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

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

Two men were convicted in the Circuit Court for Baltimore City on charges related to the 2019 murder of Donnell Brockington, who was surrounded and fatally shot multiple times by a group of six individuals. After the suspects fled, four, including the two respondents, were apprehended when their vehicle crashed. Police recovered several firearms, and DNA evidence linked both respondents to a Desert Eagle 9mm pistol found in the vehicle. At trial, a State firearms examiner testified that certain ammunition components were fired from that pistol, but neither respondent challenged the reliability of the examiner’s methodology or requested a Daubert hearing.After trial, the Supreme Court of Maryland decided Abruquah v. State, clarifying the limits on firearms identification testimony. The Appellate Court of Maryland reversed the respondents’ convictions on plain-error review, concluding that the firearms examiner’s unqualified testimony was exactly the kind prohibited by Abruquah. Additionally, one respondent challenged the trial court’s decision to close the courtroom during jury deliberations and partially restrict attendance during the verdict, arguing it violated the Sixth Amendment. The Appellate Court found these closures de minimis and rejected the public trial claim.The Supreme Court of Maryland held that the admission of the firearms examiner’s unqualified opinion was not “clear or obvious” error for plain-error review purposes, since the law was unsettled both at trial and on appeal; Abruquah was a case-specific ruling, not a categorical ban on such testimony. The Court also concluded that the courtroom closures were not de minimis but were justified under Waller v. Georgia, given the trial court’s findings of escalating spectator misconduct and concern for juror safety. The Supreme Court reversed the Appellate Court’s judgment on the convictions, affirmed its ruling on the public trial issue, and remanded for further proceedings. View "State v. Thornton" on Justia Law

A landlord operating a multi-family apartment complex in Montgomery County, Maryland, filed a summary ejectment action against a civilian tenant for unpaid rent. The landlord did not possess a residential rental license, as required by county regulations, but claimed exemption from those requirements because the apartment complex was located on land originally acquired by the United States in 1941 for military purposes. The complex primarily housed servicemembers assigned to a nearby military medical center, but also leased to civilians when units were available.The District Court of Maryland sitting in Montgomery County found that the landlord was exempt from local licensure requirements based on correspondence from the county’s housing authority and entered judgment for possession and unpaid rent against the tenant. On appeal, the Circuit Court for Montgomery County reversed, ruling that the landlord was required to obtain a local rental license, at least for units leased to civilians, and vacated the judgment for possession and unpaid rent.The Supreme Court of Maryland reviewed whether the Enclave Clause of the United States Constitution preempted Montgomery County’s licensure requirements for this property. The court held that for the United States to obtain exclusive jurisdiction under the Enclave Clause, the State must consent, cede jurisdiction, and the United States must formally accept that jurisdiction. The record showed that, although the United States acquired title with state consent and cession, there was no evidence that the United States ever formally accepted exclusive jurisdiction as required by federal law at the time of acquisition. Thus, the Enclave Clause did not apply, and the landlord failed to prove exemption from county licensure. The Supreme Court of Maryland affirmed judgment for the tenant, holding that the landlord could not bring a summary ejectment action without demonstrating compliance with, or exemption from, local licensing requirements. View "Ft. Detrick/W. Reed Army Med. Housing v. Wynn" on Justia Law

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

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

A man was charged with drug offenses after his car was stopped by police officers in Hagerstown, Maryland. The officers initiated the stop after observing the driver manipulating or pressing the screen of a cell phone mounted to the vehicle’s windshield while the car was in motion. The officers did not provide further details about the driver’s conduct beyond noting these interactions with the phone. The driver was not charged with a mobile phone or texting violation, but he moved to suppress evidence obtained as a result of the stop, arguing that the stop itself was unlawful.The Circuit Court for Washington County denied the suppression motion, holding that simply seeing someone manipulate a phone while driving constituted reasonable articulable suspicion of a mobile phone violation, since the conduct could easily be texting. After a jury trial, the defendant was convicted of fentanyl possession and related charges. On appeal, the Appellate Court of Maryland reversed, finding that the officers’ observations were of innocuous conduct and did not provide reasonable suspicion of illegal activity under Maryland’s statutes governing mobile phone use while driving.The Supreme Court of Maryland reviewed the case and affirmed the Appellate Court’s decision. The Court held that when an officer observes conduct consistent with both lawful and unlawful mobile phone use, the Fourth Amendment requires the officer to identify specific, articulable facts which, together with rational inferences, reasonably indicate a violation of the relevant statutes. Merely seeing a driver manipulate, touch, or press a phone screen, without more, is insufficient to justify a traffic stop. The Court thus concluded that the stop was not supported by reasonable suspicion and that the evidence should have been suppressed. View "State v. Stone" on Justia Law

A jury found the defendant guilty of second-degree assault. At the sentencing hearing, the trial judge initially announced a sentence of one year, suspending all but nine months to be served on home detention, followed by three years of supervised probation. While the judge was advising the defendant of his post-trial rights, the prosecutor questioned whether the sentence properly reflected the intended punishment and raised concerns about the remaining active time if probation was violated. After a brief colloquy and clarification, the judge revised the sentence, increasing it to five years, suspending all but nine months on home detention, and three years of supervised probation.The defendant appealed to the Appellate Court of Maryland, arguing that the trial judge had illegally increased the sentence after it had been imposed, in violation of Maryland Rule 4-345, which restricts modifications to sentences once they are imposed. The Appellate Court rejected this argument, holding that the sentence was not illegally increased because the revision occurred before the sentencing proceeding concluded, and Rule 4-345 was therefore not triggered.On further appeal, the Supreme Court of Maryland affirmed the decision of the Appellate Court. The Supreme Court held that under Maryland law, a sentence is not considered “imposed” under Rule 4-345 until the sentencing proceeding ends. Thus, a trial court retains authority to modify or increase a sentence during an ongoing sentencing hearing. Since the revision to the defendant’s sentence occurred before the conclusion of the sentencing proceeding—while the defendant was still present and the case was not over—Rule 4-345 did not apply, and the increase did not violate double jeopardy protections. The judgment of the Circuit Court for Prince George’s County was affirmed. View "Reyes v. State" on Justia Law