Justia Maryland Supreme Court Opinion Summaries

Police received a call from a resident in a townhouse community who was personally acquainted with a local police officer, Sergeant Muollo. The caller, who contacted the officer directly on his cell phone rather than through the usual police line, reported that an unfamiliar black sedan with multiple occupants had been parked on her street for an extended period, with cell phones visibly in use inside the car, and expressed her suspicion that the occupants might be engaged in illegal activity, possibly breaking into vehicles. The officer, considering the caller credible due to their longstanding relationship, responded to the location, observed the described car, and, along with backup, blocked the vehicle’s exit. As the officer approached, the car moved slowly forward, which the officer interpreted as an attempt to turn around. He then activated his emergency lights, approached, and detected the odor of marijuana and observed contraband, leading to the arrest of the driver, who was also found in possession of a firearm.In the Circuit Court for Montgomery County, the defendant moved to suppress the evidence, arguing the stop was unsupported by reasonable suspicion. The circuit court denied the motion, finding the officer had reasonable suspicion based on the informant’s tip, the general level of crime in the area, and the movement of the vehicle when police approached. The defendant entered a conditional guilty plea and appealed. The Appellate Court of Maryland affirmed, concluding that, under the totality of the circumstances, the officer had reasonable suspicion, citing the tip from a known resident, the officer’s corroboration of the car’s presence, and testimony that the area experienced significant crime.The Supreme Court of Maryland reversed. The court held that, under the totality of the circumstances, the officer lacked reasonable suspicion to stop the car. The tip provided no basis for suspecting criminal activity beyond the car’s unfamiliarity and presence, and the officer’s corroboration only confirmed innocuous facts. The court further found the testimony about the area being high-crime was insufficiently particularized and not based on information known to the officer at the time of the stop. The judgment was reversed. View "Kopp v. State" on Justia Law

On the morning of November 8, 2022, an individual struck and fatally injured two pedestrians while driving. Police arrived at the scene, determined he was the driver, and informed him he could not leave. He was escorted to the back of a patrol car at approximately 7:43 a.m., where he remained for a little over an hour while officers conducted their investigation, including calling in a Drug Recognition Expert (DRE). At 8:51 a.m., the DRE smelled alcohol on him, conducted sobriety tests, and formally arrested him at 9:13 a.m. A subsequent breath test at 10:15 a.m. revealed a high blood alcohol concentration. He was charged with multiple offenses and ultimately convicted on all counts based on an agreed-upon statement of facts.The Circuit Court for Montgomery County denied his motions to suppress evidence, finding that his detention prior to formal arrest was reasonable and did not amount to a de facto arrest. The court also found that the breath test was conducted within the statutory two-hour window, as he was not “apprehended” for purposes of the statute until the DRE detected alcohol. The Appellate Court of Maryland affirmed these rulings, holding that his detention was reasonable under the totality of the circumstances and that the breath test results were admissible.The Supreme Court of Maryland reviewed the case and affirmed the lower courts. It held that placing the individual in a patrol car during a rapidly developing investigation did not itself transform a lawful investigatory detention into a de facto arrest. The Court further held that, under Maryland law, an individual is “apprehended” for purposes of the two-hour testing window when police have reasonable suspicion of driving under the influence and act on it. Since this did not occur until 8:51 a.m., the breath test at 10:15 a.m. was timely, and the convictions were affirmed. View "Singh v. State" on Justia Law

A defendant was charged with multiple crimes, including murder, related to a 2016 incident. Before his first trial, the parties agreed to exclude evidence of firearms, ammunition, or marijuana found at the defendant’s residence, as these items were not relevant to the charges. In the first trial, the jury convicted the defendant on some counts and was hung on others, resulting in a mistrial on the unresolved charges. At retrial on the remaining counts, a prosecution witness unexpectedly mentioned the excluded evidence despite the prior agreement. The defendant moved for a mistrial, arguing this reference was improper. The trial court granted the mistrial, and the State did not oppose it.After the second mistrial, the defendant moved to dismiss the charges, contending that Maryland’s common law double jeopardy protections should bar a third prosecution if the State’s reckless conduct caused the mistrial. The defendant argued that the State was reckless in failing to adequately instruct the witness not to mention the excluded evidence and in its questioning. The Circuit Court for Charles County denied the motion, finding the State’s conduct was neither intentional nor reckless. The defendant appealed, and the Appellate Court of Maryland affirmed, holding that Maryland common law did not attach double jeopardy protections in these circumstances and, even if it did, the State’s conduct was not reckless.The Supreme Court of Maryland reviewed the case. Without deciding whether Maryland law bars retrial after a mistrial caused by reckless State conduct, the Court assumed for argument’s sake that such a standard might apply. The Court held that the circuit court’s factual finding—the State did not act recklessly—was not clearly erroneous. Therefore, the Supreme Court of Maryland affirmed the judgment of the Appellate Court, allowing the retrial to proceed. View "Santana v. State" on Justia Law

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