Justia Maryland Supreme Court Opinion Summaries

Three separate sets of repairs were made to a waste hauler purchased by Consolidated Waste from Standard Equipment. Consolidated Waste filed a complaint in circuit court, seeking to recoup the cost of the second round of repairs and claiming that the first and second set of repairs, performed by Standard Equipment, were made in such a way as to constitute a breach of contract and negligence. The circuit court entered judgment in favor of Standard Equipment. After appealing to the court of special appeals, the Court of Appeals issued a writ of certiorari. The Court affirmed the judgment of the trial court, holding that the trial court did not abuse its discretion (1) by excluding evidence of the third round of repairs, performed by a different company, as a reasonable trial judge could have determined that the danger of prejudice outweighed substantially any probative value of the evidence; and (2) by utilizing a verdict sheet supplied by Standard Equipment. View "Consolidated Waste Indus. v. Standard Equip. Co." on Justia Law

After a jury trial, Kendall Northam was convicted of second degree murder and first degree assault. During the proceedings, Northam, who was represented by an assistant public defender, filed a pro se motion for change of venue that included a request for a court-appointed attorney. The motion was denied. On appeal, the court of special appeals held that Northam was entitled to a new trial on the ground that the circuit court had failed to comply with the requirements of Md. R. Crim. P. 4-215(e) by failing to permit Northam to explain the reasons for his request to discharge defense counsel. The Court of Appeals granted certiorari and reversed, holding that Northam waived his right to appellate review of the claim on the ground that he was not permitted to explain the reasons for requesting permission to discharge defense counsel. View "State v. Northam" on Justia Law

Respondent Perry Simms was charged with murder as well as various weapons charges. Before the trial, Simms filed a timely notice of alibi witnesses, listing the names of eleven individuals. Prior to admission, the notice was redacted so that it showed only the name of Simms's father. At trial, the notice was admitted into evidence by the State and submitted to the jury along with transcripts of jailhouse phone calls. The trial judge reasoned that the notice was probative evidence of guilt when considered in conjunction with the phone calls, in which Simms and other callers referred to people who could vouch for Simms's whereabouts on the night of the incident. The intermediate appellate court reversed and remanded the case for a new trial, holding that the circuit court abused its discretion by admitting, over objections, a redacted copy of the alibi notice and that the error was not harmless beyond a reasonable doubt. The Court of Appeals affirmed the judgment of the court of special appeals, holding that admission of the alibi notice was error and an abuse of discretion, and the error was not harmless. View "State v. Simms" on Justia Law

After a jury trial, Dedrick Wilkerson was found guilty of second-degree rape, second-degree assault, and false imprisonment. While investigating the crime, Wilkerson was placed in flex cuffs in his home and questioned for several minutes by detectives before he was advised of his Miranda rights. At trial, Wilkerson moved to suppress both his pre-advisement and post-advisement statements made during the interrogation. The trial judge suppressed the pre-advisement statements, finding the interrogation was custodial, and denied the motion with respect to the post-advisement statements. The court of special appeals affirmed Wilkerson's conviction, concluding that the interrogating officers did not engage in the two-step or pre-advisement warning question-first tactics prohibited in Missouri v. Seibert but holding that Wilkerson preserved his Seibert argument for appellate review. In the interest of justice, the Court of Appeals concluded that the appropriate disposition of the case was a limited remand to the circuit court so the record could be more fully developed on the possible Seibert contention and the trial court could make the appropriate findings. View "Wilkerson v. State" on Justia Law

Helen Holton, a member of the Baltimore City Council, was charged with bribery, malfeasance in office, nonfeasance in office, and perjury. The circuit court granted Holton's motion to dismiss those charges on the ground of legislative privilege. The court of special appeals affirmed the ruling. At issue was whether Md. Code Ann., Cts. & Jud. Proc. 5-501, which protects local legislators from civil or criminal actions based on words spoken at a board or committee meeting, provided Holton with immunity. The Court of Appeals granted the State's petition for writ of certiorari. The Court affirmed the judgment of the court of special appeals, holding that the lower court did not err in holding that section 5-501 provides legislative immunity to local officials in state criminal prosecutions other than prosecutions for defamation. View "State v. Holton" on Justia Law

After a jury trial, Andre Arthur was convicted of failing to obey a lawful order and resisting arrest. The court of special appeals affirmed Arthur's convictions, holding that although the issue of an unlawful arrest was factually generated, the trial court did not err in using a pattern jury instruction rather than Arthur's proposed jury instruction because the language of the pattern jury instruction adequately conveyed that the arrest must be lawful. On appeal, the Court of Appeals reversed the judgment of the intermediate appellate court, holding that because the evidence presented at trial generated the issue of whether Stanley had probable cause to arrest Arthur, (1) the pattern jury instruction did not fairly cover the issue of whether the arresting officer had probable cause to arrest Arthur, and (2) the trial court abused its discretion in failing to provide a jury instruction on the law concerning Arthur's right to resist an unlawful arrest. Remanded for a new trial. View "Arthur v. State" on Justia Law

Waymon Anderson was convicted of sexual abuse of a minor and second degree sexual offense. The State's evidence submitted to the trial court included a written report made to a detective in the police department by the medical director of the facility that conducted a forensic exam of the victim and interviewed the victim. The court of special appeals affirmed the ruling. Anderson filed a petition for writ of certiorari, contending that the trial court erred in admitting the report by the doctor, who was not present at trial, and allowing another doctor to testify as to its contents when the report had not been made for purposes of medical diagnosis or treatment. The Court of Appeals reversed the judgment of the intermediate appellate court, holding that (1) the report should have been excluded on the ground that it was prepared in anticipation of litigation and was not admissible under either the "business records" exception or the "statements in contemplation of treatment" exception to the rule against hearsay; and (2) the erroneous decision to admit the report into evidence was not harmless beyond a reasonable doubt. Remanded for a new trial. View "Anderson v. State" on Justia Law

After Lee Stephens was indicted on charges of first degree murder and conspiracy to commit first degree murder, Stephens sought a pre-trial evidentiary hearing to determine whether the state could produce DNA evidence at trial connecting him to the murder. The circuit court denied the request, and Stephens appealed. The state filed a motion to dismiss the appeal on the ground that it was an impermissible interlocutory appeal. The court of special appeals denied the motion. The Court of Appeals issued a writ of certiorari on its own initiative and dismissed the appeal, holding that the circuit court's ruling did not come within the purview of the collateral order doctrine because the order was reviewable after final judgment. View "Stephens v. State" on Justia Law

Petitioner Warren Ballard was indicted on charges of first degree murder and related offenses. Ballard filed a motion to suppress a portion of what he disclosed during the latter half of his interrogation, arguing that, although he properly received Miranda warnings, he unequivocally invoked his right to counsel when he uttered the words, "You mind if I not say no more and just talk to an attorney about this" mid-way through the interrogation. The trial court denied the motion and later found Ballard guilty as charged. On appeal, the intermediate court of appeals affirmed, finding the trial court properly denied the suppression motion. The Court of Appeals reversed the judgment of the intermediate appellate court with instructions to reverse the judgments of the circuit court, holding that Ballard's statement constituted an unequivocal invocation of the right to counsel, and therefore, pursuant to Miranda and its progeny, the interrogating detective was required at that moment to cease all questioning. Because the state made substantive use of Ballard's statements made during the ensuing interrogation that should have been suppressed, the case was remanded for a new trial. View "Ballard v. State" on Justia Law

Petitioner Troy Jones was convicted of unlawful possession of a regulated firearm after having been convicted of a felony, pursuant to Md. Code Ann., Pub. Safety, 5-133(b). Jones appealed, arguing in the alternative that (1) Section 5-133(b) does not contain a penalty provision and that the penalty provisions in Md. Code Ann., Pub. Safety, 5-133(c) and 5-143 do not apply; and (2) an out-of-state conviction cannot serve as a predicate conviction for a violation of Section 5-133(b) and that the trial judge erred in imposing a mandatory minimum five-year sentence for the violation. The court of special appeals affirmed. The Court of Appeals affirmed in part and reversed in part, holding that (1) Section 5-143 serves as the penalty provision for a violation of Section 5-133(b); (2) an out-of-state conviction can serve as a predicate conviction for purposes of Section 5-133(b); and (3) the trial judge erred in imposing a mandatory five-year sentence for a violation of Section 5-133(b). Remanded for new sentencing. View "Jones v. State" on Justia Law