Justia Maryland Supreme Court Opinion Summaries

In these two cases arising from two instances of police misconduct the Court of Appeals held that the police officers were acting within the scope of their employment, and therefore, the City of Baltimore was responsible for compensating the plaintiffs.The officers in these cases were members of the Baltimore City Police Department's now-defunct Gun Trace Task Force. Members of the task force engaged in a wide-ranging racketeering conspiracy, resulting in the officers being convicted in federal court. These two cases arose out of instances in which the officers conducted stops and made arrests without reasonable articulable suspicion or probable cause. The plaintiffs and the officers agreed to a settlement of the lawsuits. As part of the settlements, the officers assigned to the plaintiffs the right to indemnification from the City. Thereafter, the plaintiffs sought payment of the settlements by the City. In both cases, the parties entered into a stipulated settlement of undisputed material facts. The Supreme Court held (1) the stipulations in both cases established that the officers' conduct satisfied the test for conduct within the scope of employment; and (2) therefore, the City was responsible for compensating the plaintiffs for the officers' actions by paying the settlements that the plaintiffs and the officers reached. View "Baltimore City Police Department v. Potts" on Justia Law

The Court of Appeals affirmed the judgment of the court of special appeals reversing Defendant's conviction of second-degree murder, holding that non-mutually admissible evidence was admitted at trial, prejudicing Defendant, and the seizure of a cell phone from Defendant's person exceeded the parameters of the Fourth Amendment and Article 26 of the Maryland Declaration of Rights.Defendant was tried in the circuit court along with a co-defendant for murder. Both defendants were convicted of second-degree murder. On appeal, Defendant argued that his trial should have been severed from that of his co-defendant since a substantial amount of the evidence against the co-defendant was not admissible against him. Defendant further argued that the trial court erred in failing to suppress a cell phone that was seized from his pocket. The Court of Appeals agreed, holding that (1) the trials should have been severed because the joint trial unfairly prejudiced Defendant, and the resulting prejudice could not be cured; and (2) in the absence of a valid search and seizure warrant for the search of Defendant's person or an applicable exception to the warrant requirement, the seizure of the cell phone was unlawful. View "State v. Zadeh" on Justia Law

The Court of Appeals affirmed the judgment of the court of special appeals reversing the circuit court's decision determining that it had personal jurisdiction over Defendant and entering a judgment in favor of Plaintiff, holding that the factors weighed against the constitutional reasonableness of causing Defendant to defend this suit in Maryland.This case was filed by Defendant's stepson, who was a North Carolina resident, against Defendant, who was also a North Carolina resident. Plaintiff ultimately obtained a default judgment against Defendant in the amount of $99,856.84. The court of special appeals reversed the circuit court's decision with respect to the finding of personal jurisdiction. The Court of Appeals affirmed, holding that Defendant's act of filing a sole lawsuit through counsel did not rise to the level of a "persistent course of conduct" to justify the assertion of personal jurisdiction over her in this matter. View "Pinner v. Pinner" on Justia Law

The Court of Appeals reversed the judgment of the court of special appeals affirming the judgment of the circuit court granting Defendant's petition for postconviction relief and ordering a new trial on the ground that Defendant's trial counsel provided ineffective assistance of counsel by not requesting an alibi jury instruction, holding that the circumstance that Defendant's trial counsel did not request an alibi jury instruction did not prejudice Defendant.At issue was whether Defendant satisfied, under Strickland v. Washington, 466 U.S. 668 (1984), his burden of proving that he was prejudiced when his trial counsel did not request, and the trial court did not give, an alibi jury instruction where purported alibi witnesses testified at trial. The Court of Appeals concluded that Defendant was not prejudiced because none of the purported alibi witnesses' testimony indicated that Defendant could not have been at the murder scene, and the circumstance that the circuit court gave other instructions regarding the State's burden to prove guilt beyond a reasonable doubt diminished the claim of prejudice. View "State v. Mann" on Justia Law

The Court of Appeals affirmed the decision of the court of special appeals affirming Defendant's conviction of two counts of criminal attempt for his refusal to testify in a murder trial, holding that Defendant failed to proffer sufficient evidence of duress to generate the defense of duress.Defendant was called to testify in a murder trial but refused to answer any questions on the basis of the privilege against self-incrimination. The court subsequently issued an order immunizing Defendant and directing him to testify, but Defendant continued to refuse to answer questions. Defendant was subsequently charged with contempt. During the trial, Defendant attempted to raise the common law defense of duress. The trial court rejected the defense as a matter of law and found Defendant guilty of contempt. Defendant appealed, arguing that duress can be a defense to a contempt charge for a refusal to testify. The court of special appeals affirmed. The Court of Appeals agreed, holding that even assuming the defense of duress was available to Defendant, Defendant's proffered evidence failed to generate the defense of duress because the alleged threat was not "present, imminent, and impending." View "Howell v. State" on Justia Law

The Court of Chancery reversed the judgment of the Court of Special Appeals affirming the judgment of the circuit court denying Defendant's motion to suppress cocaine on the grounds that officers' warrantless search of Defendant's person was illegal, holding that the same facts and circumstances that justify a search of an automobile do not necessarily justify an arrest and search incident thereto.On appeal, Defendant challenged the denial of his motion to suppress, arguing that the officers lacked probable cause to believe that Defendant possessed ten grams or more of marijuana. The Court of Appeals held (1) a person enjoys a heightened expectation of privacy in his or her person as compared to the diminished expectation of privacy he or she has in an automobile; and (2) the arrest and search of Defendant was unreasonable because the record did not suggest that possession of a joint and the odor of burnt marijuana gave the police probable cause to believe Defendant was in possession of a criminal amount of that substance. View "Pacheco v. State" on Justia Law

The Court of Appeals reversed the judgment of the Court of Special Appeals affirming the ruling of the circuit court denying Defendant's motion to suppress a gun as evidence and convicting Defendant of one count of possessing a regulated firearm after having been convicted of a crime of violence, holding that the suppression court erred in denying Defendant's motion to suppress.Three police officers were on patrol looking to discover guns, drugs, or other contraband when they discovered Defendant sitting in the driver's seat of a vehicle that was illegally parked outside of his home. The officers approached the vehicle, frisked Defendant, and arrested Defendant after confirming that he possessed a handgun. The Court of Appeals reversed, holding that the State failed to establish that the frisk of Defendant was reasonable under the circumstances and that the attenuation doctrine did not serve to render the evidence admissible. View "Thornton v. State" on Justia Law

The Court of Appeals affirmed the decision of the court of special appeals affirming the judgment of the circuit court denying Defendant's petition for postconviction relief alleging ineffective assistance of counsel, holding that Defendant proved that his trial counsel's performance was deficient but failed to establish prejudice.Defendant was found guilty of eleven charges arising out of an armed robbery. After an unsuccessful appeal, Defendant petitioned for postconviction relief, arguing that trial counsel provided ineffective assistance by not moving to strike a juror for cause and by not using a peremptory challenge against the juror. The circuit court denied the petition, and the court of special appeals affirmed. The Court of Appeals affirmed, holding (1) Defendant's trial counsel's conduct fell below an objective standard of reasonableness, but the presumption of prejudice did not apply here; and (2) Defendant failed to prove prejudice under the circumstances of this case. View "Ramirez v. State" on Justia Law

The Court of Appeals affirmed the judgment of the Court of Special Appeals upholding the suppression hearing court's denial of Defendant's motion to suppress, holding that evidence of an out-of-court identification procedure, through which the victim of an alleged assault identified Defendant as the perpetrator of the crime, contained sufficient indicia of reliability to withstand a motion to suppress.At the conclusion of a suppression hearing, the presiding judge concluded that the second photo array identification procedure at issue in this case was admissible because she found it reliable by clear and convincing evidence. Ultimately, the jury found Defendant guilty of attempted robbery, second-degree assault, and reckless endangerment. The Court of Special Appeals affirmed, holding that the identification had sufficient indicia of reliability to overcome the procedure's suggestiveness. The Court of Appeals affirmed, holding that the identification contained sufficient indicia of reliability to overcome the suggestive nature of the pretrial identification procedures. View "Small v. State" on Justia Law

The Court of Appeals reversed the judgment of the court of special appeals affirming in part and reversing in part the judgment of the post-conviction granting Respondent a new trial, holding that certain actions on the part of Respondent’s trial counsel did not violate Respondent’s constitutional right to effective assistance of counsel.Respondent was convicted of first-degree murder, robbery, kidnapping, and false imprisonment. Respondent later filed a petition for post-conviction relief alleging that he received ineffective assistance of counsel. The post-conviction court denied relief. The intermediate appellate remanded the case. On remand, the post-conviction court concluded that Respondent’s trial counsel’s performance was deficient and that this deficiency prejudiced Respondent. As a result, the post-conviction court vacated the convictions and granted Respondent a new trial. The court of appeals reversed in part, but the court’s ultimate disposition left the new trial granted by the circuit court in place. The Court of Appeals reversed, holding that trial counsel’s deficient performance in one aspect of her representation did not prejudice Respondent within the meaning of Strickland v. Washington, 466 U.S. 668 (1984). View "State v. Syed" on Justia Law