Justia Maryland Supreme Court Opinion Summaries

In this case, Montgomery County, Maryland, enacted amendments to its County Code in 2021 and 2022 regulating firearms. The amendments expanded the definition of “place of public assembly,” prohibited the possession of firearms (including “ghost guns”) in or within 100 yards of such places, and removed exceptions for state-issued handgun permit holders. The amendments also imposed new restrictions concerning minors’ access to firearms and regulated ghost guns and their components. The petitioners, two businesses and eight individuals, claimed these provisions were preempted by state law, not a valid local law, and amounted to an unconstitutional taking.After removal to federal court and a partial remand, the Circuit Court for Montgomery County ruled in favor of the challengers, finding the county’s provisions preempted by state law, not a local law, and an unconstitutional taking, and issued declaratory and injunctive relief. The Appellate Court of Maryland remanded for further analysis of preemption and takings issues, particularly concerning the expansion of “place of public assembly.”The Supreme Court of Maryland reviewed the case, holding that new issues may only be properly added by amending the complaint, not through summary judgment motions. The Court determined that Criminal Law § 4-209(b)(1) authorizes charter counties to regulate firearms in limited contexts (with respect to minors, law enforcement, and within 100 yards of certain public places), and that this authority was not abrogated by other state preemption statutes. The Court found Montgomery County’s regulation valid for parks, places of worship, schools, libraries, courthouses, legislative assemblies, recreational and multipurpose exhibition facilities, and polling places, but invalid for hospitals, health centers, long-term care, childcare facilities, government buildings as broadly defined, and generalized gatherings. The Court also clarified the scope of local regulation regarding minors and found no unconstitutional taking occurred. The judgment of the Appellate Court was vacated and remanded with instructions for further proceedings consistent with these holdings. View "Engage Armament v. Montgomery Cnty." on Justia Law

Miguel Angel Santana was charged with several offenses related to a 2016 murder. At his first trial in the Circuit Court for Charles County, a pretrial agreement excluded certain evidence about firearms, ammunition, and marijuana. The jury convicted him on two counts but hung on four others, resulting in a mistrial on those four counts. At the retrial on the remaining counts, a State witness referenced the excluded evidence during testimony, leading Santana’s counsel to move for a mistrial, which the court granted. Before a third trial could begin, Santana moved to dismiss the charges, arguing that Maryland common law should prevent retrial if the State’s reckless conduct caused the mistrial.The Circuit Court for Charles County denied Santana’s motion to dismiss. The court found that the State’s actions did not amount to recklessness, as the prosecutors had prepared the witness for his testimony and did not intend or expect him to reference the excluded evidence. The court concluded that the State's conduct, while unfortunate, was neither intentional nor reckless. Santana appealed, and the Appellate Court of Maryland affirmed the circuit court’s ruling, holding that Maryland’s common law double jeopardy protections did not apply because no factual findings on the criminal charges had been made and, even if the protections did apply, the circuit court’s finding was not clearly erroneous.The Supreme Court of Maryland reviewed the case to consider whether Maryland’s common law double jeopardy prohibition bars retrial after a mistrial caused by reckless State conduct, and whether the State acted recklessly here. The court assumed, without deciding, that Maryland law could bar retrial for reckless conduct, but held that the circuit court’s finding that the State was not reckless was not clearly erroneous. Accordingly, the Supreme Court of Maryland affirmed the judgment of the Appellate Court, permitting retrial to proceed. View "Santana v. State" on Justia Law

The Office of the Attorney General of Maryland initiated a criminal investigation into allegations of child sexual abuse and concealment by clergy and staff of the Archdiocese of Baltimore, based on a 2015 directive from the Governor authorizing the investigation and prosecution of “crimes of exploitation.” The Attorney General’s office issued grand jury subpoenas to the Archdiocese, leading to the production of voluminous records. No indictments were returned, but the Attorney General prepared a report naming over 150 individuals, including some accused of abuse and others alleged to have concealed abuse or failed to act. None of the individuals at issue, the Petitioners, were charged with crimes. The Attorney General sought court authorization to publicly disclose their identities, arguing that public accountability necessitated the release.The Circuit Court for Baltimore City found that the Attorney General had constitutional authority to conduct the investigation and prepare the report, and authorized disclosure of Petitioners’ identities, citing a particularized need for transparency and accountability. Petitioners appealed, and the Appellate Court of Maryland affirmed in part, agreeing that the Attorney General had investigatory authority and could prepare a report, but held that the Circuit Court should have made individualized findings regarding the need to disclose each Petitioner’s identity, and remanded for further analysis.Upon further review, the Supreme Court of Maryland affirmed that the Governor’s directive was within constitutional bounds and that the Attorney General’s office had the authority to investigate and report on child sexual abuse within the Archdiocese. However, the Court held that the interest in public accountability does not create a particularized need sufficient to overcome the secrecy of grand jury materials as to uncharged individuals who object. The Supreme Court of Maryland reversed the Appellate Court’s judgment and directed the Circuit Court to deny the Attorney General’s motion to disclose Petitioners’ identities. View "In Re: Criminal Investn. No. CID 18-2673 Balt. City Circuit Court" on Justia Law

The case arose from a criminal prosecution in which a defendant was charged with murdering his wife, claiming self-defense. During pretrial proceedings, the lead prosecutor, the Anne Arundel County State’s Attorney, conducted witness interviews alone, including one with a witness who relayed that the defendant stated his wife had previously threatened him with a knife—a fact potentially relevant to the defense. The State’s Attorney did not initially disclose this information to defense counsel, resulting in a discovery dispute. At a subsequent hearing, the Circuit Court for Anne Arundel County found a discovery violation and concluded that the State’s Attorney had made herself a likely necessary witness in the case by interviewing witnesses alone. The court disqualified her from acting as prosecutor and imposed a firewall order mandating that she have no further involvement in the case except as a witness, with very limited exceptions.The State appealed these interlocutory orders to the Appellate Court of Maryland. The Appellate Court dismissed the appeal for lack of jurisdiction, finding that the disqualification order was not immediately appealable under the collateral order doctrine because determining whether the State’s Attorney was a necessary witness was not completely separate from the merits of the criminal case. The court did not separately address the firewall order.On further appeal, the Supreme Court of Maryland considered whether the disqualification and firewall orders were immediately appealable under the collateral order doctrine. The Supreme Court held that the disqualification order was not immediately appealable because resolving whether the State’s Attorney was a necessary witness was not completely separate from the merits of the prosecution. However, the Supreme Court determined that the firewall order, which barred the State’s Attorney from participating in the case except as a witness, was immediately appealable as it raised important separation of powers concerns and was distinct from the merits. The Court affirmed in part, reversed in part, and remanded for further proceedings on the firewall order. View "State v. Houston" on Justia Law

Two individuals were separately stopped and searched by law enforcement officers in Maryland in January 2023, prior to the effective date of a new statute, Criminal Procedure Article (“CP”) § 1-211. The stops and searches were based solely on the odor of cannabis. Contraband was discovered in both cases, and the individuals were charged with various offenses. Each moved to suppress the evidence, arguing that the newly enacted statute, effective July 1, 2023, rendered evidence obtained solely on the basis of cannabis odor inadmissible, even though their searches had occurred before the law took effect.In both cases, the Circuit Court for St. Mary’s County and the Circuit Court for Worcester County denied the motions to suppress, ruling that the statute did not apply retroactively because it was not in effect at the time of the searches. The Appellate Court of Maryland affirmed both decisions, reasoning that the statute created a new substantive right and remedy that only attached to searches occurring on or after its effective date. The Appellate Court relied on its prior decision in Kelly v. State and distinguished these cases from others involving procedural or remedial statutes.Upon review, the Supreme Court of Maryland affirmed the judgments of the Appellate Court. The Court held that CP § 1-211’s exclusionary remedy applies only to evidence discovered or obtained in violation of the statute, and no violation can occur before the statute’s effective date. The Court found the statute unambiguous, rejected arguments for retroactive application based on procedural or remedial theories, and emphasized the General Assembly’s clear intent for prospective application. Therefore, the exclusionary remedy in CP § 1-211(c) does not apply to pre-enactment cannabis-related stops or searches, and the evidence was properly admitted. View "Cutchember v. State" on Justia Law

A man was charged with drug offenses after his car was stopped by police officers in Hagerstown, Maryland. The officers initiated the stop after observing the driver manipulating or pressing the screen of a cell phone mounted to the vehicle’s windshield while the car was in motion. The officers did not provide further details about the driver’s conduct beyond noting these interactions with the phone. The driver was not charged with a mobile phone or texting violation, but he moved to suppress evidence obtained as a result of the stop, arguing that the stop itself was unlawful.The Circuit Court for Washington County denied the suppression motion, holding that simply seeing someone manipulate a phone while driving constituted reasonable articulable suspicion of a mobile phone violation, since the conduct could easily be texting. After a jury trial, the defendant was convicted of fentanyl possession and related charges. On appeal, the Appellate Court of Maryland reversed, finding that the officers’ observations were of innocuous conduct and did not provide reasonable suspicion of illegal activity under Maryland’s statutes governing mobile phone use while driving.The Supreme Court of Maryland reviewed the case and affirmed the Appellate Court’s decision. The Court held that when an officer observes conduct consistent with both lawful and unlawful mobile phone use, the Fourth Amendment requires the officer to identify specific, articulable facts which, together with rational inferences, reasonably indicate a violation of the relevant statutes. Merely seeing a driver manipulate, touch, or press a phone screen, without more, is insufficient to justify a traffic stop. The Court thus concluded that the stop was not supported by reasonable suspicion and that the evidence should have been suppressed. View "State v. Stone" on Justia Law

In this case, an individual was charged and later convicted of multiple sexual offenses and assault after allegations involving his then-girlfriend’s eight-year-old granddaughter. The key evidence included a sexual assault forensic examination (SAFE) kit, from which DNA samples were collected. At trial, questions arose about the chain of custody for the kit, particularly because a perianal swab was included in the kit despite the nurse testifying she did not recall collecting it. The defense argued this discrepancy undermined the reliability and authenticity of the evidence, seeking to exclude the entire DNA report or, alternatively, to redact references to the disputed swab. The court admitted a redacted version of the report, and the jury found the defendant guilty on most counts.Following his conviction and unsuccessful direct appeal—where the Appellate Court of Maryland held that he had not preserved his chain of custody objection for appellate review—the defendant filed a motion in the Circuit Court for Howard County for a new trial under Maryland’s postconviction DNA testing statute, Criminal Procedure Article § 8-201. He contended that the DNA evidence was unreliable due to the alleged chain of custody defects. The circuit court denied the motion without a hearing. The defendant appealed, and the Appellate Court of Maryland transferred the appeal to the Supreme Court of Maryland.The Supreme Court of Maryland held that the defendant’s claim was not cognizable under CP § 8-201 because he challenged the authenticity and admissibility of the DNA evidence, not the scientific reliability of the testing itself. The court explained that § 8-201 provides relief only for claims of scientific unreliability, not for chain-of-custody or evidentiary issues that could have been raised at trial or on direct appeal. The court affirmed the circuit court’s denial of the motion for a new trial. View "Tarpley v. State" on Justia Law

A jury found the defendant guilty of second-degree assault. At the sentencing hearing, the trial judge initially announced a sentence of one year, suspending all but nine months to be served on home detention, followed by three years of supervised probation. While the judge was advising the defendant of his post-trial rights, the prosecutor questioned whether the sentence properly reflected the intended punishment and raised concerns about the remaining active time if probation was violated. After a brief colloquy and clarification, the judge revised the sentence, increasing it to five years, suspending all but nine months on home detention, and three years of supervised probation.The defendant appealed to the Appellate Court of Maryland, arguing that the trial judge had illegally increased the sentence after it had been imposed, in violation of Maryland Rule 4-345, which restricts modifications to sentences once they are imposed. The Appellate Court rejected this argument, holding that the sentence was not illegally increased because the revision occurred before the sentencing proceeding concluded, and Rule 4-345 was therefore not triggered.On further appeal, the Supreme Court of Maryland affirmed the decision of the Appellate Court. The Supreme Court held that under Maryland law, a sentence is not considered “imposed” under Rule 4-345 until the sentencing proceeding ends. Thus, a trial court retains authority to modify or increase a sentence during an ongoing sentencing hearing. Since the revision to the defendant’s sentence occurred before the conclusion of the sentencing proceeding—while the defendant was still present and the case was not over—Rule 4-345 did not apply, and the increase did not violate double jeopardy protections. The judgment of the Circuit Court for Prince George’s County was affirmed. View "Reyes v. State" on Justia Law

A defendant was found guilty by a jury of second-degree assault. At the sentencing hearing, the trial judge initially announced a sentence of one year, suspending all but nine months to be served on home detention, followed by three years of supervised probation. While the judge was advising the defendant of his post-trial rights, the prosecutor sought clarification about the sentence, noting that the initial announcement did not leave sufficient “backup” time for a probation violation. After a brief colloquy, the judge, realizing a misunderstanding regarding the sentencing guidelines, revised the sentence to five years, suspending all but nine months on home detention, and three years of supervised probation. The defendant remained in the courtroom, and the sentencing proceeding had not ended when the change was made.The defendant appealed to the Appellate Court of Maryland, arguing that the trial court had illegally increased his sentence after it was imposed, in violation of Maryland Rule 4-345, which restricts a court’s ability to modify a sentence once it has been imposed. The Appellate Court determined that the sentence was not illegally increased because the sentencing proceeding had not concluded when the change occurred, and thus, Rule 4-345 did not yet apply.The Supreme Court of Maryland reviewed the case to decide when a sentence is considered “imposed” under Maryland Rule 4-345 and whether the trial court’s increase was illegal. The Court held that a sentence is not imposed until the sentencing proceeding ends, which generally occurs when the judge signals the conclusion of the case, such as by remanding the defendant or calling the next case. Therefore, because the sentence was changed before the proceeding ended, the trial court retained authority to revise it, and Rule 4-345 was not triggered. The Supreme Court of Maryland affirmed the trial court’s judgment. View "Reyes v. State" on Justia Law

The case involved a defendant who was charged with attempted first-degree murder and related offenses in the Circuit Court for Montgomery County, Maryland. Before trial, both the defense and prosecution jointly requested a postponement of the trial date due to the resignation of the defendant’s public defender and the need for additional preparation time. During a status hearing, the defendant’s newly assigned counsel informed the court that the defendant wanted to represent himself and keep the original trial date. The matter was referred to the administrative judge, who questioned the defendant about his wishes. The defendant responded that he wanted an attorney but did not want the trial postponed, emphasizing his desire for a speedy trial and expressing frustration about his continued incarceration.After this exchange, the administrative judge postponed the trial date, and the defendant did not further request to discharge counsel or to represent himself. At trial, the defendant was represented by counsel and was convicted by a jury of attempted second-degree murder, armed robbery, and use of a firearm in the commission of a felony or crime of violence. The Appellate Court of Maryland affirmed the conviction, finding that the defendant had not expressed a present intent to discharge counsel or to represent himself, and that the trial court had provided an adequate opportunity for the defendant to clarify his wishes.The Supreme Court of Maryland reviewed whether the trial court violated the defendant’s constitutional and procedural rights by not conducting further inquiry into his alleged request for self-representation. The Supreme Court held that when a court is informed that a defendant may wish to represent himself, it must conduct a reasonable inquiry to determine if the defendant clearly and unequivocally asserts that right and must allow the defendant to explain his reasons for discharging counsel under Maryland Rule 4-215(e). However, if the defendant does not express a clear desire for self-representation or to discharge counsel, the court is not required to question him further. The Supreme Court affirmed the lower court’s judgment. View "Goodrich v. State" on Justia Law