Justia Maryland Supreme Court Opinion Summaries

After a joint jury trial, Petitioner was found guilty of second degree murder, conspiracy to commit murder, and use of a handgun in the commission of a crime of violence. The court of special appeals affirmed. Petitioners filed a petition for writ of certiorari, arguing that the prosecutor’s response to an allegation of racial and gender discrimination in the exercise of a peremptory challenge did not satisfy the requirement of Batson v. Kentucky that the State provide a specific explanation for each challenged strike which is racially, and with respect to gender, neutral. The Court of Appeals reversed, holding that the prosecutor’s explanation for striking the juror at issue, in addition to lacking the requisite specificity, violated Batson because the explanation was neither race- nor gender-neutral. Remanded for a new trial. View "Ray-Simmons v. State" on Justia Law

Petitioner operated a lake-front recreational campground on her property in Caroline County. The lake was contaminated allegedly by run-off from failed septic systems serving homes and businesses in the Town of Goldsboro. Unable to operate the campground because of the pollution to the lake, Petitioner lost the property through foreclosure. Petitioner filed a complaint for Caroline County against the State and several of its entities, alleging inverse condemnation against all Respondents and trespass against the Town. The circuit court dismissed the complaint as to all Respondents. The court of special appeals affirmed. The Supreme Court remanded, concluding that the court of special appeals erred in affirming the dismissal of Petitioner’s causes of action for negligence, trespass, and inverse condemnation on the grounds of limitations. On remand, the court of special appeals concluded that the circuit court properly dismissed the State and its agencies but erred in dismissing the three claims against the Town. The Court of Appeals reversed in part and affirmed in part, holding that Petitioner adequately alleged a facial claim for inverse condemnation against all Respondents and that a claim for inverse condemnation is not covered by the notice provisions of either the Local Government Tort Claims Act or the Maryland Tort Claims Act. View "Litz v. Dep’t of Env’t" on Justia Law

Defendants Matthew Meyer and Helen Rivera were placed on probationary terms and, as a special condition of probation, prohibited from operating a motor vehicle. The circuit court denied Meyer’s motion to correct and illegal sentence, concluding that Meyer’s sentence was not illegal. In Rivera’s case, the court of special appeals held that Rivera’s no-driving condition of probation violated the separation of powers doctrine. The State filed a petition for writ of certiorari with the Court of Appeals in both cases. The Court consolidated the cases to address the common questions of law and fact and held (1) Sheppard v. State, which prohibits a court from restricting a defendant’s driving privileges as a condition of probation under certain circumstances, was wrongly decided and is thus overruled; and (2) in Meyer, the circuit court properly denied the defendant’s motion to correct an illegal sentence, and in Rivera, the court of appeals’ judgment holding that the no-driving condition of probation violated the separation of powers doctrine is reversed. View "Meyer v. State" on Justia Law

Petitioner was convicted of first degree murder and sentenced to life imprisonment. The Court of Special Appeals affirmed. Two issues were presented in this appeal, first, whether Petitioner’s statement, “I don’t want to say nothing. I don’t know” was an ambiguous or clear invocation of his right to remain silent under Miranda, and second, whether Petitioner’s confession, given after he waived his Miranda rights, was voluntary or the product of inducement. The Court of Appeals affirmed, holding (1) Petitioner’s statement, “I don’t want to say nothing. I don’t know” was an ambiguous invocation of his right to remain silent; and (2) Petitioner’s confession was voluntary. View "Williams v. State" on Justia Law

Petitioners, registered Republican voters and duly elected members of the Republican Central Committee of Carroll County (Committee), filed a complaint for mandamus, declaratory judgment, and injunctive relief seeking to enjoin the Committee from submitting more than one name to the Governor to fill a vacancy in the House of Delegates. Thereafter, Petitioners filed an amended complaint along with a motion for a temporary restraining order. The circuit court denied all relief sought. The Court of Appeals affirmed, holding that Md. Const. art. III, 13 does not impose a duty on a party central committee to submit any fixed number of names to the Governor to fill a vacancy. Instead, a party central committee may submit multiple names to fill a vacancy, and the Governor must appoint a person from among those whose names were submitted. View "Fuller v. Republican Cent. Comm’n" on Justia Law

In 2012, Petitioner voluntarily consented to a search of his person in the form of saliva and penile swabs for the purpose of furnishing DNA evidence to the police department to use in the investigation of a rape allegation. The DNA profile created from the extraction of Petitioner’s DNA excluded Defendant as a suspect of the alleged rape. Defendant’s DNA profile was subsequently uploaded to the local DNA database. Later, an automatic search resulted in a match between Defendant’s DNA profile and a DNA profile associated with an unsolved burglary committed in 2008. Based on that DNA evidence, Defendant was charged with burglary and related charges. Defendant moved to suppress the State’s DNA match evidence on the grounds that the subsequent use of his DNA to conduct a comparison search of the DNA databank exceeded the scope of his consent and therefore constituted an unlawful search under the Fourth Amendment. The suppression hearing judge denied the motion. The Court of Appeals affirmed, holding that, where Defendant’s consent to search was not expressly limited by him, the State, or the law, the Fourth Amendment did not preclude the police from retaining and using Defendant’s DNA profile created from his voluntarily provided DNA sample for additional, unrelated criminal investigations. View "Varriale v. State" on Justia Law

After a jury-waived trial, Petitioner was convicted of possession of oxycodone with intent to distribute. Petitioner appealed, arguing that he was entitled, by application of the rule established in Riley v. California, decided by the Supreme Court, to suppression of the evidence obtained as the result of the search of his cell phone incident to his lawful arrest. The Court of Appeals affirmed, holding that the officer who searched Petitioner’s cell phone acted in good faith on then-controlling authority in Maryland in searching Petitioner’s cell phone, and therefore, Petitioner was not entitled to have the cell phone data excluded at trial. View "Demby v. State" on Justia Law

Petitioner was convicted of possession with intent to distribute marijuana, possession of marijuana, and possession of drug paraphernalia. Petitioner appealed the denial of his motion to suppress text messages that the police obtained during the warrantless search of his cell phone incident to his lawful arrest. The Court of Appeals affirmed, holding that the trial court properly denied Petitioner’s motion to suppress the data obtained from his cell phone, as (1) in light of the U.S. Supreme Court’s decision in Riley v. California, officers must generally secure a warrant before conducting searches of data on cell phones; but (2) the police in this case acted in good faith on then-controlling authority in Maryland in searching Petitioner’s cell phone, and therefore, Petitioner was not entitled to suppression of the data obtained from his cell phone. View "Spence v. State" on Justia Law

Defendant was charged with carjacking and related offenses, various firearms offenses, and possession of illicit drugs. The morning of trial, Defendant’s attorney made an oral motion seeking to exclude evidence derived from a flip cell phone that was seized from Defendant incident to his arrest. The primary evidence obtained from the cell phone was a screen saver image that matched the custom wheel rims of the stolen car. The circuit court denied the motion to suppress. After a jury trial, Defendant was found guilty. The court of special appeals affirmed. Before the Court of Appeals, Defendant relied on the U.S. Supreme Court’s intervening decision in Riley v. California to argue that the arresting officer’s review of photos on Defendant’s cell phone without a warrant was an unconstitutional search, and therefore, the evidence derived from the cell phone should have been suppressed. The Supreme Court affirmed, holding (1) Defendant waived his motion to suppress by failing to make his motion within the time period and with the specificity required by the Maryland Rules; and (2) even had the motion been made in a timely manner, the screen saver image was admissible under Riley. View "Sinclair v. State" on Justia Law

Defendant was charged with armed robbery. During trial, a DNA expert testified regarding the work of another DNA analyst. The expert was a supervisor in the same lab, reviewed the work of the other analyst, and came to his own conclusion that was consistent with the conclusion of the other analyst. The analyst herself, however, did not testify. The Court of Special Appeals concluded that the admission of the DNA case report without the analyst’s testimony violated Defendant’s ability to confront his accuser. The Court of Appeals affirmed, holding that the language “within a reasonable degree of scientific certainty” in the DNA report rendered the report testimonial within Williams v. Illinois. View "State v. Norton" on Justia Law