Justia Maryland Supreme Court Opinion Summaries

The case involved a defendant who was charged with attempted first-degree murder and related offenses in the Circuit Court for Montgomery County, Maryland. Before trial, both the defense and prosecution jointly requested a postponement of the trial date due to the resignation of the defendant’s public defender and the need for additional preparation time. During a status hearing, the defendant’s newly assigned counsel informed the court that the defendant wanted to represent himself and keep the original trial date. The matter was referred to the administrative judge, who questioned the defendant about his wishes. The defendant responded that he wanted an attorney but did not want the trial postponed, emphasizing his desire for a speedy trial and expressing frustration about his continued incarceration.After this exchange, the administrative judge postponed the trial date, and the defendant did not further request to discharge counsel or to represent himself. At trial, the defendant was represented by counsel and was convicted by a jury of attempted second-degree murder, armed robbery, and use of a firearm in the commission of a felony or crime of violence. The Appellate Court of Maryland affirmed the conviction, finding that the defendant had not expressed a present intent to discharge counsel or to represent himself, and that the trial court had provided an adequate opportunity for the defendant to clarify his wishes.The Supreme Court of Maryland reviewed whether the trial court violated the defendant’s constitutional and procedural rights by not conducting further inquiry into his alleged request for self-representation. The Supreme Court held that when a court is informed that a defendant may wish to represent himself, it must conduct a reasonable inquiry to determine if the defendant clearly and unequivocally asserts that right and must allow the defendant to explain his reasons for discharging counsel under Maryland Rule 4-215(e). However, if the defendant does not express a clear desire for self-representation or to discharge counsel, the court is not required to question him further. The Supreme Court affirmed the lower court’s judgment. View "Goodrich v. State" on Justia Law

A woman who receives a housing voucher due to her disability applied to rent an apartment in a complex owned by a property management company. The monthly rent for the unit was $1,590, and her voucher would have covered $1,464, leaving her responsible for $126 per month. Her only other income was $841 per month in supplemental security income. The property owner applied its standard policy, requiring all applicants to demonstrate monthly income at least 2.5 times the full rent, aggregating all sources of income, including voucher subsidies. The applicant’s combined income and voucher fell short of the $3,975 threshold, so her application was denied.After the Maryland Commission on Civil Rights found no probable cause for her discrimination claim, the applicant sued in the Circuit Court for Baltimore County, alleging that the owner’s minimum-income requirement constituted impermissible source-of-income discrimination under Maryland’s Housing Opportunities Made Equal (HOME) Act, which prohibits discrimination based on “source of income” in housing. The owner moved for summary judgment, arguing its policy was facially neutral and applied equally to all sources of income. The circuit court granted summary judgment to the owner, finding that the policy did not discriminate based on the source of income, only the amount.On appeal, the Supreme Court of Maryland reviewed the case. The Court agreed with the circuit court that the owner was entitled to summary judgment on the disparate treatment claim, as the policy was facially neutral and applied equally. However, the Supreme Court of Maryland held that the owner was not entitled to summary judgment on the disparate impact claim. The Court explained that a facially neutral policy may still violate the HOME Act if it disproportionately affects voucher holders without a legitimate business justification. The judgment of the circuit court was vacated and the case remanded for further proceedings. View "Hare v. David S. Brown Enterprises" on Justia Law

Erica Hall and Nicholas Houser married in 2012 and have one minor child, C.H., born in 2018. In 2020, both parties sought an absolute divorce. On the trial day, they presented agreements to the Circuit Court for Anne Arundel County, including one to waive child support and arrears. The court requested justification for this waiver, but the parties only argued their fitness as parents and their constitutional rights. The court found the waiver in the parents' best interest, not the child's, and ordered Mr. Houser to pay child support and arrears to Ms. Hall, who had primary custody of C.H.The Appellate Court of Maryland affirmed the circuit court's decision, rejecting the parents' agreement regarding child support and upholding the child support and arrears order. Both parties then petitioned the Supreme Court of Maryland.The Supreme Court of Maryland held that parents cannot waive the issue of child support because it is a legal obligation, and the right to receive support belongs to the child, not the parents. The court also held that a parent's fundamental right to determine the care, custody, and control of their children does not include waiving child support, as it is a parental obligation. The court found that the trial court did not abuse its discretion in rejecting the parents' agreement to waive child support, as the parties failed to provide sufficient justification for the waiver. The Supreme Court of Maryland affirmed the judgment of the Appellate Court, maintaining the child support and arrears order. View "In re: Marriage of Houser" on Justia Law

A farm in Talbot County, Maryland, was the subject of nuisance complaints from neighboring residents due to offensive odors and swarms of insects. The farm, owned by Arthur L. Foster, Sr., and later managed by his son, Arthur L. Foster, Jr., began receiving Class A biosolids and soil conditioners from Denali Water Solutions in January 2021. These materials were stored and applied to the farm, causing strong, foul odors and a midge infestation, which led to numerous complaints from nearby residents.The Talbot County Agricultural Resolution Board (the Board) conducted an investigation and held hearings to determine whether the practices at the farm were generally accepted agricultural practices under Talbot County's Right to Farm (RTF) law, Chapter 128 of the Talbot County Code (TCC). The Board found that the application and stockpiling of the materials were generally accepted agricultural practices and issued recommendations to mitigate the odor.The Circuit Court for Talbot County reversed the Board's decision, finding that the agricultural operations on the farm had not been in existence for one year or more when the complaints were filed, as required by Maryland's RTF law, Md. Code Ann., Cts. & Jud. Proc. § 5-403. The court remanded the case to the Board with instructions to find that the operations did not benefit from protection under the RTF laws.The Appellate Court of Maryland reversed the Circuit Court's decision, holding that the expanded use of soil conditioners and biosolids at the farm was a protected activity under both the state and county RTF laws. The court found substantial evidence supporting the Board's decision that the practices were generally accepted agricultural practices and did not violate public health, safety, and welfare.The Supreme Court of Maryland reversed the Appellate Court's decision, holding that the Board's findings were not supported by substantial evidence. The court found that the Board failed to make necessary findings regarding the public health, safety, and welfare impacts of the practices and did not adequately consider whether the stockpiling of materials for use at other locations was a generally accepted agricultural practice. The case was remanded for further proceedings consistent with the Supreme Court's opinion. View "In re: Foster Farm" on Justia Law

Jamal Antoine Williams was charged with promoting a criminal organization after standing watch while a gang leader spray-painted a gang-related message on public property and posing for pictures in front of the graffiti. The criminal organization in question was the Rollin 30s Crips, a set of the transnational gang known as the Crips. Williams admitted to previous membership in the Crips and was identified as a participant in the graffiti incident through video surveillance and social media posts.In the Circuit Court for Montgomery County, Williams waived a jury trial and pled not guilty with an agreed statement of facts. The court found him guilty of promoting a criminal organization under CR § 9-805 and sentenced him to five years’ incarceration, with all but six months suspended, followed by supervised probation. Williams appealed, and the Appellate Court of Maryland affirmed his conviction, interpreting "promote" broadly to include his actions.The Supreme Court of Maryland reviewed the case and held that CR § 9-805 is a general intent crime, requiring the State to prove that the defendant knew the organization was a "criminal organization" as defined by the statute. The court further held that the statute applies only to individuals who exercise a leadership role in the criminal organization or, if not members, exercise discretionary authority in connection with the act of promotion. The court found that the evidence was insufficient to prove that Williams had a leadership role or exercised discretionary authority in the gang. Consequently, the Supreme Court of Maryland reversed the conviction and directed the lower court to enter a judgment of acquittal. View "Williams v. State" on Justia Law

A former Baltimore police officer, Christopher Nguyen, was charged with reckless endangerment for failing to prevent an assault on Wayne Brown by Kenneth Somers. Nguyen arrived at the scene to find Brown injured and Somers admitting to the assault. While Nguyen was investigating, Somers kicked Brown in the head. Nguyen was charged for not preventing this spontaneous assault.In the Circuit Court for Baltimore City, Nguyen was convicted of reckless endangerment after a bench trial. The court found that Nguyen had a duty to protect Brown and that his failure to prevent the assault was a gross departure from the standard of conduct expected of a reasonable officer. The Appellate Court of Maryland affirmed the conviction, holding that Nguyen had a duty to protect Brown as a member of the public and that his conduct constituted reckless endangerment.The Supreme Court of Maryland reviewed the case. The court held that the State failed to prove that Nguyen had a legal duty to protect Brown from an unforeseeable assault by Somers. The court noted that the common law duties of police officers do not extend to protecting individuals from spontaneous and unforeseeable assaults by third parties. Additionally, the court found that the State did not establish a special relationship between Nguyen and Brown that would create a duty to protect. Consequently, the Supreme Court of Maryland reversed the judgment of the Appellate Court, finding that the State did not meet its burden of proving a legal duty under the circumstances. View "Nguyen v. State" on Justia Law

Henry Walters bequeathed the Walters Art Gallery, adjacent property, and all their contents to the Mayor and City Council of Baltimore in 1931. The City established a board of trustees to manage the assets, and in 1933, the General Assembly incorporated the Trustees of the Walters Art Gallery as an educational corporation with full control over the property. The Board has since operated the Walters Art Gallery, now known as the Walters Art Museum, for public benefit.The Circuit Court for Baltimore City ruled in favor of the plaintiffs, Walters Workers United and AFSCME, who sought to compel the Board to produce records under the Maryland Public Information Act (MPIA). The court concluded that the Board was a governmental instrumentality subject to the MPIA. The Appellate Court of Maryland affirmed this decision, emphasizing the Board's public purpose, City ownership of the property, and financial support from the City.The Supreme Court of Maryland reviewed the case and reversed the lower courts' decisions. The Court held that the Board is not a governmental unit or instrumentality under the MPIA. The Court emphasized the Board's operational independence, its fiduciary role in carrying out a private donor's charitable intent, and the lack of substantial City control over its operations. The Court concluded that the Board's relationship with the City does not make it a governmental instrumentality subject to the MPIA. The case was remanded to the Appellate Court of Maryland with instructions to remand to the Circuit Court for further proceedings consistent with this opinion. View "Walters Art Gallery v. Walters Workers United" on Justia Law

Everett Robinson was transferred to Canton Harbor Healthcare Center, a skilled nursing facility, for follow-up care after a stroke. During his stay, he developed pressure ulcers, which allegedly worsened after his transfer to other facilities, leading to his death. Felicia Robinson, his widow, and his surviving children filed a complaint against Canton Harbor, alleging negligence in allowing the pressure ulcers to develop and worsen, causing his wrongful death. They submitted a certificate of a qualified expert, signed by registered nurse Anjanette Jones-Singh, attesting that Canton Harbor breached the standard of care, causing the pressure ulcers.The Circuit Court for Baltimore City dismissed the complaint, ruling that as a registered nurse, Jones-Singh was not qualified to attest to the proximate cause of Robinson's pressure ulcers. The Robinsons appealed, and the Appellate Court of Maryland vacated the dismissal, holding that a registered nurse is not disqualified per se from attesting that a breach of nursing standards proximately caused pressure ulcers. The case was remanded for further proceedings.The Supreme Court of Maryland affirmed the Appellate Court's judgment. The court held that a registered nurse may attest in a certificate that a breach of nursing care standards at a skilled nursing facility proximately caused a pressure ulcer, provided the nurse relies on a pre-existing diagnosis and does not make a medical diagnosis. The court also held that a registered nurse meets the peer-to-peer requirement to attest to breaches of nursing care standards but not to the standards applicable to physicians. The case was allowed to proceed based on the certificate provided by Nurse Jones-Singh. View "Canton Harbor Healthcare v. Robinson" on Justia Law

In 2020, the Maryland General Assembly passed the Housing Opportunities Made Equal (HOME) Act, which added "source of income" to the list of prohibited considerations in housing rental or sale. The appellant, a housing voucher recipient, applied to rent an apartment in the appellee's complex. The appellee applied a minimum-income requirement, combining all sources of income to determine if the total exceeded 2.5 times the full gross rent. The appellant's combined income, including her voucher, did not meet this threshold, leading to the rejection of her application. The appellant sued, claiming the minimum-income requirement constituted source-of-income discrimination under § 20-705.The Circuit Court for Baltimore County granted summary judgment to the appellee, finding that the appellee's policy did not discriminate based on the source of income but rather on the amount of income. The court ruled that the appellee neutrally applied its income qualification criteria and rejected the appellant based on the amount of her income, not its source.The Supreme Court of Maryland reviewed the case and held that the appellee's counting of voucher income in the same manner as other income sources did not entitle it to summary judgment. The court found that this approach did not resolve the appellant's disparate impact claim, which asserts that a facially neutral policy has a disparate impact on a protected group without a legitimate, nondiscriminatory reason. The court vacated the judgment of the circuit court and remanded the case for further proceedings consistent with its opinion, emphasizing the need to address the disparate impact analysis. View "Hare v. David S. Brown Enterprises" on Justia Law

In early 2019, G.K. and K.K. purchased a homeowners insurance policy from Travelers Home and Marine Insurance Company for their residence. The policy included an anti-assignment clause prohibiting assignment without the insurer's consent. In May 2020, after the policy expired, the Policyholders reported roof damage from a 2019 storm and hired Featherfall Restoration, LLC to repair it. Travelers denied the claim, citing wear and tear. The Policyholders then assigned their claim to Featherfall, which Travelers refused to recognize due to the anti-assignment clause.Featherfall filed a complaint with the Maryland Insurance Administration (MIA), asserting its right to act in place of the Policyholders. The MIA upheld Travelers' denial, stating the anti-assignment clause invalidated the assignment. Featherfall requested a hearing, arguing the clause should not apply to post-loss assignments. The MIA Commissioner granted summary decision in favor of Travelers, finding the assignment invalid and Featherfall not entitled to a hearing.Featherfall sought judicial review in the Circuit Court for Baltimore City, which affirmed the MIA's decision and denied declaratory relief. The Appellate Court of Maryland also affirmed, holding that anti-assignment clauses apply to post-loss assignments and that Featherfall lacked standing.The Supreme Court of Maryland reviewed the case and held that the anti-assignment clause did not prohibit the assignment of a post-loss claim. The court distinguished between the policy itself and a claim arising under it, noting that a claim is a chose in action and thus assignable. The court reversed the lower courts' decisions and remanded the case to the MIA for further proceedings consistent with this opinion. View "In re Petition of Featherfall Restoration" on Justia Law