Justia Maryland Supreme Court Opinion Summaries

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

Complainants were disabled residents of a condominium. Complainants filed a complaint against the condominium's board of directors (the Condo) and their property management company, alleging that the Condo had discriminated against them by refusing to grant a reasonable accommodation for their disabilities. Specifically, Complainants alleged that the Condo refused to provide keys to the side and back doors to their building. The Office of Administrative Hearings ruled that Complainants had not proven that giving them the keys to the side and back doors was necessary and reasonable. The Appeal Board of the Commission on Human Relations (Board) disagreed and determined that the Condo (1) was required to prove that giving Complainants keys was an unreasonable financial burden, and (2) failed to establish that giving Complainants keys presented an undue burden. The circuit court reversed. The court of special appeals vacated the circuit court's decision. The Court of Appeals affirmed, holding (1) the Condo was required to prove that providing keys to Complainants was unreasonable in light of the costs attendant in doing so; and (2) the Board properly performed the requisite balancing test when it concluded the Condo unreasonably denied Complainants' requests to be given the disputed keys. View " Cameron Grove Condo. Bd. of Dirs. v. Comm'n on Human Relations" on Justia Law

On March 30, 2009, Petitioner committed a theft of property. After a trial held on December 11, 2009, Petitioner was convicted of the theft of property having a value of $615. Petitioner was sentenced to ten years in prison. On October 1, 2009, amendments to the Maryland theft statute took effect that would have made Petitioner's crime a misdemeanor punishable by imprisonment not exceeding eighteen months, a $500 fine, or both. The Court of Appeals granted a petition for a writ of certiorari to decide whether the penalty provisions of the 2009 theft statute amendments were applicable to Petitioner's sentencing. The Court reversed, holding that the sentence imposed upon Petitioner was illegal because it was not authorized by the statute in effect at the time of his trial and sentencing. Remanded. View "Waker v. State" on Justia Law

After a jury trial, Defendant was convicted of second-degree assault in connection with an attack on his girlfriend. The court of special appeals affirmed. At issue before the Court of Appeals was whether the trial court acted within its discretion in responding to a jury question concerning evidence that was not presented at trial. The Supreme Court affirmed, holding that the trial court acted within its discretion in crafting the jury response it did, as (1) trial courts have a duty to answer, as directly as possible, the questions posed by jurors; (2) the circuit court's response in this case closely tracked a pattern jury instruction given earlier; (3) the court's answer did not contradict the trial judge's earlier instructions; and (4) the answer given allowed the jury to draw what inferences it might from the evidence without the court impermissibly suggesting what inferences to draw. View "Appraicio v. State" on Justia Law

This case involved the adoption of a minor child, Sean, by his stepfather. William, the putative father of Sean, filed an objection to the stepparent adoption one day after the expiration of the thirty-day deadline provided by the show cause order issued by the circuit court. The trial court granted Stepfather's motion to strike William's untimely objection and directed that the adoption proceed as an uncontested matter, noting that William did not allege any circumstance to excuse his failure to timely file his objection. The court of special appeals affirmed. The Court of Appeals affirmed, holding (1) William's failure to file a timely objection constituted an irrevocable consent to the adoption of Sean; and (2) the deemed consent statutory scheme of the Maryland Family Law Article and the Maryland Rules does not offend due process. View "In re Adoption of Sean M." on Justia Law

In 2006, Petitioner was convicted of child sexual abuse. Petitioner's conviction was based on his inappropriate contact with a minor during the 1983-84 school year when Petitioner was employed as a school teacher. Petitioner was sentenced to ten years incarceration with three years supervised probation upon release. In 2008, Petitioner was released early from prison. In 2009, the General Assembly passed a new law changing the sex offender registration requirements. The new statute retroactively required a child sex offender who committed a sex offense prior to October 1, 2005, but was convicted on or after October 1, 1995, and had not previously been required to register under Maryland law, to now register as a child sex offender. In October 2009, Petitioner unsuccessfully sought a declaration that he not be required to register as a sex offender under the statute. The Supreme Court reversed, holding that the imposition of the registration requirement upon Petitioner violated the ex post facto prohibition contained in the Maryland Declaration of Rights. View "Doe v. Dep't Of Pub. Safety & Corr. Servs." on Justia Law

Railroad employee (Employee) filed suit against his employer (Railroad) under the Federal Employers Liability Act (FELA), alleging that Railroad was negligent in its use of large ballast rather than small ballast in areas where Employee worked. Employee claimed that walking on the large ballast caused him to develop osteoarthritis in both knees. A jury found Railroad seventy percent negligent and Employee twenty percent negligent and awarded Employee $1,246,000 for his injuries. The court of special appeals affirmed. At issue before the Supreme Court was whether and when a railroad employee's negligence action under FELA may be precluded by the Federal Railroad Safety Act (FRSA). The Supreme Court affirmed, holding (1) a negligence action alleging the improper use of ballast will be precluded only to the extent to which the ballast performs a track-support function, and under such circumstances, the railroad should bear the burden of proving the facts that support preclusion; and (2) here, Employee's FELA claim was not precluded by FRSA because Railroad failed to prove that the ballast complained of performed a track-support function. View "CSX Transp., Inc. v. Pitts" on Justia Law

In 1998, Appellant pleaded guilty to child sexual abuse and third degree sexual offense. Upon conviction, Appellant was required to register as a sex offender for ten years. Since his conviction, however, the statutes changed to require lifetime registration for certain classes of sex offenders. Appellant sought declaratory relief in 2010, claiming he had satisfied the ten-year registration requirement and that he was not subject to lifetime registration. The circuit court declared that Appellant was subject to lifetime registration. The Supreme Court affirmed, holding that Appellant was required to register for life as a sex offender under Md. Code Ann. Crim. Proc. 11-707(a)(4)(iii) because his 1998 convictions made him a tier III sex offender under the current statutory scheme, and he was subject to lifetime registration on September 30, 2010, making retroactive application of the statute proper by its own terms. View "Ochoa v. Dep't of Pub. Safety & Corr. Servs." on Justia Law

Taxpayer, a Maryland resident, appealed an assessment by the State Comptroller that did not allow a credit against the county income tax portion of the Maryland income tax. Taxpayer's income consisted of significant "pass-through" income generated by a Subchapter S corporation in other states, which was apportioned to Taxpayer and taxed by the states in which it was generated. The tax court affirmed the assessment. The circuit court reversed and remanded for further factual development and "an appropriate credit for out-of-state income taxes paid" on the corporation's income. The Court of Appeals affirmed, holding that the failure of the Maryland income tax law to allow a credit against the county tax for a Maryland resident taxpayer with respect to pass-through income of an S corporation that arises from activities in another state and that is taxed in that state violates the dormant Commerce Clause of the federal Constitution. View "Md. State Comptroller v. Wynne" on Justia Law

The Maryland State Conference of NAACP Branches (NAACP), pursuant to the Public Information Act, requested certain records from the Maryland State Police Department (State Police) to ensure State Police officers did not engage in racial profiling during traffic stops and searches. Although the State Police did provide the NAACP with reports detailing the number and status of racial profiling complaints, the reports did not contain information concerning the State Police's own internal investigations of these complaints, as it considered those records portions of personnel files. The circuit court concluded that the records constituted personnel records but that they should be disclosed with redaction of names and identification. The court of special appeals held that the unredacted records were not exempt from disclosure, as the files did not constitute personnel records of an individual. The Court of Appeals affirmed but for different reasons, holding (1) the disclosure of unredacted records was not properly before the court of special appeals; and (2) the redacted records were not personnel records, and therefore, the circuit court did not err in its judgment. View "Md. Dep't of State Police v. Md. State Conf. of NAACP Branches" on Justia Law