Justia Maryland Supreme Court Opinion Summaries

Two men were convicted in the Circuit Court for Baltimore City on charges related to the 2019 murder of Donnell Brockington, who was surrounded and fatally shot multiple times by a group of six individuals. After the suspects fled, four, including the two respondents, were apprehended when their vehicle crashed. Police recovered several firearms, and DNA evidence linked both respondents to a Desert Eagle 9mm pistol found in the vehicle. At trial, a State firearms examiner testified that certain ammunition components were fired from that pistol, but neither respondent challenged the reliability of the examiner’s methodology or requested a Daubert hearing.After trial, the Supreme Court of Maryland decided Abruquah v. State, clarifying the limits on firearms identification testimony. The Appellate Court of Maryland reversed the respondents’ convictions on plain-error review, concluding that the firearms examiner’s unqualified testimony was exactly the kind prohibited by Abruquah. Additionally, one respondent challenged the trial court’s decision to close the courtroom during jury deliberations and partially restrict attendance during the verdict, arguing it violated the Sixth Amendment. The Appellate Court found these closures de minimis and rejected the public trial claim.The Supreme Court of Maryland held that the admission of the firearms examiner’s unqualified opinion was not “clear or obvious” error for plain-error review purposes, since the law was unsettled both at trial and on appeal; Abruquah was a case-specific ruling, not a categorical ban on such testimony. The Court also concluded that the courtroom closures were not de minimis but were justified under Waller v. Georgia, given the trial court’s findings of escalating spectator misconduct and concern for juror safety. The Supreme Court reversed the Appellate Court’s judgment on the convictions, affirmed its ruling on the public trial issue, and remanded for further proceedings. View "State v. Thornton" on Justia Law

A landlord operating a multi-family apartment complex in Montgomery County, Maryland, filed a summary ejectment action against a civilian tenant for unpaid rent. The landlord did not possess a residential rental license, as required by county regulations, but claimed exemption from those requirements because the apartment complex was located on land originally acquired by the United States in 1941 for military purposes. The complex primarily housed servicemembers assigned to a nearby military medical center, but also leased to civilians when units were available.The District Court of Maryland sitting in Montgomery County found that the landlord was exempt from local licensure requirements based on correspondence from the county’s housing authority and entered judgment for possession and unpaid rent against the tenant. On appeal, the Circuit Court for Montgomery County reversed, ruling that the landlord was required to obtain a local rental license, at least for units leased to civilians, and vacated the judgment for possession and unpaid rent.The Supreme Court of Maryland reviewed whether the Enclave Clause of the United States Constitution preempted Montgomery County’s licensure requirements for this property. The court held that for the United States to obtain exclusive jurisdiction under the Enclave Clause, the State must consent, cede jurisdiction, and the United States must formally accept that jurisdiction. The record showed that, although the United States acquired title with state consent and cession, there was no evidence that the United States ever formally accepted exclusive jurisdiction as required by federal law at the time of acquisition. Thus, the Enclave Clause did not apply, and the landlord failed to prove exemption from county licensure. The Supreme Court of Maryland affirmed judgment for the tenant, holding that the landlord could not bring a summary ejectment action without demonstrating compliance with, or exemption from, local licensing requirements. View "Ft. Detrick/W. Reed Army Med. Housing v. Wynn" on Justia Law

While incarcerated at the Maryland Correctional Training Center, Michael Young was attacked twice by other inmates, suffering severe injuries. Young alleged that the attacks were the result of negligence by Sergeant Jeremy Wright and Warden Richard Dovey, as well as a broader pattern or practice of unconstitutional conduct by the State of Maryland. He brought suit against Sgt. Wright, Warden Dovey, and the State, claiming negligence and a "Longtin" pattern-or-practice violation. The jury found Wright and Dovey liable for negligence (but not malice or gross negligence) and awarded Young $1,000,000 against each. On the Longtin claim, the jury awarded $2,000,000 against the State.The Circuit Court for Baltimore County entered judgment for Young on all three awards. On appeal, the Appellate Court of Maryland held that, under the Maryland Tort Claims Act (MTCA), the judgments against the individual defendants should be reduced to a combined $800,000, finding two “incidents or occurrences.” The Appellate Court also vacated the Longtin judgment, holding that although such claims may be brought against the State, Young failed to present sufficient evidence.The Supreme Court of Maryland reviewed the case. It held that, under the MTCA, where State personnel commit a tort within the scope of their duties without malice or gross negligence, only the State may be held liable and judgment must be entered against the State, not the individuals. The Court also held that, absent a jury finding of multiple, non-concurrent negligent acts as proximate causes of the injuries, only one “incident or occurrence” could be found; thus, Young’s damages were capped at $400,000. Finally, because Young did not contest the sufficiency of evidence on his Longtin claim, the Court vacated the Appellate Court's discussion on that issue as moot. The Supreme Court reversed in part and vacated in part. View "State v. Young" on Justia Law

A woman brought tort claims against a county board of education, alleging that she was sexually abused by a teacher between 1967 and June 1971 while she was a student. Her lawsuit followed passage of the Child Victims Act of 2023, which eliminated time limitations on claims for child sexual abuse. The board moved to dismiss her suit, asserting that it retained sovereign immunity from tort claims based on conduct predating July 1, 1971, because the General Assembly had not provided a funding mechanism for such claims prior to authorizing boards to purchase liability insurance on that date.The Circuit Court for Wicomico County denied the board’s motion to dismiss. The board sought an immediate appeal, arguing that denial of sovereign immunity was immediately appealable under the collateral order doctrine. The Appellate Court of Maryland dismissed the appeal for lack of jurisdiction. The board then obtained review in the Supreme Court of Maryland.The Supreme Court of Maryland first held that an order denying a motion to dismiss on the basis of complete sovereign immunity is immediately appealable under the collateral order doctrine if it presents a pure legal question and meets other requirements of the doctrine. The court reasoned that sovereign immunity is an immunity from suit itself and that, absent immediate review, an important aspect of that immunity would be irretrievably lost.On the merits, the Supreme Court of Maryland held that the county board retained sovereign immunity for claims based on pre-July 1, 1971 conduct. Even if the General Assembly had retroactively authorized such suits in the Child Victims Act, it had neither appropriated funds nor provided a mechanism for the board to pay judgments for those claims. The court reversed the Appellate Court’s dismissal, directed that the complaint be dismissed without prejudice, and clarified that the claim could be revived if the legislature provides a funding mechanism. View "Bd. of Education v. Sturm" on Justia Law

A debtor in bankruptcy, Scarlett Bowman, challenged the ability of a passive trust, Towd Point Mortgage Trust 2016-4, U.S. Bank National Association, to collect interest and fees on a mortgage loan it held, arguing that Towd was not licensed under the Maryland Mortgage Lender Law. The asset at issue was a residential property subject to a note and deed of trust assigned to Towd, a passive trust that did not originate the loan but simply held it. It was undisputed that Towd was unlicensed, but the parties disputed whether a license was required under the relevant Maryland law.Previously, the United States Bankruptcy Court for the District of Maryland certified questions to the Supreme Court of Maryland, because the issue of whether passive trusts were required to be licensed under the Maryland Mortgage Lender Law had not been settled by any controlling appellate decision. The dispute arose after the Appellate Court of Maryland’s decision in Estate of Brown v. Ward, 261 Md. App. 385 (2024), which held that passive trusts could be required to obtain a license as “credit grantors” under a different statutory scheme (OPEC), but did not address the Mortgage Lender Law itself. Following Brown and regulatory guidance, the state’s financial regulator attempted to require licensure of passive trusts for all mortgage loans. In response, the Maryland General Assembly enacted the Maryland Secondary Market Stability Act of 2025 to clarify that passive trusts were exempt from licensure under the Mortgage Lender Law.The Supreme Court of Maryland held that the Maryland Mortgage Lender Law did not require passive trusts to obtain a mortgage lender license before the effective date of the Secondary Market Stability Act. Brown did not interpret or change the Mortgage Lender Law’s requirements. Because passive trusts were never subject to the law’s licensing requirement, the subsequent legislative exemption was a clarification rather than a restoration or retroactive change. The court answered the certified question in the negative and did not reach the remaining questions. View "In re: Bowman" on Justia Law

A lender initiated a foreclosure action against a church and a related entity concerning certain real property in Baltimore City. The church and the related entity, as borrowers, argued that the lender had previously forgiven the debt and that a recorded mortgage was maintained only to protect the church from other creditors, not to reflect a genuine obligation. The borrowers further alleged that the lender’s right to foreclose was based on fraud, claiming that the underlying note either was satisfied or never reflected a true loan. Before the scheduled foreclosure sale, they raised these defenses in a motion, and a merits hearing was scheduled; the court stayed the sale pending that hearing, provided the borrowers obtained property insurance and posted a bond.The borrowers failed to timely obtain the required insurance, resulting in dissolution of the stay. The lender rescheduled the sale, and the borrowers did not appeal the dissolution, move to reinstate the stay after allegedly securing insurance, or request a hearing before the sale. The sale proceeded, and the lender bought the property. In post-sale exceptions, the borrowers repeated their fraud-based defenses and added a new fraud allegation. The Circuit Court for Baltimore City overruled these exceptions, finding they could not be raised post-sale, and ratified the sale. On appeal, the Appellate Court of Maryland reversed, holding the borrowers could assert their fraud claim after the sale, particularly since the lender was the purchaser and the fraud concerned the validity of the lien.The Supreme Court of Maryland reversed the Appellate Court, holding that a borrower who knows or reasonably should know of a defense to foreclosure—such as fraud or lien invalidity—must raise it before the foreclosure sale under Maryland Rule 14-211. Such defenses cannot be raised as post-sale exceptions if they were or should have been raised earlier, regardless of the purchaser’s identity. The Court also clarified the borrower’s options when a stay is dissolved for failure to meet conditions but held the lower court was not required to reschedule the merits hearing on its own initiative. The case was remanded for further proceedings on other issues. View "Hallam v. New Life Evang. Baptist Church" on Justia Law

A man was charged with multiple counts of distributing and possessing child pornography based on evidence linking his internet activity and social media account to illegal transmissions. The investigation began after the National Center for Missing and Exploited Children reported that child sexual abuse material was sent from a particular Kik account associated with an IP address. Police obtained records from Verizon, which identified the defendant as the subscriber of that IP address at a specific home address, and from Kik, which provided chat logs and a legend explaining their format. At trial, a detective explained these records, identifying images and matching file transmissions to the defendant’s account and home IP address. The detective also described, using the legend, how to read the chat logs, and discussed the nature of IP addresses.The Circuit Court for Anne Arundel County admitted the Verizon and Kik records as business records and allowed the detective’s testimony as lay testimony. The defendant was convicted on multiple counts and sentenced to a lengthy term of incarceration, with some time suspended. On appeal, the Appellate Court of Maryland affirmed, relying on prior cases to hold that the detective’s explanations were within the understanding of an average layperson and did not require expert qualification.The Supreme Court of Maryland reviewed whether the trial court erred by admitting the detective’s testimony as lay rather than expert testimony. The court held that testimony about the contents of the Verizon records and reading the Kik logs with the legend was properly admitted as lay testimony, as the inferences were within common knowledge. However, the court found that testimony distinguishing between types of IP addresses and describing one as “static” required expert qualification but concluded the error was harmless beyond a reasonable doubt. The Supreme Court of Maryland affirmed the judgment. View "Jun v. State" on Justia Law

An infant, K.B., was removed from her mother’s care after a police officer witnessed the mother acting abusively toward K.B. and expressing suicidal thoughts. The Baltimore County Department of Social Services filed a petition alleging K.B. was a child in need of assistance (CINA) due to abuse, neglect, and the mother’s history of mental health issues and prior terminations of parental rights. At the adjudication and disposition hearing, the Circuit Court for Baltimore County declared K.B. a CINA, committed her to the Department’s custody, and established supervised visitation. The court’s order included a standard notice that the permanency plan of reunification could later be changed.At a subsequent initial review hearing, the Department recommended changing K.B.’s presumptive plan of reunification to a concurrent plan of reunification and adoption. A magistrate adopted this recommendation, and the juvenile court overruled the mother’s exceptions, ordering the concurrent plan. The mother appealed. The Appellate Court of Maryland reversed, holding that the juvenile court had improperly established a permanency plan before the required permanency plan hearing and without considering the statutory factors or providing proper notice.The Supreme Court of Maryland reviewed whether the juvenile court could change the permanency plan at the initial review hearing. It held that the presumptive plan of reunification established at disposition is not a permanency plan as defined by Maryland law. The court ruled that a permanency plan must be determined at a hearing that complies with statutory requirements, including consideration of specific factors and provision of reasonable notice to all parties about the date, time, and purpose of the hearing. The court affirmed the Appellate Court’s judgment and remanded the case for proper proceedings. View "In re: K.B." on Justia Law

On the morning of November 8, 2022, a motor vehicle collision occurred in Gaithersburg, Maryland, in which the petitioner fatally struck two pedestrians. Law enforcement arrived at the scene around 7:30 a.m. and informed the petitioner that he was not free to leave. He was placed in the back of a police cruiser at 7:43 a.m., where he remained for slightly over an hour while officers investigated the incident. A Drug Recognition Expert (DRE) arrived at 8:51 a.m., detected signs of alcohol impairment, and conducted field sobriety tests. The petitioner was formally arrested at 9:13 a.m. and transported to the police station for a breath test at 10:15 a.m., which revealed an alcohol concentration of 0.24. He was indicted on ten counts related to the collision and ultimately convicted on all counts based on an agreed statement of facts.The Circuit Court for Montgomery County denied the petitioner’s motions to suppress evidence, finding that the investigatory detention did not transform into a de facto arrest and that the breath test was conducted within the statutory two-hour window after apprehension, as defined in Willis v. State. The court found that reasonable suspicion existed for the detention, and no forceful tactics were used by officers. The Appellate Court of Maryland affirmed these rulings, agreeing that the detention was reasonable and that the breath test results were admissible under Maryland law.The Supreme Court of Maryland reviewed the case and affirmed the Appellate Court’s judgment. It held that placing an individual in a police cruiser for a reasonable period during a swiftly developing investigation does not per se convert a lawful investigatory detention into a de facto arrest. The Court further held that “apprehension” for purposes of Maryland’s two-hour breath test statute occurred at 8:51 a.m., when police had reasonable suspicion and acted on it; thus, the breath test at 10:15 a.m. was timely and admissible. View "Singh v. State" on Justia Law

A woman developed mesothelioma and lung cancer, allegedly due to exposure to asbestos dust brought home on her husband’s work clothing. Her husband, a professional insulator, installed asbestos-containing insulation on turbines manufactured by a defendant company at a Maryland power plant in the 1960s. Facilities for workers to shower or change at the worksite were not provided, so he regularly brought dusty work clothes home. The woman, who never visited the worksite, handled and laundered these clothes, potentially exposing herself to asbestos fibers. After her death, her estate continued the personal injury and wrongful death action against the manufacturer and others.The Superior Court of the District of Columbia initially granted summary judgment to the defendant on all claims, including strict liability for design defect. On appeal, the District of Columbia Court of Appeals vacated the summary judgment concerning the design defect claim and remanded the case. Following further proceedings, the Superior Court again granted summary judgment in favor of the defendant, finding that as a bystander, the plaintiff could not recover on a strict liability theory. This led to a second appeal, after which the District of Columbia Court of Appeals certified to the Supreme Court of Maryland the question of whether, under Maryland law, a household member exposed to asbestos dust brought home by a worker must prove an additional element of duty in a strict liability design defect claim.The Supreme Court of Maryland held that a household member in the plaintiff’s position is not required to prove the additional element of duty beyond the four elements of strict liability for design defect as set forth in Phipps v. General Motors Corp. The court clarified that, unlike failure to warn and negligence claims, duty is not a required element for strict liability design defect claims, whether for users, consumers, or household members exposed through no fault of their own. View "Quinn v. General Electric Co." on Justia Law