Justia Maryland Supreme Court Opinion Summaries

A defendant was initially tried on multiple charges related to a 2016 murder. At the first trial, the parties had agreed to exclude evidence regarding firearms, ammunition, and marijuana found in a search of the defendant’s home, as these items were not relevant. The jury convicted the defendant on some counts but could not reach a verdict on four charges, leading the Circuit Court for Charles County to declare a mistrial on those counts. At the retrial of the remaining charges, a prosecution witness unexpectedly referenced the previously excluded evidence during testimony. The defense objected, moved for a mistrial, and the State did not oppose. The court granted the motion.The defendant later moved to dismiss further prosecution, citing Maryland’s common law prohibition against double jeopardy, and argued that the State’s reckless conduct had prompted the mistrial. The Circuit Court denied the motion, finding that the State’s actions were neither intentional nor reckless. The defendant appealed, but the Appellate Court of Maryland affirmed, holding that Maryland’s common law double jeopardy protections did not apply since no factual findings had been made on the criminal charges at issue, and even if they did, the State’s conduct was not reckless.The Supreme Court of Maryland assumed, without deciding, that Maryland’s common law double jeopardy rule would bar retrial if a mistrial were caused by the State’s reckless conduct. Reviewing the Circuit Court’s factual finding for clear error, the Supreme Court held that there was competent evidence supporting the lower court’s determination that the State was not reckless. As a result, the Supreme Court of Maryland affirmed the judgment of the Appellate Court, allowing the prosecution to proceed. View "Santana v. State" on Justia Law

A commercial tenant operating a beer and wine store in Maryland entered into a five-year lease requiring it to pay base rent as well as additional charges—including real estate taxes, water and sewer bills, late fees, HVAC replacement costs, and attorneys’ fees—that the lease defined as “Additional Rent.” The lease contained a clause by which the tenant waived its statutory right of redemption, meaning it could not prevent eviction by paying the overdue amounts after judgment. After the tenant fell behind on these additional charges but remained current on base rent, the landlord filed a summary ejectment action to repossess the premises.The District Court for Frederick County found the tenant liable for most of the claimed additional charges and, relying on the lease’s waiver clause, awarded the landlord possession with no right of redemption. On appeal, the Circuit Court for Frederick County vacated that judgment, holding that some attorneys’ fees were improperly included as unpaid rent and that the tenant lacked adequate notice of certain charges, making the redemption waiver unenforceable.The Supreme Court of Maryland reviewed the case. It held that in nonresidential leases, a waiver of the statutory right of redemption does not violate Maryland public policy and is enforceable unless a traditional contract defense applies. The court also clarified that the statutory pre-suit notice requirement in Real Property Article § 8-401(c)(1) applies only to residential tenancies and not to commercial ones. However, it held that a landlord may recover possession only for rent that is due and unpaid under the lease, and summary ejectment cannot be based on charges of which the tenant had no prior notice before suit was filed.The Supreme Court of Maryland vacated the judgment of the circuit court and remanded for recalculation of the rent due, instructing that only charges for which the tenant had received prior notice and the contractual time to pay could support possession. View "Kapneck 14-16 v. Breezy's Speakeasy" on Justia Law

In this case, Montgomery County, Maryland, enacted amendments to its County Code in 2021 and 2022 regulating firearms. The amendments expanded the definition of “place of public assembly,” prohibited the possession of firearms (including “ghost guns”) in or within 100 yards of such places, and removed exceptions for state-issued handgun permit holders. The amendments also imposed new restrictions concerning minors’ access to firearms and regulated ghost guns and their components. The petitioners, two businesses and eight individuals, claimed these provisions were preempted by state law, not a valid local law, and amounted to an unconstitutional taking.After removal to federal court and a partial remand, the Circuit Court for Montgomery County ruled in favor of the challengers, finding the county’s provisions preempted by state law, not a local law, and an unconstitutional taking, and issued declaratory and injunctive relief. The Appellate Court of Maryland remanded for further analysis of preemption and takings issues, particularly concerning the expansion of “place of public assembly.”The Supreme Court of Maryland reviewed the case, holding that new issues may only be properly added by amending the complaint, not through summary judgment motions. The Court determined that Criminal Law § 4-209(b)(1) authorizes charter counties to regulate firearms in limited contexts (with respect to minors, law enforcement, and within 100 yards of certain public places), and that this authority was not abrogated by other state preemption statutes. The Court found Montgomery County’s regulation valid for parks, places of worship, schools, libraries, courthouses, legislative assemblies, recreational and multipurpose exhibition facilities, and polling places, but invalid for hospitals, health centers, long-term care, childcare facilities, government buildings as broadly defined, and generalized gatherings. The Court also clarified the scope of local regulation regarding minors and found no unconstitutional taking occurred. The judgment of the Appellate Court was vacated and remanded with instructions for further proceedings consistent with these holdings. View "Engage Armament v. Montgomery Cnty." on Justia Law

Miguel Angel Santana was charged with several offenses related to a 2016 murder. At his first trial in the Circuit Court for Charles County, a pretrial agreement excluded certain evidence about firearms, ammunition, and marijuana. The jury convicted him on two counts but hung on four others, resulting in a mistrial on those four counts. At the retrial on the remaining counts, a State witness referenced the excluded evidence during testimony, leading Santana’s counsel to move for a mistrial, which the court granted. Before a third trial could begin, Santana moved to dismiss the charges, arguing that Maryland common law should prevent retrial if the State’s reckless conduct caused the mistrial.The Circuit Court for Charles County denied Santana’s motion to dismiss. The court found that the State’s actions did not amount to recklessness, as the prosecutors had prepared the witness for his testimony and did not intend or expect him to reference the excluded evidence. The court concluded that the State's conduct, while unfortunate, was neither intentional nor reckless. Santana appealed, and the Appellate Court of Maryland affirmed the circuit court’s ruling, holding that Maryland’s common law double jeopardy protections did not apply because no factual findings on the criminal charges had been made and, even if the protections did apply, the circuit court’s finding was not clearly erroneous.The Supreme Court of Maryland reviewed the case to consider whether Maryland’s common law double jeopardy prohibition bars retrial after a mistrial caused by reckless State conduct, and whether the State acted recklessly here. The court assumed, without deciding, that Maryland law could bar retrial for reckless conduct, but held that the circuit court’s finding that the State was not reckless was not clearly erroneous. Accordingly, the Supreme Court of Maryland affirmed the judgment of the Appellate Court, permitting retrial to proceed. View "Santana v. State" on Justia Law

A woman developed mesothelioma and lung cancer, allegedly caused by exposure to asbestos dust brought home on her husband’s work clothing. Her husband had applied asbestos-containing insulation to power generation turbines manufactured by a company at a Maryland power plant in the 1960s. The plaintiff did not work at the plant or use the product herself but routinely shook out and laundered her husband’s dusty clothes. After her death, her estate continued the lawsuit, asserting a strict liability design defect claim against the turbine manufacturer and others.The Superior Court of the District of Columbia initially granted summary judgment for the manufacturer on all claims. On appeal, the District of Columbia Court of Appeals vacated the grant of summary judgment as to the strict liability design defect claim and remanded the case. Following remand, the Superior Court again granted summary judgment for the manufacturer, concluding that, under Maryland law, the plaintiff could not recover as a bystander. The plaintiff appealed, and the District of Columbia Court of Appeals certified a question of law to the Supreme Court of Maryland, asking whether a household member claiming injury from asbestos dust must prove an additional element of “duty” beyond the four elements of strict liability under Maryland law.The Supreme Court of Maryland held that a household member in the plaintiff’s position need not prove the additional element of duty to recover on a strict liability design defect claim in an asbestos case. The court emphasized that, unlike negligence or failure to warn claims, strict liability design defect actions require only the four elements identified in Phipps v. General Motors Corp. The court clarified that “duty” is not an additional element for such claims, regardless of whether the plaintiff is a “user,” “consumer,” or a household member exposed through no fault of their own. View "Quinn v. General Electric Co." on Justia Law

The Office of the Attorney General of Maryland initiated a criminal investigation into allegations of child sexual abuse and concealment by clergy and staff of the Archdiocese of Baltimore, based on a 2015 directive from the Governor authorizing the investigation and prosecution of “crimes of exploitation.” The Attorney General’s office issued grand jury subpoenas to the Archdiocese, leading to the production of voluminous records. No indictments were returned, but the Attorney General prepared a report naming over 150 individuals, including some accused of abuse and others alleged to have concealed abuse or failed to act. None of the individuals at issue, the Petitioners, were charged with crimes. The Attorney General sought court authorization to publicly disclose their identities, arguing that public accountability necessitated the release.The Circuit Court for Baltimore City found that the Attorney General had constitutional authority to conduct the investigation and prepare the report, and authorized disclosure of Petitioners’ identities, citing a particularized need for transparency and accountability. Petitioners appealed, and the Appellate Court of Maryland affirmed in part, agreeing that the Attorney General had investigatory authority and could prepare a report, but held that the Circuit Court should have made individualized findings regarding the need to disclose each Petitioner’s identity, and remanded for further analysis.Upon further review, the Supreme Court of Maryland affirmed that the Governor’s directive was within constitutional bounds and that the Attorney General’s office had the authority to investigate and report on child sexual abuse within the Archdiocese. However, the Court held that the interest in public accountability does not create a particularized need sufficient to overcome the secrecy of grand jury materials as to uncharged individuals who object. The Supreme Court of Maryland reversed the Appellate Court’s judgment and directed the Circuit Court to deny the Attorney General’s motion to disclose Petitioners’ identities. View "In Re: Criminal Investn. No. CID 18-2673 Balt. City Circuit Court" on Justia Law

Matthew and Jamie Skipper obtained health insurance from CareFirst BlueChoice, Inc. through the Maryland Health Benefit Exchange. After experiencing infertility, they underwent in-vitro fertilization (IVF), which included freezing embryos. When they later sought coverage for the medically necessary procedure of embryo thawing as part of a subsequent IVF cycle, CareFirst denied coverage, citing a policy exclusion. The Skippers paid for the thawing themselves and later sought reimbursement. CareFirst denied their appeal as untimely. The Skippers filed a complaint with the Maryland Insurance Administration and, while that was pending, brought a putative class action in the United States District Court for the District of Maryland. Shortly after the federal suit was filed, CareFirst reversed its denial and paid the claim. The federal court then dismissed the Skippers’ complaint for lack of jurisdiction due to the amount-in-controversy requirement. The Skippers promptly refiled their class action in the Circuit Court for Prince George’s County.CareFirst moved to dismiss in the Circuit Court, arguing the case was moot because it had paid the Skippers’ claim and that the policy did not cover embryo thawing. The Circuit Court granted the motion based on mootness. The Appellate Court of Maryland reversed, holding that the payment did not moot the class claims and that the complaint adequately stated a claim.The Supreme Court of Maryland affirmed the Appellate Court’s judgment. The Court held that when a putative class action is first filed in another court and the defendant tenders individual relief to the named representative before dismissal for lack of jurisdiction, a substantially similar complaint promptly refiled in state court is not moot until the representative has a reasonable opportunity to seek class certification. Additionally, the Court held that the relevant policy exclusion does not authorize CareFirst to deny coverage for medically necessary expenses arising from IVF procedures, including embryo thawing, and that Maryland law requires such coverage. The case was remanded for further proceedings. View "Carefirst Bluechoice v. Skipper" on Justia Law

A candidate, John Calvin Dove, Jr., submitted a certificate of candidacy to run for the Democratic Party nomination for the Maryland House of Delegates in Legislative District 12B for the 2026 gubernatorial election. Gary Simmons challenged Dove’s qualifications, asserting that Dove was not a resident and did not maintain a place of abode in Legislative District 12B at the time he filed his candidacy certificate. Simmons further alleged that Dove had misrepresented his residency on his voter registration and his certificate of candidacy, arguing that these actions rendered Dove ineligible and his candidacy certificate invalid.The Circuit Court for Anne Arundel County scheduled a hearing on Simmons’s petition, but Dove moved to dismiss, arguing that the constitutional residency requirement only needed to be met six months before the general election, a date which had not yet arrived. The circuit court agreed with Dove, finding the challenge premature and dismissing Simmons’s petition with prejudice, without taking evidence on Dove’s residency or place of abode.On appeal, the Supreme Court of Maryland reviewed the case. The court held that Simmons’s petition was not premature as to his claims under the Election Law Article, which require that a candidate be lawfully registered to vote and reside in the legislative district at the time of filing the certificate of candidacy. The court found that such a challenge is ripe for adjudication at the time of filing. The Supreme Court of Maryland reversed the judgment of the Circuit Court for Anne Arundel County and remanded the case for an evidentiary hearing and a decision on the merits of Simmons’s challenge before set deadlines. The costs were assessed against Dove. View "Simmons v. Dove" on Justia Law

Several Maryland local governments, including Baltimore City, Anne Arundel County, and the City of Annapolis, filed lawsuits in Maryland circuit courts against 26 multinational oil and gas companies. They alleged that the defendants’ extraction, production, promotion, and sale of fossil fuels—combined with deceptive marketing about their products’ climate risks—substantially contributed to global greenhouse gas emissions, resulting in severe local impacts such as sea-level rise, flooding, and heat waves. The local governments sought damages and equitable relief based on Maryland common law claims of public nuisance, private nuisance, trespass, negligent failure to warn, and strict liability failure to warn.In the trial courts (the Circuit Courts for Baltimore City and Anne Arundel County), the defendants successfully moved to dismiss the complaints. The courts found that the local governments’ claims were preempted by federal law, specifically by federal common law and the Clean Air Act, and that the complaints failed to state claims upon which relief could be granted under Maryland law. The cases took a procedural detour through federal courts due to removal attempts, but were ultimately remanded to state court. The Appellate Court of Maryland consolidated the appeals, and the Supreme Court of Maryland granted review by writ of certiorari.The Supreme Court of Maryland affirmed the dismissals. The court held that the local governments’ state law claims, though pled as torts, effectively sought to regulate interstate and international air emissions—an area governed exclusively by federal law. Relying on United States Supreme Court precedent, the court explained that such claims are displaced by federal common law and, in turn, by the Clean Air Act, which does not authorize broad state law claims in this context. The court further held that, even if not preempted, none of the plaintiffs stated valid claims under Maryland law for public or private nuisance, trespass, or failure to warn. View "Mayor & City Cncl. Of Balt. v. B.P. P.L.C." on Justia Law

A Maryland county brought a lawsuit against several pharmacy benefit managers, mail-order pharmacies, and retail pharmacies, alleging that they worked with opioid manufacturers to deceptively market opioids and facilitated opioid abuse by placing these drugs on preferred formularies with few restrictions. The county claimed that this conduct created a public nuisance by causing widespread opioid misuse, which resulted in increased public health and safety costs for the county. The county sought a finding of public nuisance, an injunction, abatement costs, damages to compensate for public services, and attorney’s fees.Prior to review by the Supreme Court of Maryland, the United States District Court for the District of Maryland certified two questions to the state high court. The questions asked whether, under Maryland’s common law, the licensed dispensing of, or administration of benefit plans for, a controlled substance can constitute an actionable public nuisance, and what elements and forms of relief are available for such a claim if so. The county argued that Maryland common law supported these claims, relying on language from prior cases and the Restatement (Second) of Torts, while defendants maintained that Maryland had never recognized such a broad public nuisance doctrine, especially for lawful and licensed conduct.The Supreme Court of Maryland held that the licensed dispensing of, or administration of benefit plans for, a controlled substance does not constitute an actionable public nuisance under Maryland common law. The court explained that Maryland’s public nuisance doctrine historically allowed government entities only to seek criminal prosecutions or injunctive relief—not damages—and has not been expanded to cover lawful, regulated conduct such as the licensed dispensing of opioids. The court further found that the county’s complaint failed to meet a key requirement of public nuisance: interference with a common public right. Even if it did, the court stated that judicial restraint was appropriate given the extensive federal and state regulation of this area, making common law public nuisance an unsuitable remedy. View "Express Scripts v. Anne Arundel Cnty." on Justia Law