Justia Maryland Supreme Court Opinion Summaries

After a re-trial, a jury found Defendant guilty of first degree murder, second degree murder, and related offenses. At issue on appeal was whether pre-trial statements made by and on behalf of Defendant on the morning of the commencement of his re-trial should have been construed by the trial court as requests to discharge his counsel under Maryland Rule 4-215(e) or merely as a request for a continuance. Defendant claimed the circuit court failed to comply with Rule 4-215(e) and violated his constitutional right to counsel when Defendant was denied permission to discharge his counsel after he made several purported requests to do so. The court of special appeals reversed. The Court of Appeals reversed, holding (1) even assuming that the statements made to the trial court were sufficient collectively to engage a Rule 4-215(e) inquiry into the putative merits of Defendant's purported request to discharge his counsel, the conduct of the judges who considered Defendant's request as such complied with the requirements of Rule 4-215(e); and (2) the trial court did not violate Defendant's constitutional right to counsel of choice by denying his request for a continuance. Remanded with directions to affirm the judgment of the circuit court. View "State v. Taylor" on Justia Law

Petitioners in this case were two residents of Howard County who filed a complaint seeking a declaratory judgment that a variety of County resolutions, ordinances, zoning decisions, and administrative actions violated the Howard County Charter. Specifically, Petitioners alleged that the County, by taking certain actions by resolution or administrative decision, rather than passing an original bill as the Charter requires for all legislative acts, denied Petitioners the opportunity to petition those acts to referendum, which, consequently, violated their interests in their constitutional rights to free speech and to vote. The circuit court dismissed the complaint, concluding that Petitioners lacked standing. The court of special appeals affirmed, holding that Petitioners failed to show a concrete injury to their voting rights and thereby lacked standing. The Court of Appeals affirmed, holding that Petitioners failed to establish standing because they alleged no specific and personal injuries stemming from the County's actions. View "Kendall v. Howard County" on Justia Law

The Maryland Transit Administration (MTA) fired Plaintiff, a bus operator that suffered from a heart condition. MTA terminated Plaintiff's employment for failing to meet the standard adopted by the State establishing that an individual is not qualified to drive a commercial motor vehicle if that individual suffers from certain cardiovascular diseases. The standard had previously been adopted by the United States Department of Transportation (DOT). Plaintiff brought this action in the circuit court, alleging that the MTA violated his rights under the Americans with Disabilities Act (ADA). After a jury trial, MTA was found guilty of discrimination. The court of special appeals reversed, holding that Plaintiff's inability, because of his heart condition, to meet the DOT standards rendered him unqualified as a matter of law for an MTA bus operator position. The Supreme Court affirmed, holding (1) as a matter of law, the MTA's use of the federally-created qualification standard governing drivers suffering from cardiovascular disease satisfied the ADA's requirements of being "job-related" and of "business necessity" and that "performance cannot be accomplished by reasonable accommodation"; and (2) because Plaintiff failed to meet this properly imposed qualification standard, he was not a "qualified individual" under the ADA. View "Zei v. Md. Transit Admin." on Justia Law

The two consolidated criminal cases before the Court of Appeals here involved Jeffrey Valonis, who was convicted of robbery and related criminal charges in a bench trial, and Anthony Tyler, who was convicted of burglary and malicious destruction of property in a bench trial. At issue before the court was whether the amendment to Maryland Rule 4-245(b), which added the language "the court determines and announces on the record" and requires a trial judge to make an explicit finding of jury trial waiver on the record is subject to strict compliance and whether the failure to make such a factual determination is reversible error. The Court remanded the cases for a new trial, holding that in these two cases, the trial judges committed reversible error in failing to comply with the determine and announce requirement of Rule 4-246(b) and thereby failed to demonstrate a valid waiver of Defendants' right to a trial by jury. View "Valonis v. State" on Justia Law

Defendant was charged with third-degree sex offense and sexual solicitation of a minor. To satisfy the age element of the charge for the third-degree sex offense, the State had to prove Defendant was at least twenty-one years old at the time he had the alleged inappropriate contact with a fourteen-year-old girl. To satisfy that element, the State presented the testimony of a police officer, who interviewed Defendant and had an opportunity to examine Defendant's driver's license. Defendant objected to that testimony on hearsay grounds. The State argued that, even if the date of birth was hearsay, it was admissible as an adoptive admission of a party-opponent under Md. R. Evid. 5-803(a)(2). The trial court allowed the detective to testify, and a jury convicted Defendant on both counts. The Court of Appeals affirmed, holding that the trial court did not clearly err in finding that Defendant's conduct of providing the driver's license to the detective constituted an adoptive admission under Rule 5-803(a)(2). View "Gordon v. State" on Justia Law

After a jury trial, Defendant was convicted of rape, kidnapping, and related charges. Nine years later, Defendant filed a revised petition for postconviction DNA testing, which the circuit court granted. Thereafter, because of what Defendant interpreted as "favorable" DNA results, Defendant requested a new trial. The postconviction court denied the motion, concluding that the testing results were unfavorable to Defendant. The Court of Appeals affirmed, holding that, even if the DNA test results could be considered "favorable" evidence, the postconviction court did not abuse its discretion in ruling that the test results did not provide a substantial possibility that Defendant would not have been found guilty if the DNA evidence had been introduced at trial. View "Brown v. State" on Justia Law

Defendant was charged for multiple criminal offenses. Prior to the conclusion of jury deliberations during trial, the jury sent a completed verdict sheet to the trial judge indicating that the jury voted to acquit Defendant on charges of first degree assault, conspiracy to commit first degree assault, and conspiracy to commit robbery. The jury sheet indicated further, however, that the jury had not agreed as to disposition of the charge of robbery and second degree assault. The jury was unable to reach a unanimous verdict regarding the counts as to which it was undecided. The judge declared a mistrial as to all counts. Defendant filed a motion to bar retrial on the charges for which he believed the first jury acquitted him. The motion was denied. The court of special appeals reversed, determining that there was no manifest necessity for a mistrial and that retrial on the three counts for which the jury indicated a unanimous vote on the verdict sheet was barred by double jeopardy. The Court of Appeals affirmed after noting that Maryland law permits partial verdicts under the circumstances present here, holding that retrial of Defendant on the three disputed charges was prohibited by principles of double jeopardy. View "State v. Fennell" on Justia Law

After a jury trial, Petitioner was convicted of first-degree assault and aggravated cruelty to animals. The court of special appeals affirmed the convictions. Petitioner petition for writ of certiorari, arguing (1) the evidence was insufficient to support his felony animal cruelty conviction, and (2) his attorney's failure, after the close of all evidence, to renew the motion for judgment of acquittal constituted ineffective assistance. The Court of Appeals affirmed, holding (1) the evidence presented at trial was sufficient to support Petitioner's conviction of felony animal cruelty; and (2) it was unnecessary to address Petitioner's claim of ineffective assistance since it rested solely on his assertion that the evidence presented against him was insufficient to sustain his felony animal cruelty conviction. View "Haile v. State" on Justia Law

The City of Baltimore initiated a condemnation action to acquire an old theater once used as a vaudeville venue. The theater's owner (Owner) contested the action, arguing that the City had no right to condemn the property. Six weeks before trial, Owner filed an emergency motion demanding a postponement and an order requiring the City to pay to move all the junk out of the theater prior to trial so the jury would not view the property in its existing condition. The trial court denied the motion and the jury viewed the theater as is. The court of special appeals ruled that the trial court did not abuse its discretion in denying Owner's motion. The Court of Appeals affirmed, holding that Owner was not entitled to a payment in advance of trial, and Owner suffered no prejudice from the denial beyond what it brought upon itself. View "A&E North, LLC v. Mayor & City Council of Baltimore" on Justia Law

After a jury trial, Defendant was convicted of two counts of first-degree murder and use of a handgun in the commission of a crime. Defendant appealed, arguing that the trial court's replacement of a juror with an alternate juror without the knowledge or acquiescence of defense counsel was a violation of Maryland Rule 4-326(d) and, therefore, reversible error. The court of special appeals affirmed, holding that no prejudice occurred by the removal of the juror. The Court of Appeals reversed and remanded, holding (1) the trial court's unilateral action in discharging the juror and replacing her with an alternate without first notifying defense counsel was error; and (2) the State did not carry its burden of establishing that Defendant was not prejudiced by the rule violation. View "Grade v. State" on Justia Law