Justia Maryland Supreme Court Opinion Summaries

A nonprofit organization seeking to preserve the Sugarloaf Mountain area submitted two requests under the Maryland Public Information Act (MPIA) to Frederick County, seeking records relating to changes in a local land management plan. The County acknowledged receipt but did not produce any documents or respond further for eight months. After the nonprofit filed suit in the Circuit Court for Frederick County, the County provided some documents and withheld others, citing various privileges. Following a bench trial, the Circuit Court ordered most withheld documents to be produced and later conducted an in camera review for a subset of documents, ultimately finding some were properly withheld.After prevailing in obtaining key documents, the nonprofit sought attorneys’ fees. The Circuit Court found the requested fees reasonable under the applicable “lodestar” method but reduced the award from over $48,000 to $25,000, considering factors such as the absence of an “evil motive” by County officials and the burden on County taxpayers. The Circuit Court denied a supplemental fee petition for procedural reasons. On appeal, the Appellate Court of Maryland affirmed the reduced fee award, finding no abuse of discretion, but vacated the denial of the supplemental petition and remanded that issue.On further appeal, the Supreme Court of Maryland held that the Circuit Court abused its discretion in calculating the attorneys’ fees award. The Supreme Court found that the Circuit Court improperly relied on factors not relevant under the lodestar approach set forth in Maryland Rule 2-703(f)(3), such as the officials’ motives and the effect on taxpayers, and failed to explain the basis for the reduction. The Supreme Court of Maryland reversed the Appellate Court’s affirmance of the fee award, remanded with instructions to vacate the award, and directed the Circuit Court to reconsider the petition using the proper legal standards. View "Sugarloaf Alliance v. Frederick Cnty." on Justia Law

While incarcerated at the Maryland Correctional Training Center, Michael Young was attacked twice by other inmates, suffering severe injuries. Young alleged that the attacks were the result of negligence by Sergeant Jeremy Wright and Warden Richard Dovey, as well as a broader pattern or practice of unconstitutional conduct by the State of Maryland. He brought suit against Sgt. Wright, Warden Dovey, and the State, claiming negligence and a "Longtin" pattern-or-practice violation. The jury found Wright and Dovey liable for negligence (but not malice or gross negligence) and awarded Young $1,000,000 against each. On the Longtin claim, the jury awarded $2,000,000 against the State.The Circuit Court for Baltimore County entered judgment for Young on all three awards. On appeal, the Appellate Court of Maryland held that, under the Maryland Tort Claims Act (MTCA), the judgments against the individual defendants should be reduced to a combined $800,000, finding two “incidents or occurrences.” The Appellate Court also vacated the Longtin judgment, holding that although such claims may be brought against the State, Young failed to present sufficient evidence.The Supreme Court of Maryland reviewed the case. It held that, under the MTCA, where State personnel commit a tort within the scope of their duties without malice or gross negligence, only the State may be held liable and judgment must be entered against the State, not the individuals. The Court also held that, absent a jury finding of multiple, non-concurrent negligent acts as proximate causes of the injuries, only one “incident or occurrence” could be found; thus, Young’s damages were capped at $400,000. Finally, because Young did not contest the sufficiency of evidence on his Longtin claim, the Court vacated the Appellate Court's discussion on that issue as moot. The Supreme Court reversed in part and vacated in part. View "State v. Young" on Justia Law

A woman brought tort claims against a county board of education, alleging that she was sexually abused by a teacher between 1967 and June 1971 while she was a student. Her lawsuit followed passage of the Child Victims Act of 2023, which eliminated time limitations on claims for child sexual abuse. The board moved to dismiss her suit, asserting that it retained sovereign immunity from tort claims based on conduct predating July 1, 1971, because the General Assembly had not provided a funding mechanism for such claims prior to authorizing boards to purchase liability insurance on that date.The Circuit Court for Wicomico County denied the board’s motion to dismiss. The board sought an immediate appeal, arguing that denial of sovereign immunity was immediately appealable under the collateral order doctrine. The Appellate Court of Maryland dismissed the appeal for lack of jurisdiction. The board then obtained review in the Supreme Court of Maryland.The Supreme Court of Maryland first held that an order denying a motion to dismiss on the basis of complete sovereign immunity is immediately appealable under the collateral order doctrine if it presents a pure legal question and meets other requirements of the doctrine. The court reasoned that sovereign immunity is an immunity from suit itself and that, absent immediate review, an important aspect of that immunity would be irretrievably lost.On the merits, the Supreme Court of Maryland held that the county board retained sovereign immunity for claims based on pre-July 1, 1971 conduct. Even if the General Assembly had retroactively authorized such suits in the Child Victims Act, it had neither appropriated funds nor provided a mechanism for the board to pay judgments for those claims. The court reversed the Appellate Court’s dismissal, directed that the complaint be dismissed without prejudice, and clarified that the claim could be revived if the legislature provides a funding mechanism. View "Bd. of Education v. Sturm" on Justia Law

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

Several Maryland local governments, including Baltimore City, Anne Arundel County, and the City of Annapolis, filed lawsuits in Maryland circuit courts against 26 multinational oil and gas companies. They alleged that the defendants’ extraction, production, promotion, and sale of fossil fuels—combined with deceptive marketing about their products’ climate risks—substantially contributed to global greenhouse gas emissions, resulting in severe local impacts such as sea-level rise, flooding, and heat waves. The local governments sought damages and equitable relief based on Maryland common law claims of public nuisance, private nuisance, trespass, negligent failure to warn, and strict liability failure to warn.In the trial courts (the Circuit Courts for Baltimore City and Anne Arundel County), the defendants successfully moved to dismiss the complaints. The courts found that the local governments’ claims were preempted by federal law, specifically by federal common law and the Clean Air Act, and that the complaints failed to state claims upon which relief could be granted under Maryland law. The cases took a procedural detour through federal courts due to removal attempts, but were ultimately remanded to state court. The Appellate Court of Maryland consolidated the appeals, and the Supreme Court of Maryland granted review by writ of certiorari.The Supreme Court of Maryland affirmed the dismissals. The court held that the local governments’ state law claims, though pled as torts, effectively sought to regulate interstate and international air emissions—an area governed exclusively by federal law. Relying on United States Supreme Court precedent, the court explained that such claims are displaced by federal common law and, in turn, by the Clean Air Act, which does not authorize broad state law claims in this context. The court further held that, even if not preempted, none of the plaintiffs stated valid claims under Maryland law for public or private nuisance, trespass, or failure to warn. View "Mayor & City Cncl. Of Balt. v. B.P. P.L.C." on Justia Law

Sanjeev Varghese was injured when he rode his bicycle into a steel cable stretched between two bollards on Pier 5 at Baltimore’s Inner Harbor. The barrier was located between a vehicular access road and a pedestrian promenade. The City of Baltimore had approved the design of the access road and its barriers, with changes for safety and aesthetics implemented in 2005. In 2017, a similar bicycle accident occurred, and the City received notice of that incident. In 2018, Varghese crashed into the barrier and subsequently sued the City for negligence, claiming the barrier was hazardous and that the City failed to address a known danger.The Circuit Court for Baltimore City allowed Varghese’s claims to proceed to a jury, which found the City negligent and awarded damages. The City moved for judgment notwithstanding the verdict, arguing it was entitled to governmental immunity based on the discretionary nature of its design decisions. The circuit court denied this motion. On appeal, the Appellate Court of Maryland affirmed the judgment, concluding that the City was not immune from liability for failing to fix a known hazard.The Supreme Court of Maryland reviewed the case and held that the City’s decisions regarding the design and placement of the barrier were discretionary governmental functions. The court reaffirmed that municipalities are immune from tort liability for such discretionary design decisions unless the condition created is so obviously dangerous that no reasonable person could disagree. The court found that this exception did not apply here, as the barrier was not shown to be obviously dangerous. Therefore, the Supreme Court of Maryland reversed the judgment of the Appellate Court and instructed that judgment be entered in favor of the City. View "May. & City Cncl. Of Baltimore v. Varghese" on Justia Law

Henry Walters bequeathed the Walters Art Gallery, adjacent property, and all their contents to the Mayor and City Council of Baltimore in 1931. The City established a board of trustees to manage the assets, and in 1933, the General Assembly incorporated the Trustees of the Walters Art Gallery as an educational corporation with full control over the property. The Board has since operated the Walters Art Gallery, now known as the Walters Art Museum, for public benefit.The Circuit Court for Baltimore City ruled in favor of the plaintiffs, Walters Workers United and AFSCME, who sought to compel the Board to produce records under the Maryland Public Information Act (MPIA). The court concluded that the Board was a governmental instrumentality subject to the MPIA. The Appellate Court of Maryland affirmed this decision, emphasizing the Board's public purpose, City ownership of the property, and financial support from the City.The Supreme Court of Maryland reviewed the case and reversed the lower courts' decisions. The Court held that the Board is not a governmental unit or instrumentality under the MPIA. The Court emphasized the Board's operational independence, its fiduciary role in carrying out a private donor's charitable intent, and the lack of substantial City control over its operations. The Court concluded that the Board's relationship with the City does not make it a governmental instrumentality subject to the MPIA. The case was remanded to the Appellate Court of Maryland with instructions to remand to the Circuit Court for further proceedings consistent with this opinion. View "Walters Art Gallery v. Walters Workers United" on Justia Law

In early 2019, G.K. and K.K. purchased a homeowners insurance policy from Travelers Home and Marine Insurance Company for their residence. The policy included an anti-assignment clause prohibiting assignment without the insurer's consent. In May 2020, after the policy expired, the Policyholders reported roof damage from a 2019 storm and hired Featherfall Restoration, LLC to repair it. Travelers denied the claim, citing wear and tear. The Policyholders then assigned their claim to Featherfall, which Travelers refused to recognize due to the anti-assignment clause.Featherfall filed a complaint with the Maryland Insurance Administration (MIA), asserting its right to act in place of the Policyholders. The MIA upheld Travelers' denial, stating the anti-assignment clause invalidated the assignment. Featherfall requested a hearing, arguing the clause should not apply to post-loss assignments. The MIA Commissioner granted summary decision in favor of Travelers, finding the assignment invalid and Featherfall not entitled to a hearing.Featherfall sought judicial review in the Circuit Court for Baltimore City, which affirmed the MIA's decision and denied declaratory relief. The Appellate Court of Maryland also affirmed, holding that anti-assignment clauses apply to post-loss assignments and that Featherfall lacked standing.The Supreme Court of Maryland reviewed the case and held that the anti-assignment clause did not prohibit the assignment of a post-loss claim. The court distinguished between the policy itself and a claim arising under it, noting that a claim is a chose in action and thus assignable. The court reversed the lower courts' decisions and remanded the case to the MIA for further proceedings consistent with this opinion. View "In re Petition of Featherfall Restoration" on Justia Law

Plaintiffs, limited liability companies, filed class action lawsuits in the United States District Court for the District of Maryland seeking relief under the Medicare Secondary Payer (MSP) provisions. These provisions make Medicare a secondary payer when a beneficiary has other insurance coverage. Plaintiffs obtained assignments from Medicare Advantage Organizations and other secondary payers to seek reimbursement from primary payers like the defendants, Government Employees Insurance Company and its affiliates (GEICO). Plaintiffs had no preexisting interest in the claims and were compensated on a contingency basis.The United States District Court for the District of Maryland denied GEICO's motion to dismiss the case, which argued that the assignments were void as against Maryland public policy based on the doctrines of maintenance, champerty, and barratry. The court found no clear statement of Maryland law on this issue and certified questions to the Supreme Court of Maryland.The Supreme Court of Maryland held that Plaintiffs did not violate Maryland’s barratry statute, which prohibits soliciting another person to sue for personal gain without an existing relationship or interest. Plaintiffs did not solicit secondary payers to file lawsuits but obtained the right to sue in their own names through assignments. The court also held that the common law doctrines of maintenance, champerty, and barratry, to the extent they still apply, do not invalidate Plaintiffs’ assignments. The court concluded that the assignments are not void as against public policy and did not address the enforceability of choice-of-law provisions in the agreements. View "GEICO v. MAO-MSO Recovery II" on Justia Law

Dallas Fenton was convicted of multiple sexual offenses against a fourteen-year-old child, including eight counts of third-degree sexual offense, one count of sexual solicitation of a minor, and one count of indecent exposure. He was sentenced to ten years for one of the third-degree sexual offenses (Count 1) and another ten years for a different third-degree sexual offense (Count 8), to be served consecutively.The Division of Correction (DOC) informed Fenton that he would not receive diminution of confinement credits for the sentence on Count 8 because he had been previously convicted of a similar offense (Count 1). Fenton's grievance with the Inmate Grievance Office (IGO) was dismissed, and the Circuit Court for Washington County partially granted and partially denied his petition for judicial review, ruling that he was entitled to good conduct credits but not other types of diminution credits for Count 8.The Appellate Court of Maryland held that Fenton was not prohibited from accruing diminution credits for Count 8, as the statute only applied if the previous conviction occurred before the commission of the offense for which the sentence was being served. The court vacated the circuit court's judgment and remanded the case for recalculation of Fenton's credits.The Supreme Court of Maryland affirmed the Appellate Court's decision, holding that under Md. Code Ann., Corr. Servs. § 3-702(c), diminution credits are precluded only if the offense was committed after a previous conviction for the same offense. The court concluded that Fenton was entitled to diminution credits for Count 8, as he had not been "previously convicted" at the time of the offense. View "Dept. of Pub. Saf. & Corr. Serv. v. Fenton" on Justia Law