's claim. The Appellate Court of Maryland reversed, holding that FERSA preempted the Estate's breach of contract claim.The Supreme Court of Maryland reviewed the case and held that FERSA does not preempt the Estate’s post-distribution breach of contract action. The court found that FERSA’s purposes, which include establishing a federal employee retirement plan and ensuring it is fully funded and financially sound, do not concern plan beneficiaries. The court also noted that FERSA’s provisions elevate the requirements of a qualifying state property settlement agreement over a deceased participant’s designated beneficiary, provided notice is given before payment. The court concluded that a post-distribution suit to enforce contractual obligations in a divorce property settlement agreement does not hinder any governmental interest in administrative convenience or avoiding double payment. The judgment of the Appellate Court was reversed, and the Circuit Court's judgment was affirmed. View "In re Isely" on Justia Law

A group of Baltimore City registered voters, led by Anthony J. Ambridge, filed a petition seeking judicial review of a proposed amendment to the Baltimore City Charter, known as "Question F," which was to appear on the 2024 general election ballot. The petitioners argued that the proposed charter amendment was not proper "charter material" and that the ballot language was not understandable. The Maryland State Board of Elections opposed the petition, arguing that the claims were barred by laches and that the judicial review mechanism used by the petitioners was inappropriate.The Circuit Court for Anne Arundel County ruled in favor of the petitioners, determining that the claims were not barred by laches and could be raised under the judicial review mechanism. The court found that Question F violated Article XI-A of the Maryland Constitution as it was not proper charter material and that the ballot language was not easily understandable by voters. The court ordered that the results of Question F should not be certified.The Supreme Court of Maryland reviewed the case and held that EL § 9-209(a) is not a proper mechanism to challenge whether a proposed charter amendment is proper charter material or whether the ballot language meets the standards for understandability. The Court also held that the petitioners' claims were barred by laches due to the unreasonable delay in filing the petition, which caused prejudice to the State Board, the City, and the electorate. The Court further concluded that the ballot language conveyed, with minimum reasonable clarity, the actual scope and effect of the measure, allowing voters to make an informed choice. The Supreme Court of Maryland reversed the circuit court's order and remanded the case for entry of judgment in favor of the appellants. View "State Bd. of Elections v. Ambridge" on Justia Law

Caruso Builder Belle Oak, LLC entered into a contract with Ronalda Sullivan on July 17, 2015, for the sale of a property in Prince George’s County, Maryland. The property was subject to deferred private water and sewer assessments, and Caruso provided a disclosure that was allegedly noncompliant with Maryland’s Real Property Article § 14-117(a)(3)(i). The parties settled on the contract on February 24, 2016. On February 22, 2019, Sullivan filed a complaint against Caruso seeking monetary penalties under § 14-117(b)(2)(i) for the noncompliant disclosure.The Circuit Court for Prince George’s County dismissed Sullivan’s complaint, ruling that her claim was barred by Maryland’s three-year statute of limitations, which began to run on the date of the contract, July 17, 2015. Sullivan appealed, and the Appellate Court of Maryland reversed the circuit court’s decision, holding that the statute of limitations began to run on the date of settlement, February 24, 2016, making Sullivan’s claim timely.The Supreme Court of Maryland reviewed the case and held that a seller’s violation of § 14-117(a)(3)(i) gives rise to a cause of action because the purchaser suffers an informational harm. The court determined that the statute of limitations began to run on the date of the contract, July 17, 2015, because Sullivan knew or should have known of the noncompliant disclosure at that time. Therefore, her claim filed on February 22, 2019, was barred by the three-year statute of limitations. The Supreme Court of Maryland reversed the Appellate Court’s decision and remanded with instructions to affirm the Circuit Court’s dismissal of Sullivan’s complaint. View "Caruso Builder Belle Oak v. Sullivan" on Justia Law

The case involves Isiah Hollins, who was convicted of second-degree assault following an altercation with Alexander Alvarenga at a McDonald's restaurant in Rockville, Maryland. On November 16, 2021, Hollins, a supervisor, and Alvarenga, an employee, engaged in a fight during which Hollins stabbed Alvarenga multiple times with a knife. Hollins was charged with attempted first-degree murder and related assault charges but argued self-defense, claiming Alvarenga was the initial aggressor due to his violent character.In the Circuit Court for Montgomery County, Hollins sought to introduce evidence of Alvarenga's propensity for violence, including prior assault convictions and past fights, to support his self-defense claim. The trial court denied Hollins's request to cross-examine Alvarenga about a recent unrelated incident and refused to give a non-pattern jury instruction regarding Alvarenga's violent character. The jury acquitted Hollins of attempted first-degree murder and first-degree assault but convicted him of second-degree assault. Hollins was sentenced to ten years in prison, with two years suspended, and five years of probation.Hollins appealed to the Appellate Court of Maryland, which affirmed his conviction. The appellate court agreed that the trial court erred in refusing the jury instruction solely because it was not a pattern instruction but concluded that the evidence did not support the instruction. Hollins then petitioned for a writ of certiorari.The Supreme Court of Maryland reviewed the case and held that the trial court abused its discretion by refusing to consider the requested jury instruction on the basis that it was not a pattern instruction. The court found that there was "some evidence" that Alvarenga had a character trait for violence, which could allow the jury to infer that he was the initial aggressor. The Supreme Court of Maryland reversed the judgment of the Appellate Court and remanded the case for a new trial. View "Hollins v. State" on Justia Law