Justia Maryland Supreme Court Opinion Summaries

Eric Shapiro founded Hyperheal Hyperbarics, Inc., a medical provider offering hyperbaric oxygen therapy and wound care. He served as a director, controlled day-to-day operations, and was employed as a certified HBOT technician. Hyperheal's charter required indemnification for directors and officers to the fullest extent permitted by Maryland law. Hyperheal sued Shapiro, alleging misconduct that led to significant financial losses. The claims included intentional misrepresentation and common law indemnification, asserting that Shapiro breached fiduciary duties as a director and engaged in improper conduct to increase profits.The Circuit Court for Baltimore County dismissed Shapiro's indemnification claim on summary judgment, concluding that the corporation's claims were based solely on his actions as an employee, not as a director. The Appellate Court of Maryland reversed this decision, finding that the allegations implicated Shapiro's fiduciary duties as a director, thus triggering indemnification under the statute. The Appellate Court held that the claims bore a sufficient nexus to Shapiro's status as a director.The Supreme Court of Maryland affirmed the Appellate Court's judgment. The court held that the indemnification required under subsection 2-418(d) of the Corporations and Associations Article applies when a director is sued "by reason of service" in his capacity as a director and prevails. The court determined that the requisite nexus requirement is established if any of the factual allegations, causes of action, or legal theories implicate the individual's role or status as a director. Therefore, Shapiro was entitled to indemnification for his legal expenses incurred in defending the lawsuit. View "Hyperheal Hyperbarics v. Shapiro" on Justia Law

Jamie Wallace was biking home from work through the promenade part of the Inner Harbor Park in Baltimore when her bike’s front tire became wedged in a gap between the bricks and granite bulkhead, causing her to fall and sustain injuries. She sued the Mayor and City Council of Baltimore for negligence, alleging the City failed to warn of the gap. The City sought judgment under the Maryland Recreational Use Statute, arguing it owed no duty of care as the promenade was designated for recreational purposes and biking is a recreational activity.The Circuit Court for Baltimore City denied the City’s motion for summary judgment, ruling the statute did not apply because Wallace was commuting, not engaging in recreational activity. The court also denied the City’s motions for judgment during the trial and judgment notwithstanding the verdict after the jury awarded Wallace $100,000 in compensatory damages. The Appellate Court of Maryland affirmed, concluding the promenade functioned primarily as a public pedestrian walkway and shared bicycle path, not a recreational facility, and the statute did not abrogate the City’s common law duty.The Supreme Court of Maryland reviewed the case and held that the Maryland Recreational Use Statute did not shield Baltimore City from liability. The court determined that by incorporating the promenade into its transportation infrastructure, the City established an independent right of access separate from any recreational invitation and assumed the corresponding common law duties. The judgment of the Appellate Court was affirmed, and the City was not protected by the Recreational Use Statute in this instance. View "Mayor of Baltimore v. Wallace" on Justia Law

James Russell Trimble, who was convicted of first-degree murder and other crimes committed when he was 17 years old, filed a motion for a reduction of his sentence under Maryland's Juvenile Restoration Act (JUVRA). This act allows individuals convicted as minors and who have served at least 20 years to seek a sentence reduction. Trimble argued that his age at the time of the offense and his rehabilitation efforts warranted a reduced sentence.The Circuit Court for Baltimore County denied Trimble's motion, finding that his age at the time of the crime did not support a sentence reduction, and that he continued to pose a danger to the public. The court also did not credit the testimony of Trimble's expert, who argued that Trimble's antisocial personality disorder (ASPD) had remitted. The court emphasized the brutal nature of the crime and the lasting impact on the victim's family.The Appellate Court of Maryland affirmed the circuit court's decision, holding that the circuit court did not abuse its discretion. The appellate court found that the circuit court had adequately considered all the required factors under JUVRA, including Trimble's age, rehabilitation efforts, and expert testimony. The appellate court also noted that the circuit court was not required to give special consideration to any particular factor, including rehabilitation.The Supreme Court of Maryland reviewed the case and affirmed the lower courts' decisions. The court held that under JUVRA, the circuit court has broad discretion to determine whether an individual is a danger to the public and whether the interests of justice will be served by a reduced sentence. The court is required to consider ten enumerated factors but is not required to give special consideration to any particular factor. The Supreme Court found that the circuit court had properly exercised its discretion in denying Trimble's motion for a reduced sentence. View "Trimble v. State" on Justia Law

Plaintiffs, limited liability companies, filed class action lawsuits in the United States District Court for the District of Maryland seeking relief under the Medicare Secondary Payer (MSP) provisions. These provisions make Medicare a secondary payer when a beneficiary has other insurance coverage. Plaintiffs obtained assignments from Medicare Advantage Organizations and other secondary payers to seek reimbursement from primary payers like the defendants, Government Employees Insurance Company and its affiliates (GEICO). Plaintiffs had no preexisting interest in the claims and were compensated on a contingency basis.The United States District Court for the District of Maryland denied GEICO's motion to dismiss the case, which argued that the assignments were void as against Maryland public policy based on the doctrines of maintenance, champerty, and barratry. The court found no clear statement of Maryland law on this issue and certified questions to the Supreme Court of Maryland.The Supreme Court of Maryland held that Plaintiffs did not violate Maryland’s barratry statute, which prohibits soliciting another person to sue for personal gain without an existing relationship or interest. Plaintiffs did not solicit secondary payers to file lawsuits but obtained the right to sue in their own names through assignments. The court also held that the common law doctrines of maintenance, champerty, and barratry, to the extent they still apply, do not invalidate Plaintiffs’ assignments. The court concluded that the assignments are not void as against public policy and did not address the enforceability of choice-of-law provisions in the agreements. View "GEICO v. MAO-MSO Recovery II" on Justia Law

Amondre Clark filed a successful petition for writ of habeas corpus after several of his convictions were vacated on October 20, 2023. The Division of Correction did not execute the next valid sentences and apply credit for time served under the vacated convictions. Instead, the Division tolled his next valid consecutive sentences, waiting to see if the State’s reprosecution would result in a new conviction. On April 17, 2024, Clark pled guilty to one charge and was sentenced to a new "time served" sentence. However, the Division did not release him, treating the new sentence as a "replacement sentence" for one of the vacated sentences and tacking on the consecutive sentences it had tolled.Clark filed a petition for habeas relief in the Circuit Court for Baltimore City, arguing that the Division incorrectly interpreted CP § 6-218(c) and (d). The habeas court agreed, ordering his immediate release. The Division appealed to the Appellate Court of Maryland, but the Supreme Court of Maryland granted Clark’s petition for a writ of certiorari.The Supreme Court of Maryland held that under CP § 6-218(d), when a criminal defendant’s term of confinement consists of multiple sentences and one or more convictions underlying those sentences is vacated, the defendant is entitled to receive credit for time served when the conviction is vacated, commencing on the date of the first invalidated sentence. The court also held that if a defendant is reprosecuted or retried and a new conviction results, CP § 6-218(c) applies to any leftover credit after credit has been given under CP § 6-218(d). The new sentence should be in last place in a chain of consecutive sentences, and the sentencing judge may make the new sentence consecutive or concurrent to any then-existing sentences.The court vacated the judgment of the habeas court and remanded the case to the habeas court with instructions to vacate the sentence entered on April 17, 2024, and remand the matter to the sentencing court to exercise its discretion with a full understanding of the status of the valid sentences. View "Bivens v. Clark" on Justia Law

Copinol Restaurant, Inc. ("Copinol") and 26 North Market LLC ("North Market") entered into a commercial lease agreement for a property in Frederick, Maryland, with a term ending on March 31, 2032. Copinol failed to pay rent on time in May 2023, prompting North Market to terminate the lease and demand that Copinol vacate the premises. When Copinol did not vacate, North Market filed a tenant holding over action in the District Court of Maryland, seeking possession of the property and damages.The District Court of Maryland ruled in favor of North Market, granting it possession of the property. Copinol appealed to the Circuit Court for Frederick County, which initially ruled in Copinol's favor, stating that the tenant holding over statute did not apply because the lease had not expired. However, after North Market filed a motion to alter or amend the judgment, the circuit court reversed its decision and affirmed the District Court's judgment, awarding possession to North Market.Copinol then filed a petition for writ of certiorari, which the Supreme Court of Maryland granted. The Supreme Court of Maryland held that the tenant holding over statute, RP § 8-402, does not apply where a tenant is in possession of property pursuant to a lease that has not expired by lapse of time. The Court further held that a landlord cannot contractually modify the statutory meaning of the phrase "expiration of a lease" to avail itself of the tenant holding over statute in a manner inconsistent with its plain language. The Court reversed the circuit court's judgment and remanded the case for entry of judgment in favor of Copinol. View "Copinol Restaurant v. 26 N. Market" on Justia Law

Dallas Fenton was convicted of multiple sexual offenses against a fourteen-year-old child, including eight counts of third-degree sexual offense, one count of sexual solicitation of a minor, and one count of indecent exposure. He was sentenced to ten years for one of the third-degree sexual offenses (Count 1) and another ten years for a different third-degree sexual offense (Count 8), to be served consecutively.The Division of Correction (DOC) informed Fenton that he would not receive diminution of confinement credits for the sentence on Count 8 because he had been previously convicted of a similar offense (Count 1). Fenton's grievance with the Inmate Grievance Office (IGO) was dismissed, and the Circuit Court for Washington County partially granted and partially denied his petition for judicial review, ruling that he was entitled to good conduct credits but not other types of diminution credits for Count 8.The Appellate Court of Maryland held that Fenton was not prohibited from accruing diminution credits for Count 8, as the statute only applied if the previous conviction occurred before the commission of the offense for which the sentence was being served. The court vacated the circuit court's judgment and remanded the case for recalculation of Fenton's credits.The Supreme Court of Maryland affirmed the Appellate Court's decision, holding that under Md. Code Ann., Corr. Servs. § 3-702(c), diminution credits are precluded only if the offense was committed after a previous conviction for the same offense. The court concluded that Fenton was entitled to diminution credits for Count 8, as he had not been "previously convicted" at the time of the offense. View "Dept. of Pub. Saf. & Corr. Serv. v. Fenton" on Justia Law

Janice Hollabaugh authorized her attorney to request her medical records from a health care provider for a personal injury claim. The provider contracted with MRO Corporation to fulfill the request. MRO sent a "Cancellation Invoice" to Hollabaugh’s attorney, stating that the request was canceled and charged a $22.88 fee for searching for the records, even though no records were produced. Hollabaugh reimbursed her attorney for the fee and subsequently filed a class action lawsuit against MRO, alleging that the fee violated the Confidentiality of Medical Records Act.The Circuit Court for Baltimore County determined that Hollabaugh had standing but concluded that the Act authorized MRO’s fee, leading to the dismissal of the case. The Appellate Court of Maryland affirmed the standing decision but also upheld the fee's authorization under the Act. Hollabaugh then petitioned the Supreme Court of Maryland, which granted certiorari to review the case.The Supreme Court of Maryland held that Hollabaugh had standing to sue because she reimbursed her attorney for the fee, creating a reasonable inference of injury. The Court further held that the Confidentiality of Medical Records Act does not permit a health care provider to charge a preparation fee for a search that does not result in the production of any medical records. The Court reasoned that the statutory language and context imply that fees are only authorized for the retrieval and preparation of existing records. Consequently, the Court affirmed the lower court's decision on standing but reversed the decision regarding the fee's authorization, remanding the case for further proceedings consistent with its opinion. View "Hollabaugh v. MRO Corporation" on Justia Law

In this case, the Prince George’s County Council, sitting as the District Council, engaged in a 2009 comprehensive rezoning process known as a sectional map amendment for subregions 5 and 6. Several property owners, including Christmas Farm and MCQ Auto Servicenter, were affected by this rezoning. Christmas Farm sought a more intensive zoning classification but failed to file the required ethics affidavit. MCQ’s property was downzoned, but MCQ successfully petitioned for a revisory petition, resulting in the restoration of its original zoning classification.The Circuit Court for Prince George’s County and the Appellate Court of Maryland reviewed the zoning decisions multiple times, resulting in several remands to the District Council. The courts found that the District Council failed to comply with procedural requirements, including the failure to provide notice and an opportunity to be heard. The most recent remand occurred in 2019, where the District Council adopted sectional map amendments without holding a public hearing or notifying the affected property owners.The Supreme Court of Maryland reviewed whether a 2021 countywide rezoning constituted a substantive change in the law that rendered moot the property owners' assertions of error from the 2019 proceeding. The Court also examined whether the District Council erred in failing to provide notice and an opportunity to be heard and whether it complied with the Appellate Court’s prior remand order.The Supreme Court of Maryland held that the 2021 countywide rezoning was not a comprehensive rezoning or a substantive change in the law that rendered the property owners' assertions moot. The rezoning was a technical mapping exercise intended to align zoning classifications with the new zoning ordinance. The Court also held that the District Council failed to comply with state and local laws requiring notice and a public hearing and did not follow the Appellate Court’s remand instructions. The judgment of the Appellate Court was affirmed, and the case was remanded for further proceedings consistent with the opinion. View "County Council of Prince George's County. v. Robin Dale Land LLC" on Justia Law

Estefany Martinez, a former Amazon employee, worked as a Fulfillment Associate at the Baltimore Fulfillment Center from June 2017 to November 2021. She and other employees were required to clock out before undergoing a post-shift security screening process, for which they were not compensated. Martinez brought a backpack into the work area, which required her to use the bag scan lane during the security screening, often resulting in delays. Data showed that the time taken to exit the facility after clocking out varied, with some instances exceeding five minutes.Martinez filed a lawsuit against Amazon in the Circuit Court for Baltimore City, which was later removed to federal court. The United States District Court for the District of Maryland certified a question to the Supreme Court of Maryland regarding the applicability of the de minimis doctrine to claims under the Maryland Wage Payment and Collection Law and the Maryland Wage and Hour Law. The district court granted Martinez’s Motion for Class Certification and stayed the case pending the resolution of the certified question.The Supreme Court of Maryland held that the de minimis doctrine, as described in Anderson v. Mt. Clemens Pottery Company, applies to claims brought under the Maryland Wage and Hour Law and the Maryland Wage Payment and Collection Law. The court concluded that the doctrine, which disregards negligible periods of work time, is consistent with the legislative intent of the Maryland Wage Laws, which are patterned after the Fair Labor Standards Act. The court answered the certified question in the affirmative, confirming that the de minimis rule applies to the Maryland Wage Laws. View "Martinez v. Amazon" on Justia Law