Justia Maryland Supreme Court Opinion Summaries

Plaintiffs, a minor and her mother, sued Defendants, owners of residential rental properties, for negligence and deceptive practices in violation of the Maryland Consumer Protection Act after the minor suffered brain injuries allegedly resulting from her ingestion of lead-based paint at one of Defendants' properties. Defendants moved for summary judgment, contending that they had complied with the Reduction of Lead Risk in Housing Act by registering their property, and therefore, they were immune from suit under the immunity provisions of the Act. The circuit court granted summary judgment for Defendants, holding (1) the Act's provisions granting immunity were constitutional, and (2) Defendants' registration renewals were timely because they were mailed on December 31. The court of special appeals reversed, holding that Defendants were not entitled to qualified immunity because they did not fully comply with the Act where the renewal of their registration was not received by December 31. The Court of Appeals reversed and remanded with directions to reverse the circuit court, holding that the immunity provisions in the Act were invalid under the Maryland Declaration of Rights because no adequate remedy was substituted for the grant of immunity and the victim was uncompensated for her injuries. View "Jackson v. Dackman Co." on Justia Law

After a jury trial, Petitioner William Briscoe was convicted of possessing a regulated firearm after having been convicted of, inter alia, possessing cocaine and wearing, carrying, or transporting a handgun in a vehicle. The convictions were based on evidence law enforcement officers recovered while searching Petitioner's vehicle and glove compartment at the time of his arrest. Petitioner sought suppression of the handgun, claiming it was the fruit of an illegal search. The circuit court denied the motion. While Defendant's appeal was pending, the Supreme Court decided Arizona v. Gant. The State conceded that, under Gant, the search violated the Fourth Amendment but argued that Petitioner was not entitled to suppression by application of the good-faith exception to the Fourth Amendment's exclusionary rule. The court of special appeals did not reach the Gant issue, holding instead that the handgun was recovered during a valid inventory search. The Court of Appeals affirmed but on different grounds, holding (1) the search of the glove compartment was not a valid inventory search, but (2) the good-faith exception to the exclusionary rule applied to what, at the time, was a lawful search of the glove compartment. View "Briscoe v. State" on Justia Law

Woodmore Towne Centre applied for a non-tidal wetlands permit to construct a road extension and stream crossing in order to provide primary access into a development. After the Maryland Department of the Environment (MDE) approved the permit, Patuxent Riverkeeper, a nonprofit environmental group, initiated a judicial review action against MDE and Woodmore. The circuit court dismissed the action for lack of standing. The Supreme Court reversed, holding that Riverkeeper had standing under Md. Code Ann. Envir. 5-204(f) to initiate a judicial review action because one of its members had alleged sufficient harm to his aesthetic, recreational, and economic interests in connection with the issuance of the non-tidal wetlands permit at issue. View "Patuxent Riverkeeper v. Dep't of Env't" on Justia Law

Petitioner Christopher Mansfield was tried in a bench trial at the circuit court on five counts charging statutory sex-related offenses. At the close of the evidence, the trial judge, sua sponte and over Petitioner's objection, declared a mistrial, explaining that her knowledge of Petitioner's prior convictions and the partiality it engendered made a mistrial manifestly necessary. Petitioner moved to dismiss the indictment on double jeopardy grounds, arguing that there was not manifest necessity for the granting of the mistrial where the trial judge had knowing of Petitioner's prior convictions well before the trial began. The motions judge and the court of special appeals upheld the decision. The Court of Appeals reversed, holding that under these circumstances, when it is the court that is the trier of facts, and the court's impartiality, whether due to a personal bias or prejudice toward a criminal defendant or an inability to resolve disputed factual allegations, is impaired, manifest necessity does not exist when the reasonable alternative of recusal existed prior to jeopardy attaching. Remanded. View "Mansfield v. State" on Justia Law