Justia Maryland Supreme Court Opinion Summaries

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

Petitioners filed a petition for judicial review of the Baltimore City Council's approval of a planned unit development (PUD) with a Wal-Mart supercenter. Both Petitioners' residences were approximately 0.4 miles away from the PUD. The Mayor and City Council of the City, the owners of the property, and the developers of the PUD (Respondents) filed motions to dismiss, alleging that Petitioners lacked standing to challenge the PUD. The circuit court granted Respondents' motions and dismissed Petitioners' petition for review. The court of special appeals affirmed, concluding that Petitioners did not qualify for prima facie aggrieved status and that they had failed to show any special aggrievement different from the general public. The Supreme Court granted certiorari and held that the circuit court did not err in its judgment, as Petitioners failed to allege specific facts that they had been specially aggrieved in a manner different than the public generally. View "Ray v. Baltimore" on Justia Law

Petitioner, a Mexican immigrant who did not speak or comprehend English, was convicted of first degree murder and related offenses. Before trial, Petitioner sought suppression of a statement he made connecting him to the murder. On appeal, Petitioner argued that the State failed to prove that he was properly advised of, and validly waived, his Miranda rights. The court of special appeals concluded that the record developed at the suppression hearing sufficed to permit the court to rule that the Miranda warnings and Petitioner's waiver complied with constitutional dictates. The Supreme Court affirmed, holding that the suppression court reasonably could find, from the totality of the evidence offered by the State, that the State proved both that proper Miranda warnings were adequately conveyed to Petitioner and that he knowingly and voluntarily waived those rights before he was interrogated and made the statement he sought to suppress. View "Gonzalez v. State" on Justia Law

Defendant entered a plea of not criminally responsible to charges of first-degree attempted murder and was found incompetent to stand trial. Defendant was committed to the Perkins Hospital for several years waiting to become competent to stand trial. The charges against him were eventually dismissed pursuant to Md. Code Crim. Proc. 3-107(a), which requires dismissal of charges upon passage of certain time period. The State subsequently re-indicted Defendant, who was again found incompetent and placed at Perkins for another round of incompetency-to-stand-trial (IST) treatment. Defendant challenged his re-indictment, arguing that the State could not continue to confine him by re-indicting him on the same charges that were required to be dismissed. The appellate court reversed. The Supreme Court vacated the appellate court's ruling and remanded, holding (1) section 3-107 expressly provides that a dismissal of charges is without prejudice; but (2) nevertheless, Defendant's IST committment was improper, as (i) the passage of five years without Defendant's becoming competent and the resulting dismissal of his original charges under section 3-107 created the presumption that Defendant could not be restored to competency, and (ii) ordering Defendant in IST commitment, while the presumption that he was unrestorable was in place, was error. View "State v. Ray" on Justia Law