Justia Maryland Supreme Court Opinion Summaries

The Court of Appeals affirmed the decision of the court of special appeals affirming the judgment of the circuit court convicting Defendant of driving under the influence of alcohol per se and driving while impaired by alcohol, holding that the record supported a finding that police officers complied with the twenty-minute observation period set forth in COMAR 10.35.02.08G.Prior to trial, Defendant filed a motion in limine to exclude the results of a breath test on the ground that the twenty-minute observation period set forth in the COMAR regulation had not been complied with. The circuit court denied the motion. After he was convicted, Defendant appealed, arguing that the circuit court erred in admitting the results of the breath test. The court of special appeals affirmed. The Court of Appeals affirmed, holding (1) the alleged compliance or noncompliance with the twenty-minute observation period goes to the weight to be given to breath test results, not the admissibility; and (2) the circuit court made findings on the record that the officers complied with the twenty-minute observation period set forth in the COMAR regulation. View "Dejarnette v. State" on Justia Law

The Court of Appeals affirmed the decision of the court of special appeals finding that Petitioner waived his objections to the trial court's denial of his proposed voir dire questions, holding that Petitioner failed to preserve his claims based on Kazadi v. State, 223 A.3d 554 (2020).In Kazadi, the Court of Appeals held that, upon request, a court is required to ask potential jurors voir dire questions directed at a defendant's fundamental rights related to the burden of proof, the presumption of innocence, and the right not to testify and held that this ruling applied retroactively to cases pending on appeal so long as the relevant question was preserved for appellate review. In the instant case, which was pending when Kazadi was decided and in which the trial court declined Defendant's request to ask Kazadi voir dire questions, was whether Petitioner's claim based on the trial court's failure to ask questions required by Kazadi was properly reserved for appellate review. The Court of Appeals affirmed, holding that Petitioner's claims were not preserved for appellate review under Md. Rule 4-323(c). View "Lopez-Villa v. State" on Justia Law

The Court of Appeals held that a defendant's right to a unanimous jury verdict is violated when the State presents evidence of multiple incidents at trial to prove a single charged count in the absence of an election between the incidents or a special jury instruction.The court of special appeals affirmed the circuit court's judgment convicting Defendant of first-degree burglary, first-degree assault, and other crimes. At issue on appeal was whether the circuit court abused its discretion in failing to provide a supplemental instruction after the State argued in closing arguments that "the jury could rely on either of two distinct incidents to find [Defendant] guilty of the crimes that were charged as single counts." The court of special appeals determined that Defendant's encounters with the victim were part of a single continuous incident, and therefore, that a special unanimity instruction or election between incidents was not required. The Court of Appeals reversed, holding that Defendant's convictions did not meet this Court's constitutional standards for unanimity and must be vacated. View "Johnson v. State" on Justia Law

The Court of Appeals affirmed the judgment of the court of special appeals affirming the judgment of the circuit court convicting Defendant of second-degree assault and misconduct in office, holding that there was no error.Specifically, the Court of Appeals held (1) where a conviction for misconduct in office is based on the corrupt doing of an unlawful act, the conviction for the "unlawful act" does not merge with the conviction for misconduct; and (2) there was sufficient evidence in the record to support Defendant's convictions for assault in the second degree and misconduct in office. View "Koushall v. State" on Justia Law

The Court of Appeals affirmed the judgment of the court of special appeals affirming Defendant's conviction for gross negligence involuntary manslaughter but reversing his conviction for depraved heart murder, holding that the evidence was insufficient to support the conviction for second-degree depraved heart murder.Specifically, the Court of Appeals held (1) the evidence was sufficient to support Defendant's conviction for involuntary manslaughter under both a gross negligence and failure to perform a legal duty theory of the offense; (2) legal duty involuntary manslaughter is not a lesser-included offense of depraved heart murder; and (3) Defendant's conduct did not constitute conduct that demonstrated an extreme indifference to the value of human life, and therefore, the evidence was not sufficient to support Defendant's conviction for second-degree depraved heart murder. View "Beckwitt v. State" on Justia Law

The Court of Appeals held that this Court's holding in Kazadi v. State, 223 A.3d 554 (2020), applies to cases in which a defendant had not yet noted an appeal when the opinion was issued in Kazadi but had preserved a Kazadi issue at trial and that the Kazadi issue in this case was preserved for appellate review.In Kazadi, the Court of Appeals held that, on request and during voir dire, a trial court must ask whether any prospective jurors are unwilling or unable to comply with the jury instructions on the fundamental principles of presumption of innocence, the defendant's right not to testify, and the State's burden of proof. The Court of Appeals in this case held that, in light of case law from the United States Supreme Court and this Court and considerations of fairness, the holding in Kazadi applies to cases in which there had not yet been a final disposition, regardless of whether a notice of appeal had been filed at the time the opinion in Kazadi was issued and in which the issue had been preserved for appellate review. View "Kumar v. State" on Justia Law

The Court of Appeals affirmed the judgment of the court of special appeals reversing the circuit court's judgment in favor of Plaintiff in this personal injury case, holding that the court of special appeals did not err or abuse its discretion.Plaintiff, who was injured while shopping at a supermarket owned and operated by Defendant, brought this suit alleging negligence and negligent hiring, training, and supervision. A jury returned a verdict in favor of Plaintiff. The intermediate appellate court reversed, concluding that the circuit court erred in denying Defendant's motion for judgment made at the close of evidence and in giving a jury instruction on spoliation. The Court of Appeals affirmed, holding that the court of appeals (1) applied the correct standard of review when reviewing the circuit court's denial of Defendant's motion for judgment; (2) did not err in reversing the circuit court's denial of Defendant's motion for judgment; and (3) did not err in holding that the circuit court's spoliation instruction was prejudicial. View "Webb v. Giant of Maryland, LLC" on Justia Law

The Court of Appeals affirmed the judgment of the court of special appeals affirming Defendant's conviction of illegal possession of a firearm, holding that there was no error.Specifically, the Court of Appeals held (1) the scope of the State's mandatory disclosure obligations pursuant to Md. Rule 4-263(c)(2) does not include jail call recordings held by a state correctional facility that has not reported to the State in a particular case; (2) under the circumstances of this case, the State exercised due diligence in disclosing the jail call recordings; and (3) even if the State violated its discovery obligations through its late disclosure, the error was harmless. View "Alarcon-Ozoria v. State" on Justia Law

The Court of Appeals reversed the judgment of the court of appeals affirming Defendant's conviction of first-degree murder, holding that this Court's holding in Kazadi v. State, 223 A.3d 554 (Md. 2020), applies to cases in which a defendant had not yet noted an appeal when the opinion was issued in Kazadi but had preserved a Kazadi issue at trial.In Kazadi, the Court of Appeals held that, on request and during voir dire, a trial court must asking whether prospective jurors are unwilling or unable to comply with the jury instructions on the fundamental principles of presumption of innocence, the State's burden of proof, and the defendant's right not to testify. The Court later stated that that the holding would apply to any cases pending on direct appeal when the opinion was filed and the relevant question had been preserved for review. In the instant case, the court of special appeals affirmed Defendant's first-degree murder conviction, concluding that the circuit court did not err in declining to ask Defendant's proposed voir dire questions. The Court of Appeals reversed, holding that the circumstances were satisfied for Kazadi to apply to this case. View "Kumar v. State" on Justia Law

The Court of Appeals affirmed Petitioner's convictions of perjury and misconduct in office, holding that this Court declines to abrogate the two-witness rule for "oath-against-oath" perjury cases and that there was sufficient evidence to support the convictions.Petitioner, a veteran officer in the Baltimore Police Department, was charged with perjury and misconduct in office based on allegedly false testimony he gave at a criminal trial. The circuit court found Defendant guilty, and the court of special appeals affirmed. Petitioner filed a petition for certiorari, arguing that the lower courts' bases for affirmance were erroneous, and the State filed a cross-petition for certiorari asking the Court to abrogate the two-witness rule prospectively. The Supreme Court affirmed, holding (1) the State met its burden of production under the two-witness rule in this case; and (2) the evidence was sufficient to sustain Petitioner's convictions for perjury and misconduct in office. View "O'Sullivan v. State" on Justia Law