Justia Maryland Supreme Court Opinion Summaries

After a jury trial, Petitioner James Sweetney was convicted of robbery and related offenses, including use of a handgun in the commission of a crime of violence. At issue on appeal was whether Petitioner's constitutional right of confrontation was violated when the trial court curtailed Petitioner's cross-examination of the State's detective regarding the contents of a search warrant return that directly contradicted the detective's direct testimony about recovering a key piece of evidence. The court of special appeals affirmed. The Court of Appeals affirmed, holding that the trial court did not abuse its discretion in curtailing the cross-examination of the State's detective about ambiguous language in the out-of-court statement prepared by another law enforcement officer who did not testify at trial. View "Sweetney v. State" on Justia Law

Petitioner Erick Spencer was convicted of robbery, theft over $500, and second degree assault. On appeal, Spencer challenged the sufficiency of the evidence to sustain his robbery conviction. The Court of Appeals reversed the robbery conviction, holding that the State failed to prove an essential element of the crime of robbery. Although the State in this case presented evidence showing that Spencer entered an automobile service center and stated to the cashier, "Don't say nothing," there was no evidence that Spencer conducted himself in a manner that could cause apprehension in a reasonable person that Spencer was about to apply force. Remanded. View "Spencer v. State" on Justia Law

Petitioner, trustee of two trusts owning several hundred ground rent leases, failed to register the trusts' ground leases with the State Department of Assessments and Taxation (SDAT) as required by the state's Ground Rent Registry Statute. Petitioner instead filed an action requesting a declaratory judgment that the Statute was unconstitutional and an injunction prohibiting the SDAT from issuing extinguishment certificates regarding the trusts' ground leases as required by the Statute. The circuit court granted summary judgment in favor of SDAT and issued a declaratory judgment stating that the Statute was constitutional. The Court of Appeals reversed, holding (1) the extinguishment and transfer provisions of the Statute were unconstitutional under Maryland's Declaration of Rights and Constitution; and (2) the registration requirements were constitutional under federal and Maryland constitutional principles. Remanded. View "Muskin v. State Dep't of Assessments & Taxation" on Justia Law

After a jury trial, Petitioner Khiry Montay was convicted of first-degree felony murder and related offenses, including use of a handgun in the commission of a crime of violence. The court of special appeals affirmed. The Court of Appeals reversed, holding (1) Petitioner's confession, which was obtained when he was one month past his sixteenth birthday, should have been suppressed as involuntary for several reasons, including the fact that the police unnecessarily delayed presenting Petitioner to a district court commissioner in order to interrogate him and the fact that the police ignored thirteen requests by Petitioner to speak to his mother; and (2) Petitioner was entitled to a new trial at which the State was prohibited from introducing evidence of Petitioner's inculpatory statement. Remanded. View "Moore v. State" on Justia Law

In a guardianship proceeding, the juvenile court granted guardianship of Child to the Department of Social Services (DSS). Mother was deemed to have consented to the guardianship because neither she nor her appointed attorney filed a timely notice of objection on her behalf. The court of special appeals reversed. At issue on appeal was whether Mother had a statutory right to effective assistance of counsel despite her failure to file a timely notice of objection and request for counsel. Mother asserted that because DSS alleged that Mother was disabled, she had a right to counsel in the guardianship proceeding. The Court of Appeals affirmed, holding (1) once counsel for Mother had entered her appearance, at the request of DSS and after DSS alleged that Mother may have been disabled, Mother thereafter had a right to effective assistance of counsel as an allegedly disabled parent in a guardianship proceeding; (2) counsel rendered ineffective assistance because, after entering her appearance on behalf of Mother, counsel failed to preserve Mother's right to challenge the guardianship proceedings by failing to file a timely notice of objection; and (3) Mother was entitled to file a belated notice of objection. View "In re Adoption of Chaden M." on Justia Law

Petitioner Mark Denisyuk, a noncitizen, pleaded guilty to a deportable offense. Petitioner later filed a petition for postconviction relief, asserting that defense counsel was constitutionally ineffective by failing to notify him of the deportation risks of his guilty plea. The postconviction court held that Petitioner was prejudiced by defense counsel's failure to provide proper advice concerning immigration consequences. The court of special appeals reversed, holding that deportation was a collateral consequence of a criminal conviction and therefore did not fall within the scope of the Sixth Amendment's guarantee of effective assistance of counsel. Two days later, the U.S. Supreme Court decided Padilla v. Kentucky, which held that it is ineffective assistance to disadvise, or fail to advise, a client that deportation is a likely consequence of the guilty plea. On review, the Court of Appeals vacated the court of special appeals, holding (1) Padilla applies to postconviction claims arising from guilty pleas obtained after the enactment of the Illegal Immigration Reform and Immigrant Responsibility Act of 1996; and (2) in this case, defense counsel's failure to advise Petitioner of the deportation consequence of his guilty plea was constitutionally deficient, and counsel's deficient performance prejudiced Petitioner. Remanded for a new trial. View "Denisyuk v. State" on Justia Law

Plaintiffs, a minor and her mother, sued Defendants, owners of residential rental properties, for negligence and deceptive practices in violation of the Maryland Consumer Protection Act after the minor suffered brain injuries allegedly resulting from her ingestion of lead-based paint at one of Defendants' properties. Defendants moved for summary judgment, contending that they had complied with the Reduction of Lead Risk in Housing Act by registering their property, and therefore, they were immune from suit under the immunity provisions of the Act. The circuit court granted summary judgment for Defendants, holding (1) the Act's provisions granting immunity were constitutional, and (2) Defendants' registration renewals were timely because they were mailed on December 31. The court of special appeals reversed, holding that Defendants were not entitled to qualified immunity because they did not fully comply with the Act where the renewal of their registration was not received by December 31. The Court of Appeals reversed and remanded with directions to reverse the circuit court, holding that the immunity provisions in the Act were invalid under the Maryland Declaration of Rights because no adequate remedy was substituted for the grant of immunity and the victim was uncompensated for her injuries. View "Jackson v. Dackman Co." on Justia Law

After a jury trial, Petitioner William Briscoe was convicted of possessing a regulated firearm after having been convicted of, inter alia, possessing cocaine and wearing, carrying, or transporting a handgun in a vehicle. The convictions were based on evidence law enforcement officers recovered while searching Petitioner's vehicle and glove compartment at the time of his arrest. Petitioner sought suppression of the handgun, claiming it was the fruit of an illegal search. The circuit court denied the motion. While Defendant's appeal was pending, the Supreme Court decided Arizona v. Gant. The State conceded that, under Gant, the search violated the Fourth Amendment but argued that Petitioner was not entitled to suppression by application of the good-faith exception to the Fourth Amendment's exclusionary rule. The court of special appeals did not reach the Gant issue, holding instead that the handgun was recovered during a valid inventory search. The Court of Appeals affirmed but on different grounds, holding (1) the search of the glove compartment was not a valid inventory search, but (2) the good-faith exception to the exclusionary rule applied to what, at the time, was a lawful search of the glove compartment. View "Briscoe v. State" on Justia Law

Petitioner Christopher Mansfield was tried in a bench trial at the circuit court on five counts charging statutory sex-related offenses. At the close of the evidence, the trial judge, sua sponte and over Petitioner's objection, declared a mistrial, explaining that her knowledge of Petitioner's prior convictions and the partiality it engendered made a mistrial manifestly necessary. Petitioner moved to dismiss the indictment on double jeopardy grounds, arguing that there was not manifest necessity for the granting of the mistrial where the trial judge had knowing of Petitioner's prior convictions well before the trial began. The motions judge and the court of special appeals upheld the decision. The Court of Appeals reversed, holding that under these circumstances, when it is the court that is the trier of facts, and the court's impartiality, whether due to a personal bias or prejudice toward a criminal defendant or an inability to resolve disputed factual allegations, is impaired, manifest necessity does not exist when the reasonable alternative of recusal existed prior to jeopardy attaching. Remanded. View "Mansfield v. State" on Justia Law

Petitioners were nonresidents who neither lived nor worked in Maryland but had a source of income in the State. In 2005, the Comptroller of the Treasury issued a notice of assessment against Petitioners' 2004 joint Maryland nonresident income tax returns for failure to pay the Special Nonresident Tax (SNRT). The assessment included the amount owed for the SNRT and interest. Petitioners challenged, on federal and state constitutional grounds, the State's authority to impose the SNRT. The tax court (1) declared the SNRT to be constitutional, and (2) denied Petitioners' request to abate the accrued interest, reasoning that the court lacked the authority to do so. The circuit court affirmed as to the constitutionality of the tax but determined that the tax court could abate the interest assessment. The court of special appeals affirmed. The Court of Appeals affirmed, holding (1) the SNRT does not violate the Commerce Clause, the Equal Protection Clause, or the Privileged and Immunities Clause of the U.S. Constitution; (2) the SNRT does not violate Maryland's equal protection doctrine; and (3) the tax court's power of review extends to the abatement of interest assessments. Remanded to consider whether Petitioners were entitled to the abatement of interest. View "Frey v. Comptroller of the Treasury" on Justia Law