Justia Maryland Supreme Court Opinion Summaries

The Court of Appeals affirmed the judgment of the court of special appeals affirming the circuit court's denial of Defendant's motion to suppress, holding that the court of special appeals did not err in holding that the placement and use of a GPS tracking device was legal.In investigating suspected drug distribution activities Harford County Narcotics Task Force applied for and received an "application for court order" to install a GPS tracking device on Defendant's vehicle. The Task Force detectives subsequently applied for a received a search warrant for Defendant's vehicle and suspected residence. After the search warranted was executed, Defendant was indicted on drug-related charges. Defendant filed a motion to suppress, arguing that the GPS tracking of his vehicle was unconstitutional. The circuit court held that the search warrant lacked probable cause but that the good faith exception to the exclusionary rule applied. Defendant then entered a conditional guilty plea. The court of appeals affirmed. The Court of Appeals affirmed, holding (1) the use of the GPS tracking device was legal because the GPS order satisfied the Fourth Amendment warrant requirement; (2) the issuing judge had substantial evidence for finding probable cause; and (3) the good faith exception to the Fourth Amendment exclusionary rule applied in this case. View "Whittington v. State" on Justia Law

The Court of Appeals affirmed the judgment of the circuit court denying Defendant's motion to suppress, holding that, under the circumstances presented in this case, the police had reasonable suspicion to conduct a brief investigatory detention of Defendant, and the stop did not violate the parameters of the Fourth Amendment.In response to an anonymous 911 call that provided the location and license plate of a vehicle driven by a possibly intoxicated driver, the responding police officer located he vehicle in a parking lot, knocked on the window, and spoke to Defendant, who admitted to having had multiple drinks and that his driver's license was revoked. Defendant was arrested after he was unable to successfully complete a field sobriety test. On appeal, Defendant argued that the anonymous call could not support a finding of reasonable suspicion. The Supreme Court affirmed, holding that, under the totality of the circumstances, the stop at issue comported with the reasonable suspicion requirement of the Fourth Amendment. View "Trott v. State" on Justia Law

The Court of Appeals affirmed the denial of Clear Channel Outdoor, Inc.'s request for a refund of the taxes that it paid pursuant to a Baltimore City ordinance for the privilege of selling advertising on billboards that are not located on the premises where the goods or services being advertised were offered or sold, holding that the ordinance is constitutional.Clear Channel, which was in the business of selling advertising on its billboards in Baltimore City, sought a refund from the City Director of Finances of the taxes it paid pursuant to the city ordinance at issue. Clear Channel claimed that the ordinance was unconstitutional under the First and Fourteenth Amendments and Article 40 of the Maryland Declaration of Rights. The City denied a refund, and the Maryland Tax Court affirmed. The circuit court and court of appeals affirmed. The Supreme Court affirmed, holding that the ordinance survives the application of a rational basis test and, accordingly, is constitutional. View "Clear Channel Outdoor, Inc. v. Department of Finance of Baltimore City" on Justia Law

The Court of Appeals affirmed the judgment of the court of special appeals affirming the denial of Defendant's motion for new trial on the grounds that certain newly discovered evidence was immaterial, holding that there was no Brady violation in this case.Defendant was convicted of two counts of first-degree murder. Following the trial but prior to sentencing, the State informed Defendant's counsel of an interview that took place between two detectives and the family members of one of the State's witnesses. Defendant moved for a new trial, arguing that the nondisclosure of the interview violated Brady v. Maryland, 373 U.S. 83 (1963). The circuit court denied the motion, finding that the evidence of the interview was not material. The Court of Appeals affirmed, holding that the nondisclosure of the interview did not constitute a Brady violation. View "Canales-Yanez v. State" on Justia Law

The Court of Appeals affirmed the judgment of the court of special appeals reversing Defendant's convictions on the grounds that the circuit court should have granted Defendant's motion to suppress, holding that the State failed to meet its burden of establishing the constitutionality of Defendant's seizure at the suppression hearing.When Maryland Transit Administration (MTA) police officers conducted a fare sweep aboard a Light Rail train Defendant confessed that he did not have a ticket. An officer obtained identifying information from Defendant and ran a warrant check on him revealing the existence of a warrant for Defendant's arrest. In attempting to arrest Defendant, officers saw that Defendant had a gun. Defendant moved to suppress the gun, arguing that the fare sweep constituted a warrantless seizure not based on reasonable suspicion. The circuit court denied the motion to suppress. The court of special appeals reversed, concluding that the circuit court erred in denying Defendant's suppression motion. The Court of Appeals affirmed, holding (1) police officers effected a seizure of Defendant without reasonable suspicion by announcing the fare sweep, and Defendant did not impliedly consent to the seizure by riding the train; and (2) the record was insufficiently developed to conclude whether Light Rail sweeps are constitutional under the special needs doctrine. View "State v. Carter" on Justia Law

The Court of Appeals affirmed Defendant's convictions for sexually abusing several female students while he was their elementary school teacher, holding that any error by the trial court in excluding character evidence of appropriateness with children in Defendant's custody or care was harmless beyond a reasonable doubt.On appeal, Defendant argued that the trial judge erred by excluding evidence from parents of students and from professional colleagues that, in their opinion, Defendant was the type of person who behaved appropriately with children in his custody or care. The Court of Special Appeals affirmed. The Court of Appeals also affirmed, holding (1) character evidence of appropriateness with children in one's custody or care may be admissible in a criminal case where a defendant is accused of sexually abusing a child; (2) any error in excluding Defendant's proffered character evidence was harmless beyond a reasonable doubt; and (3) Defendant's constitutional arguments were not preserved for appellate review or abandoned and, in any event, lacked merit. View "Vigna v. State" on Justia Law

The Court of Appeals held that the City of Baltimore's street vending ordinance that restricts a food truck from parking within 300 feet of a brick-and-mortar restaurant that primarily sells the same type of food (the Rule) is constitutional.The owners of two food trucks (the Food Trucks) filed suit against the Mayor and City Council of Baltimore claiming that the Rule violates Article 24 of the Maryland Declaration of Rights by restricting the Food Trucks' ability to practice their trade. The circuit court held that the Rule does not violate Article 24's requirements of equal protection and substantive due process but proceeded to enjoin the City from enforcing the Rule, concluding on its own initiative that the Rule is impermissibly vague. The Court of Appeals reversed the circuit court's grant of injunctive relief, concluding that the Food Trucks had not preserved a vagueness claim for appellate review and that, in any event, the claim failed on the merits. The Court of Appeals affirmed, holding that the Rule does not deprive mobile vendors of their substantive due process and equal protection rights under Article 24 and that the Rule is not void for vagueness. View "Pizza di Joey v. Mayor & City Council of Baltimore" on Justia Law

The Court of Appeals reversed the decision of the court of special appeals reversing the decision of the post-conviction court granting Petitioner post-conviction relief based on the court's finding that Petitioner received ineffective assistance of counsel, holding that Petitioner's counsel rendered ineffective assistance based on a conflict of interest.Petitioner pleaded guilty to possession with intent to distribute a controlled dangerous substance. Petitioner subsequently filed a petition for post-conviction relief, alleging that he received ineffective assistance of counsel because he was misadvised of the immigration consequences of his plea agreement and because his counsel failed to disclose a personal conflict of interest. The post-conviction court granted Petitioner relief based on the court's finding of an actual conflict of interest. The court of special appeals reversed. The Court of Appeals reversed, holding that defense counsel's conflict of interest rendered his representation of Petitioner constitutionally deficient under the Sixth Amendment to the United States Constitution and Article 21 of the Maryland Declaration of Rights. View "Podieh v. State" on Justia Law

The Court of Appeals held that the odor of marijuana on or about a person, without more, does not provide law enforcement officers with probable cause to arrest and perform a warrantless search of that person incident to the arrest.Defendant filed a motion to suppress, arguing that he was unlawfully seized and subjected to a search incident to arrest. In denying Defendant's motion to suppress, the suppression court ruled that the odor of marijuana gave police probable cause to arrest Defendant and, incident to the arrest, conduct a full search of Defendant's person. The Court of Special Appeals affirmed. The Court of Appeals reversed, holding (1) the mere odor of marijuana emanating from a person, without more, does not provide the police with probable cause to support an arrest and a search of the arrestee; and (2) because the search of Petitioner was based solely on the odor of marijuana emanating from his person, the officer lacked the requisite probable cause to conduct that search. View "Lewis v. State" on Justia Law

In this criminal case in which Defendant was charged with various drunk driving offenses the Court of Appeals reversed the judgment of the trail court denying Defendant's motions in limine to exclude field sobriety tests and a breath test from the evidence, holding that, in giving advice of rights, law enforcement officers must use methods that reasonably convey the warnings and rights in the implied consent statute.Police officers found Defendant asleep at the wheel of his truck and brought him to the station after he failed several field sobriety tests. An officer read in English an "Advice of Rights" form, commonly referred to as a DR-15 form, to Defendant, who spoke Spanish. Defendant signed the DR-15, agreeing to take a breath test, and failed the test. Defendant moved to exclude the tests, arguing that he did not understand the field sobriety test instructions or the advice of rights because he did not understand English. The trial court denied the motions, and Defendant was convicted. The Supreme Court reversed and remanded for a new trial at which the breath test evidence must be suppressed, holding that the officer in this case did not use methods that reasonably conveyed the warnings and rights in the implied consent statute. View "Funes v. State" on Justia Law