Justia Maryland Supreme Court Opinion Summaries

A minor child, who had been in her grandmother’s custody due to her mother’s intellectual disabilities, became the subject of a child in need of assistance (CINA) case after concerns arose about missed medical appointments and poor academic performance. The Department of Social Services petitioned for CINA status, but the juvenile court initially allowed the child to remain with her grandmother under protective supervision. Over time, further review hearings were held, and eventually a magistrate recommended removing the child from her grandmother’s custody. The child and her grandmother objected, leading to a de novo exceptions hearing.At the exceptions hearing, the Circuit Court for Worcester County, sitting as a juvenile court, excluded the child from the hearing over the objection of her counsel, reasoning generally that it was inappropriate for children under 15, especially those with developmental delays, to attend such contested proceedings. The court later removed the child from her grandmother’s custody and placed her with the Department. The Appellate Court of Maryland affirmed the juvenile court, finding no abuse of discretion, and distinguished this case from prior precedent by concluding the juvenile court had considered the child’s due process rights.The Supreme Court of Maryland reviewed the case and held that, although the appeal was moot because the CINA proceedings had been terminated and custody restored to the grandmother, the case presented an issue of public importance warranting review. The Court held the juvenile court violated the child’s procedural due process rights by excluding her from her own CINA hearing without making individualized findings or balancing her due process interests against any potential harm from her presence. The Court articulated a new test requiring courts to make specific findings and narrowly tailor any exclusion of a child party. The judgment of the Appellate Court of Maryland was reversed. View "In re: K.B." on Justia Law

In 2025, the Frederick County Council enacted legislation establishing a Critical Digital Infrastructure (CDI) Overlay Zone, enabling data centers and related infrastructure to be built on a limited portion of county land. The boundaries and zoning designations of the Overlay Zone were later set by Ordinance 26-01-001 (the CDI Ordinance), which included color maps as exhibits to indicate the precise locations and zoning designations. A group of residents, the Frederick County Data Center Referendum Committee, sought to challenge this ordinance by referendum and gathered sufficient signatures for a petition. However, the petition included only black-and-white reproductions of the ordinance’s maps, which did not clearly show the Overlay Zone boundaries or zoning distinctions.The sufficiency of the petition was initially upheld by the Director of the Frederick County Board of Elections, who found it met requirements as to form, though she did not decide whether the ordinance was a proper subject for referendum. Several parties opposed the referendum, arguing in the Circuit Court for Frederick County that the ordinance was not subject to referendum under the County Charter and that the petition was deficient because it did not include a full and accurate reproduction of the ordinance. The circuit court agreed, finding both that the CDI Ordinance was not a “law” subject to referendum under the Charter and that the petition’s reproduction of the ordinance was insufficient due to the lack of accurate color maps.On direct appeal, the Supreme Court of Maryland affirmed the circuit court’s judgment. The Court held that under the Frederick County Charter, zoning ordinances, such as the CDI Ordinance, are not subject to referendum because the Charter intended to maintain pre-Charter limitations on referenda for such ordinances. Additionally, the Court held that the petition was insufficient because it did not contain a full and accurate reproduction of the ordinance, as the black-and-white maps omitted essential information. View "In re: Frederick Cnty. Data Center Referendum" on Justia Law

The case involved an incident in which the respondent was found at the scene of a single-vehicle accident late at night, standing near a crashed vehicle that had veered off a dry roadway and struck a speed limit sign. Law enforcement arriving at the scene observed that the respondent exhibited multiple signs of intoxication, including bloodshot eyes, slurred and lethargic speech, repeated confusion, and inconsistent statements about his actions. The only key to the vehicle was found in his possession, and there was circumstantial evidence linking him to the vehicle’s operation. The owner of the vehicle confirmed that she was not present and that there was only one key.After being charged with several traffic offenses, including driving under the influence and driving while impaired, the respondent was tried by jury in the Circuit Court for Somerset County and convicted on the relevant counts. He appealed, arguing that the evidence was insufficient to prove he was intoxicated at the time he was driving. The Appellate Court of Maryland agreed, reversing the convictions for the alcohol-related offenses on the grounds that the State did not present “specific evidence” directly linking his intoxication to the period of driving, especially given the time gap between when he was last seen and when law enforcement arrived.On review, the Supreme Court of Maryland clarified that the standard for sufficiency of the evidence in all criminal cases is the “no reasonable trier of fact” standard, as set forth in Jackson v. Virginia and reaffirmed in Smith v. State. Applying this standard, the Court held that the State’s evidence—both direct and circumstantial—was sufficient for a rational jury to infer that the respondent drove the vehicle while intoxicated. The Supreme Court of Maryland reversed the judgment of the Appellate Court and reinstated the convictions. View "State v. Palmer" on Justia Law

A Maryland religious corporation sought to reclaim possession of its real property, used as a parsonage, from the individual who had served as its Bishop. The corporation purchased the property for use by the Bishop, and the respondent resided there with permission. After the Church’s Holy Synod defrocked the respondent and removed him as Bishop, the corporation repeatedly asked him to vacate the property. The respondent refused, arguing that the Synod was illegitimate and that his removal was improper, asserting a right to remain as the rightful Bishop.The District Court of Maryland sitting in Prince George’s County dismissed the corporation’s wrongful detainer action, reasoning that resolving the property dispute would require it to determine the legitimacy of the Synod’s actions under church law, which was barred by the ecclesiastical abstention doctrine. The Circuit Court for Prince George’s County affirmed that dismissal, concluding that determining who was entitled to occupy the property required deciding internal church governance issues.The Supreme Court of Maryland reviewed the case and held that the ecclesiastical abstention doctrine does not apply because the dispute can be resolved using neutral principles of Maryland law, without interpreting religious doctrine or governance. The court found that the corporation held legal title to the property, there was no lease or evidence of tenancy, and the respondent occupied the property as a licensee. A license can be revoked at any time, and the corporation had revoked the respondent’s license to occupy the property. Therefore, the Supreme Court of Maryland reversed the lower courts’ decisions and held that the corporation is entitled to judgment on its claim for wrongful detainer. The case was remanded for further proceedings, including determination of damages and attorney’s fees. View "Ertritrean Orth. Tweahdo Diocese v. Sinoda" on Justia Law

A twelve-year-old child was charged with robbery and four related offenses following an incident in Baltimore City, where a victim’s purses were taken and liquid was thrown at her. Robbery, a crime of violence, anchored the juvenile court’s jurisdiction over the child under Maryland’s Juvenile Justice Reform Act, which restricts jurisdiction for children under thirteen except when charged with a violent crime or an act arising from the same incident. At the adjudicatory hearing, the magistrate found the child not involved in robbery but involved in misdemeanor theft, ruling that the timing of the force element was not established for robbery.After this finding, the child moved to dismiss the theft charge, arguing that jurisdiction was lost when the robbery count—the qualifying offense—was not sustained. The magistrate denied the motion, reasoning that jurisdiction attaches at filing and continues regardless of the adjudicatory outcome, following precedent from the Appellate Court of Maryland in In re J.B. The juvenile court proceeded to disposition, finding the child delinquent and imposing probation. The child’s exceptions and renewed motion to dismiss were also denied by a judge of the Circuit Court for Baltimore City.The Supreme Court of Maryland reviewed the case and held that jurisdiction, once attached by an allegation of a qualifying crime, continues until the child turns twenty-one unless terminated by a specific statutory mechanism. The court clarified that jurisdiction over offenses arising out of the same incident is derivative at filing but durable thereafter, unaffected by a not-sustained finding or dismissal of the anchoring violent charge. Additionally, the court rejected the child’s equal protection claim, finding a rational basis for treating children accused of violent crimes differently from those accused only of misdemeanors. The court affirmed the Circuit Court’s decision. View "In re: D.E." on Justia Law

The case involved charges against a defendant for first-degree murder, second-degree murder, voluntary manslaughter, robbery with a dangerous weapon, and related firearms offenses after the shooting deaths of two individuals during a drug transaction. The defendant, who admitted to the shootings but claimed self-defense, was impeached at trial with a prior custodial statement in which he denied any involvement. The statement was made during a late-night, uncounseled custodial interrogation after the defendant was advised of his Miranda rights.At trial in the Circuit Court for Baltimore City, the defendant requested a jury instruction directing the jury to consider the voluntariness of his custodial statement before using it for impeachment. The trial court declined to give this instruction, finding there was no evidence suggesting the statement was involuntary. The jury acquitted the defendant of first- and second-degree murder but found him guilty of voluntary manslaughter, robbery, and several firearms offenses. He was sentenced to 70 years' imprisonment.The defendant appealed to the Appellate Court of Maryland, arguing he was entitled to the voluntariness instruction. The Appellate Court affirmed the conviction, holding that the instruction was not required since the statement was introduced only for impeachment, was exculpatory, and there was no “some evidence” of involuntariness.Upon further review, the Supreme Court of Maryland disagreed with the Appellate Court’s reasoning that the instruction was unnecessary because the statement was used for impeachment or was exculpatory. However, the Supreme Court determined the defendant failed to present “some evidence” that his statement was involuntary, as required to trigger the instruction. The Court also concluded that, even if it was error to deny the instruction, the error was harmless beyond a reasonable doubt given the nature of the evidence and the jury’s verdict. The Supreme Court of Maryland affirmed the judgment of the Appellate Court. View "Shuler v. State" on Justia Law

The case centers on the convictions of two defendants for offenses related to the 2019 murder of Donnell Brockington in Baltimore City. After the shooting, the suspects fled in a vehicle, which crashed, and four individuals—including the defendants—were apprehended. Police recovered multiple firearms from the vehicle and nearby, with DNA evidence linking all four co-defendants to the weapons. At trial, a State firearms examiner testified that certain ammunition recovered from the crime scene “was fired with” a Desert Eagle pistol found in the vehicle. None of the defendants challenged the reliability of this methodology before or during trial, nor requested a Daubert hearing.Following their convictions, the defendants appealed. During the pendency of their appeal, the Supreme Court of Maryland issued a decision in Abruquah v. State concerning firearms identification testimony. The Appellate Court of Maryland subsequently reversed the convictions on plain-error review, finding that the examiner’s unqualified testimony was prohibited by Abruquah. Additionally, one defendant challenged the trial court’s decision to close the courtroom during jury deliberations and to limit attendance at the verdict, which was prompted by escalating incidents of spectator misconduct, including direct contact between a co-defendant’s father and a juror.The Supreme Court of Maryland reviewed the case and held that the admission of the unqualified firearms examiner’s testimony was not “clear or obvious” error at the time of trial or appeal, making plain-error reversal inappropriate. The Court clarified that Abruquah was a case-specific Daubert determination, not a categorical ban. Regarding the courtroom closure, the Court adopted the Kelly framework for de minimis closures but found the closures justified under Waller v. Georgia due to legitimate concerns for juror safety and deliberative integrity. The Court reversed the convictions in part and affirmed in part, remanding for further proceedings. View "State v. Thornton" on Justia Law

Two individuals were found shot and killed in a car in Baltimore City after a planned marijuana sale. The investigation led police to Montay D. Shuler, who was observed near the scene, arrested, and interrogated. During a custodial interview, after being advised of his Miranda rights, Mr. Shuler denied involvement in the shooting. At trial, Mr. Shuler testified, admitting that he shot both victims but claimed self-defense. The State introduced his prior custodial statement, in which he denied involvement, for the purpose of impeaching his trial testimony.Mr. Shuler was tried in the Circuit Court for Baltimore City. The jury acquitted him of first- and second-degree murder but convicted him of voluntary manslaughter and several related offenses. Mr. Shuler requested a jury instruction requiring the jury to find his custodial statement voluntary before considering it. The trial court denied this request, reasoning there was no evidence the statement was involuntary. On appeal, the Appellate Court of Maryland affirmed, holding that no voluntariness instruction was required because the statement was only used for impeachment, was exculpatory, and there was no evidence of involuntariness.The Supreme Court of Maryland reviewed the case. It held that the trial court was not required to give the requested voluntariness instruction because Mr. Shuler did not present “some evidence” that his custodial statement was involuntary under either Maryland common law or constitutional standards. The Court clarified that the right to a voluntariness instruction is not limited to inculpatory statements or those offered in the State’s case-in-chief but must be generated by evidence of involuntariness. Even assuming error in failing to give the instruction, the Supreme Court of Maryland held the error was harmless beyond a reasonable doubt given the weight of the evidence and the jury’s verdict. The judgment of the Appellate Court was affirmed. View "Shuler v. State" on Justia Law

After a homeowners association obtained a money judgment against a homeowner for unpaid assessments, it levied the homeowner’s interest in her property and proceeded with a sheriff’s sale. The homeowner did not satisfy the judgment or obtain release of the levy before the sale occurred. A third-party bidder purchased the homeowner’s interest in the property at auction. After the sale but before the court ratified it, the homeowner paid the judgment in full to the association. The association then notified the court of the satisfaction and requested that the sale be vacated, arguing the judgment had been satisfied prior to ratification.The District Court of Maryland, sitting in Prince George’s County, agreed with the association, concluding that the sale could be vacated since the homeowner satisfied the judgment before ratification. On appeal, the Circuit Court for Prince George’s County affirmed, holding a hearing and again ruling that the sale was not complete until ratification and thus could be undone by post-sale satisfaction of the judgment.The Supreme Court of Maryland reviewed the case. It held that a judgment-debtor’s satisfaction of the judgment after a sheriff’s sale, but before ratification, cannot be raised as an exception to the sale under Maryland Rule 14-305(e)(1). Post-sale satisfaction is not an irregularity in the sale and does not void the purchaser’s inchoate equitable interest in the property acquired at auction. The Court emphasized that the judgment-debtor may obtain release of the levy only before sale, and that post-sale options for release are not available. The Court reversed the Circuit Court’s judgment and remanded with instructions to allow the homeowner thirty days to file exceptions to the sale, beginning after remand to the District Court. View "Baltimore XV Props. v. Newsteps' Choice North Homeowners Association, Inc." on Justia Law

A father filed a petition in the District Court of Maryland, sitting in Montgomery County, seeking protection on behalf of his 11-year-old child from the child’s mother. The petition alleged repeated physical abuse, including punching and hitting with objects. Based on the allegations, the District Court entered an interim protective order, then a temporary protective order after finding reasonable grounds to believe abuse occurred, and ultimately a final protective order after a hearing. The final order, effective for one year, was supported by findings of a history of abuse.The mother appealed the District Court’s final protective order to the Circuit Court for Montgomery County, requesting and receiving two continuances. During this time, the circuit court issued intervening protective orders that maintained the previous protections and, at the mother’s request, allowed for a supplemental investigation. After a de novo hearing, the circuit court again entered a final protective order, modifying some conditions, and granted the father physical custody of the child. The mother then appealed to the Appellate Court of Maryland. That court transferred the case to the Supreme Court of Maryland, concluding it lacked jurisdiction because the circuit court had exercised appellate, not original, jurisdiction.The Supreme Court of Maryland held that when a circuit court hears a de novo appeal from a District Court’s final protective order under Maryland’s domestic violence statute, the circuit court has authority to issue intervening protective orders pending the final hearing. Issuing such orders does not convert the proceeding into one under the circuit court’s original jurisdiction, and thus, there is no further right of appeal to the Appellate Court of Maryland. The Supreme Court affirmed the judgment of the Circuit Court for Montgomery County. View "Walston v. Lindsay" on Justia Law