Justia Maryland Supreme Court Opinion Summaries

Petitioner was charged with conspiracy to commit theft, making a false statement to the police while under arrest, and related offenses after the vehicle in which he was an occupant was stopped by police officers and the police discovered multiple fake credit cards in the wallet of a female passenger. The police then arrested all occupants of the vehicle. Petitioner filed a motion to suppress, contending that the evidence was obtained as a result of an illegal stop. The circuit court denied the motion to suppress. Defendant appealed, contending that his Fourth Amendment rights were violated because the police lacked probable cause to arrest him. The court of special appeals held that police had probable cause to arrest Petitioner and therefore any evidence obtained by police as the fruit of that arrest was not subject to suppression. The Supreme Court affirmed, holding that Petitioner's claim was not properly before the appellate courts because Petitioner waived it by not raising it before the circuit court.View "Ray v. State" on Justia Law

Appellees in this case were seventeen-year-olds who would have been eighteen by the 2008 general election. After exhausting their administrative remedies, Plaintiffs filed separate complaints in the circuit court against the Maryland State Boar of Elections (MSBE), alleging that the MSBE violated several provisions of the Election Law Article by prohibiting seventeen-year-olds who would be eighteen by the next general election from casting any votes in non-partisan primary elections for county school boards. The circuit court concluded that the voter eligibility requirements of the Maryland Constitution did not apply to non-partisan elections for Boards of Education, municipal elections, and local ballot questions not mandated by the Constitution. The Court of Appeals vacated the circuit court and held that seventeen-year-olds who will turn eighteen by close of voter registration before the next general election were constitutionally and statutorily entitled to vote in primary elections, whether partisan or non-partisan, subject to all other provisions of the Constitution and statutory election law. Remanded.View "State Bd. of Elections v. Snyder" on Justia Law

The supervisory employee exception to the handgun law allows such an employee to carry a handgun, with the employer's permission, within the enclosed premises of the business in which the employee works. Petitioner, the head of security for a nightclub, was arrested by the county police for carrying a handgun without a permit in the open parking lot of the nightclub. Petitioner filed a lawsuit against the county and three of the police officers involved in his arrest for a violation of the Maryland Declaration of Rights, false arrest and imprisonment, and malicious prosecution, contending that his arrest was illegal because the parking lot should be considered to be "within the confines" of the nightclub. A jury found in favor of Petitioner on his state constitutional claim and on the false arrest and imprisonment claim. The court of special appeals reversed, holding that the parking lot of the club was not "within the confines of the business establishment." The Court of Appeals affirmed, holding that when Petitioner left the "confines" of the nightclub and took his handgun into the parking lot, he was no longer with the supervisory employee exception to the handgun law.View "Blue v. Prince George's County" on Justia Law

In two separate cases, Petitioner was convicted of second-degree murder and two counts of solicitation to obstruct justice, among other offenses. The cases were consolidated for appeal, and the court of special appeals affirmed. At issue before the Court of Appeals, among other things, was whether the trial court abused its discretion in disqualifying one of Petitioner’s defense counsel, who had a previous attorney-client relationship with a key state’s witness, where the witness refused to waive the conflict of interest and Petitioner’s counsel had arranged for co-counsel to cross-examine the witness. The Court of Appeals affirmed, holding (1) the trial court did not abuse its discretion in disqualifying Petitioner’s attorney, as Petitioner’s waiver of the conflict was not sufficient to cure the conflict; and (2) merger was precluded for convictions of the two counts of solicitation, where the relevant statutes contained parallel anti-merger provisions. View "Alexis v. State" on Justia Law

Petitioner was charged with certain traffic offenses in the district court. The district court acquitted Petitioner as to the charge of disobeying a lawful order or direction of a police officer but convicted Petitioner of four counts of fleeing and eluding police. Petitioner filed notice of a de novo appeal. Prior to trial, Petitioner filed a motion to dismiss the fleeing and eluding counts, arguing that, because he was acquitted of disobeying a lawful order, prosecution of the fleeing and eluding charges would violate the state and federal prohibitions against double jeopardy. The circuit court denied the motion. The Supreme Court affirmed, holding that prosecution of the fleeing and eluding charges did not violate the prohibitions against double jeopardy or the doctrine of collateral estoppel. View "Scriber v. State" on Justia Law

After a jury trial, Petitioner was found guilty of two counts of first-degree murder and related offenses. Petitioner appealed the denial of his motion to suppress the contents of a storage locker belonging to him, arguing that it was the tainted fruit of the consent he had given to police while he was unlawfully detained at the police station. The court of special appeals affirmed the conviction. The Court of Appeals affirmed, holding (1) the police obtained Petitioner’s consent to search his locker during their lawful detention of him; and (2) therefore, the suppression court correctly ruled that Petitioner was not entitled to suppression of the evidence found in the locker. View "Barnes v. State" on Justia Law

Defendant was charged with misuse of telephone facilities and harassment. Prior to the start of trial, Defendant’s public defender informed the court: “Your Honor, on behalf of [Defendant], I’d request a postponement. He indicates that he would like to hire private counsel in this matter.” The trial judge denied postponement, and, after a trial, Defendant was convicted as charged. Defendant appealed, arguing that reversal was required because the trial court denied his request to obtain private counsel without complying with the requirements of Md. R. Crim. P. 4-215(e). The court of appeals affirmed, concluding that Defendant did not express a “clear intent” to discharge or replace his attorney, and therefore, Rule 4-215(e) was not implicated. The Court of Appeals reversed, holding (1) when an ambiguous statement by a defendant or his or her counsel is made under Rule 4-215(e), the trial judge must engage in a Rule 4-215(e) colloquy with the defendant; and (2) in this case, the trial judge could have reasonably concluded from defense counsel’s statements that Defendant wanted to discharge his attorney and thus had a duty to engage in a Rule 4-215(e) colloquy with Defendant. View "Gambrill v. State" on Justia Law

The State charged Petitioner with various drug-related crimes. Petitioner’s co-defendant filed three proposed voir dire questions asking whether any prospective juror had ever been the victim of a crime or a member of a law enforcement agency. The circuit court declined to ask any of the proposed voir dire questions. The jury ultimately convicted Petitioner of drug-related crimes. The court of special appeals affirmed. The Court of Appeals reversed, holding (1) a trial court need not ask during voir dire whether any prospective juror has ever been the victim of a crime, but, on request, a trial court must ask whether any of the prospective jurors have strong feelings about the crime with which the defendant is charged; and (2) where all of the State’s witnesses are members of law enforcement agencies and/or where the basis for a conviction is reasonably likely to be the testimony of members of law enforcement agencies, on request, a trial court must ask during voir dire whether any of the prospective jurors have ever been a member of a law enforcement agency. View "Pearson v. State" on Justia Law

Petitioner was charged with various offenses, including reckless endangerment. Because the indictment did not set out the elements of the charged offense or the factual basis for that offense, Petitioner requested that the State provide him with a bill of particulars. Rather than answer each question Petitioner asked in his request, the State simply directed Petitioner to discovery. The trial court overruled Petitioner’s exceptions, finding that the State’s responses satisfied the statutory requirement that the State’s response “furnish the particulars sought.” A jury found Petitioner guilty of reckless endangerment. Petitioner appealed, arguing that the trial court abused its discretion by denying his exceptions to the State’s non-specific responses to the questions posed in his request for a bill of particulars. The court of special appeals affirmed. The Court of Appeals reversed, holding (1) the State’s responses to the questions posed in Petitioner’s demand for a bill of particulars were inadequate; and (2) therefore, the trial court abused its discretion when it overruled Petitioner’s exceptions to those responses. View "Dzikowski v. State" on Justia Law

In two cases, Montgomery County took a portion of properties owned by Respondents. Because the parties disputed the value paid for either taking the County filed a complaint for condemnation. During the proceedings, the circuit court imposed discovery violation sanctions precluding Respondents from introducing evidence as to the fair market value of the taken properties. Respondents were therefore unable to generate a genuine issue of material fact concerning the County's appraisal valuations. As a result, the circuit court granted summary judgment for the County on the issue of just compensation. The court of special appeals reversed, concluding that summary judgment on the question of just compensation is not available in condemnation proceedings because a property owner cannot be deprived of the constitutional right to have a jury determine just compensation. The Court of Appeals reversed, holding (1) permitting summary judgment does not violate the constitutional right to have the opportunity for a jury trial to ascertain just compensation in compensation actions provided the landowner litigates the case according to the Maryland Rules; and (2) summary judgment was properly granted in each case because there was no genuine dispute of material fact and the County was entitled to judgment as a matter of law. View "Montgomery County v. Soleimanzadeh" on Justia Law