Justia Maryland Supreme Court Opinion Summaries

A married couple, with three young children, filed for divorce. The mother requested primary custody, pendente lite child support, and alimony, while the father requested primary custody and child support. A family magistrate found both parents capable of earning significant income and denied the mother's request for pendente lite child support and alimony, recommending shared custody and shared payment of the mortgage and utilities for the marital home.The Circuit Court for Howard County adopted the magistrate's recommendations and denied the mother's exceptions to the magistrate's report. The mother appealed, citing Md. Code Ann., Cts. & Jud. Proc. § 12-303(3)(v), which allows appeals from interlocutory orders for the payment of money.The Appellate Court of Maryland dismissed the appeal, holding that an interlocutory order denying pendente lite child support and alimony is not appealable under CJ § 12-303(3)(v) because it does not direct the payment of money. The mother then petitioned the Supreme Court of Maryland for a writ of certiorari.The Supreme Court of Maryland affirmed the Appellate Court's judgment, holding that CJ § 12-303(3)(v) authorizes appeals only from interlocutory orders that direct the payment of money, not from orders denying such requests. The Court concluded that the legislative history and case law support this interpretation, emphasizing that the statute's plain language does not permit appeals from orders denying the payment of money. View "Adelakun v. Adelakun" on Justia Law

In this case, Erica Hall and Nicholas Houser, who married in 2012 and have one minor child, sought an absolute divorce in 2020. They presented three agreements to the Circuit Court for Anne Arundel County, including one that proposed no child support and waived arrears. The court rejected this agreement, stating it was not in the child's best interest and ordered Mr. Houser to pay child support and arrears to Ms. Hall, who was the primary custodian.The Appellate Court of Maryland affirmed the circuit court's decision, rejecting the parents' agreement regarding child support and upholding the award of child support and arrears. Both parties then petitioned the Supreme Court of Maryland for a writ of certiorari.The Supreme Court of Maryland held that parents cannot waive the issue of child support and arrears, even in a bilateral agreement, because child support is a legal obligation, and the right to receive it belongs to the child, not the parents. The court also held that a parent's fundamental right to determine the care, custody, and control of their children does not include the ability to waive child support, as it is a parental obligation, not a right. Therefore, lawfully ordered child support does not violate a parent's fundamental rights.Additionally, the court found that the trial court did not abuse its discretion in rejecting the parents' agreement to pay no child support, as the parties failed to provide sufficient justification for their request. The Supreme Court of Maryland affirmed the judgment of the Appellate Court, maintaining the child support order. View "In re Marriage of Houser" on Justia Law

The case involves a seventeen-year-old named M.Z., who was adjudicated as a child in need of assistance (CINA) by the Circuit Court for Baltimore County due to behavioral issues and her mother's inability to manage her. M.Z. was placed in a therapeutic youth group home and later returned to her mother's custody. The Baltimore County Department of Social Services sought to terminate the CINA case, but M.Z.'s mother objected, citing ongoing behavioral concerns and the need for additional services.The Circuit Court for Baltimore County terminated the CINA case over the mother's objection, finding that the mother could adequately care for M.Z. and that the Department had exhausted its services. The mother appealed to the Appellate Court of Maryland, which dismissed the appeal, holding that the mother was not "aggrieved" by the termination since her custodial rights were restored.The Supreme Court of Maryland reviewed the case to determine whether a parent is entitled to appeal the termination of a CINA case over their objection. The court held that a parent is an "aggrieved party" entitled to appeal if they have not obtained the full relief sought in the juvenile court. The court emphasized that the CINA statute's purpose extends beyond parental rights to include the child's safety and well-being. The court found that the mother's interest in ensuring M.Z.'s safety and receiving necessary services was sufficient to make her an aggrieved party.The Supreme Court of Maryland reversed the judgment of the Appellate Court of Maryland and remanded the case for further proceedings to resolve the merits of the mother's appeal. View "In re M.Z." on Justia Law

Bonnie Campbell, a federal employee, and Michael Campbell, her ex-husband, entered into a divorce property settlement agreement in which Mr. Campbell waived his rights to Ms. Campbell's Thrift Savings Plan (TSP) account. Despite this agreement, Ms. Campbell did not remove Mr. Campbell as the beneficiary of her TSP account before her death. After her death, Mr. Campbell received the balance of the TSP account. The estate of Ms. Campbell (the Estate) sued Mr. Campbell for breach of contract to enforce the terms of the divorce settlement agreement.The Circuit Court for Montgomery County granted summary judgment in favor of the Estate on its breach of contract claim, awarding money damages. The court rejected Mr. Campbell's argument that the Federal Employees’ Retirement System Act of 1986 (FERSA) preempted the Estate's claim. The Appellate Court of Maryland reversed, holding that FERSA preempted the Estate's breach of contract claim.The Supreme Court of Maryland reviewed the case and held that FERSA does not preempt the Estate’s post-distribution breach of contract action. The court found that FERSA’s purposes, which include establishing a federal employee retirement plan and ensuring it is fully funded and financially sound, do not concern plan beneficiaries. The court also noted that FERSA’s provisions elevate the requirements of a qualifying state property settlement agreement over a deceased participant’s designated beneficiary, provided notice is given before payment. The court concluded that a post-distribution suit to enforce contractual obligations in a divorce property settlement agreement does not hinder any governmental interest in administrative convenience or avoiding double payment. The judgment of the Appellate Court was reversed, and the Circuit Court's judgment was affirmed. View "In re Isely" on Justia Law

The Supreme Court held that Maryland law allows spouse to allocate martial assets in a postnuptial agreement based on whether a spouse engaged in adultery, thereby causing the breakdown of the marriage, thus affirming the judgment of the lower courts.Plaintiff filed a complaint for absolute divorce on the grounds of adultery, requesting that the circuit court incorporate the parties' postnuptial agreement into the decree. The agreement included a $7 million lump sum provision that triggered if Defendant engaged in adultery. The circuit court determined that the lump sum provision was an enforceable penalty and issued a judgment of divorce that incorporated, but did not merge, the agreement. The appellate court affirmed. The Supreme Court affirmed, holding (1) the public policy in Maryland supports intefspousal distributions of marital assets based on adultery in postnuptial agreements; and (2) Plaintiff was entitled to no more than Defendant's "50% share of the Column B Assets." View "Lloyd v. Niceta" on Justia Law

The Supreme Court answered three questions certified by the United States District Court for the District of Maryland in this suit brought against Catholic Relief Services-United States Conference of Catholic Bishops (CRS), which follows the teaching that marriage is between one man and one woman.The district court ruled (1) CRS violated Title VII of the Civil Rights Act of 1964 by revoking Plaintiff's dependent health insurance because he was a man married to another man; and (2) Plaintiff was entitled to summary judgment on his federal Equal Pay Act claim. The court then ordered the parties to confer and file proposed questions of law with respect to the Maryland Fair Employment Practices Act (MFEPA), Md. Code Ann., State Gov't 20-606, and the Maryland Equal Pay for Equal Work Act (MEPEWA), Md. Code Ann., Lab. & Empl. 3-304. The Supreme Court answered (1) the prohibition against discrimination on the basis of sex in MFEPA does not itself also prohibit sexual orientation discrimination, which is separately covered under MFEPA; (2) MEPEWA does not prohibit sexual orientation discrimination; and (3) MFEPA's religious entity exemption applies with respect to claims by employees who perform duties that directly future the core mission of the religious entity. View "Doe v. Catholic Relief Services" on Justia Law

The Court of Appeals reversed the judgment of the court of special appeals affirming the circuit court's award of custody of T.K. under Md. Cts. & Jud. Proc. 3-819(e) to a previously non-custodial father, holding that the juvenile court erred by failing to hold an evidentiary hearing before awarding Father sole legal and physical custody of T.K.At issue was the mechanics of the application of 3-819(e) to situations in which a local department of social services has limited knowledge about one of a child's parents until after an adjudicatory hearing has concluded. The Court of Appeals reversed the decision of the circuit court, sitting as a juvenile court, awarding custody in this case, holding that because the record did not contain evidence that Father was able and willing to care for the child and because there was no stipulation to that effect, and because Mother was not given the opportunity to present evidence informing the court's best interest analysis, remand was required. View "In re T.K." on Justia Law

The Court of Appeals held that where there are two legal parents, both legal parents must consent to and foster a third party's formation and establishment of a parent-like relationship with a child under the first factor of the test set forth in In re Custody of H.S.H.-K., 533 N.W.2d 419 (Wis. 1995), adopted by this Court in Conover v. Conover, 146 A.3d 433 (Md. 2016).E.N. was the biological mother and D.D. was the biological father of two minor children. When D.D. entered into a relationship with T.R. the children moved in with the couple. T.R. later filed a complaint seeking sole legal and physical custody of the children. The circuit court granted T.R.'s complaint for custody, concluding that T.R. was a de facto parent of the children. The court of special appeals affirmed. The Court of Appeals reversed, holding (1) to establish de facto parenthood where there are two legal parents, a prospective de facto parent must demonstrate that both legal parents consented to and fostered a parent-like relationship with a child, or that a non-consenting legal parent is an unfit parent or exceptional circumstances exist; and (2) the circuit court erred in concluding that T.R. was a de facto parent and in granting her joint legal custody and sole physical custody. View "E.N. v. T.R." on Justia Law

The Court of Appeals affirmed the judgment of the court of special appeals vacating the judgment of the circuit court finding that R.S. was a child in need of assistance (CINA), holding that the court of special appeals did not err in holding that the Interstate Compact for the Placement of Children (ICPC) does not apply to out-of-state placements of a child in the care of a biological, non-custodial parent.Based on its determination that the ICPC applied to the placement of R.S. in the care of her biological father, the juvenile court awarded joint custody of R.S. to the non-custodial biological father and parental grandparents. The court of special appeals vacated the judgment, concluding that the plain language of the ICPC, codified in Md. Code, Fam. Law Art. 5-601-5-611, did not apply under the circumstances of this case. The Court of Appeals affirmed, holding (1) the ICPC does not apply to out-of-state placements with non-custodial biological parents; and (2) because the ICPC did not apply under the circumstances of this case and the court never determined that the biological father was unfit, the CINA order was properly vacated. View "In re R.S." on Justia Law

The Court of Appeals held that a juvenile court's decision to deny continued shelter care in a child in need of assistance (CINA) case is appealable under the collateral order doctrine and that the court may authorize continued shelter care for up to thirty days if makes the necessary findings and may extend shelter care beyond thirty days if it makes the findings by a preponderance standard.Anne Arundel County Department of Social Services placed an infant in emergency shelter care and filed a CINA petition with a request for continued temporary shelter care pending resolution of the CINA petition. After a hearing, the juvenile court denied the Department's request for continued shelter care, concluding that the Department had failed to establish the statutory criteria by a preponderance of the evidence. The court of special appeals affirmed, holding that the juvenile court used the correct standard of proof. The Supreme Court affirmed in part and reversed in part, holding (1) a juvenile court may continue temporary emergency shelter under conditions set forth in this opinion; and (2) any continuation of shelter care beyond thirty days must be based upon findings made applying a preponderance of evidence standard at the adjudicatory stage of the CINA case. View "In re O.P." on Justia Law