Justia Maryland Supreme Court Opinion Summaries

Prince George’s County enacted a resolution creating the Victoria Falls Special Taxing District (District) under authority granted by a State enabling act (Act). Taxpayers challenged the resolution and sought tax refunds. The tax court denied the Taxpayers’ claims. The circuit court and intermediate appellate court affirmed. The Supreme Court affirmed, holding (1) the tax court properly upheld the County’s resolution creating the District, where changes in land ownership within the District occurred after the time of application for creation of the District but before final action on the application, as the State Legislature did not intend to require that the County determine whether any change in land ownership may have affected the super-majority landowner requirement expressed in the Act for applying for the District; and (2) the tax court properly ruled that the County’s approval of the request to create the District that did not include twenty-five of the 609 lots contained within the planned Victoria Falls community was lawful under the Act’s requirement that the District be used to finance infrastructure improvements in “any defined geographic region within the county.” View "Victoria Falls Comm. for Truth in Taxation, LLC v. Prince George's County" on Justia Law

This case concerned a dispute over the paving of a parking lot located on park land leased to a restaurant. A formal agreement between the restaurant and a community organization restricted the paving of the property, and the restriction was incorporated in administrative zoning orders. Still, the lot was paved. Baltimore County was, in this case, landlord of the property, code enforcer, and final administrative adjudicator of disputes arising under local land use laws. As administrative adjudicator, the County forbade the paving. As landlord, the County directed its tenant, Oregon, LLC, to pave the lot. As code enforcer, it refrained from taking action in response to the apparent violation of a final administrative order issued by the Board of Appeals. Plaintiffs brought suit against the County and Oregon seeking declaratory and mandamus relief. The circuit court ruled against Plaintiffs. The court of special appeals affirmed, concluding that Plaintiffs had failed to exhaust administrative remedies. The Court of Appeals largely affirmed, albeit on different grounds, holding (1) Plaintiffs need not initiate an administrative proceeding to pursue enforcement of the Board’s orders; (2) the circuit court properly granted summary judgment with respect to the mandamus counts of the complaint; and (3) the circuit court has authority to issue a declaratory judgment as to whether the Board’s orders were violated. Remanded. View "Falls Road Cmty. Ass’n, Inc. v. Baltimore County" on Justia Law

Petitioner was a paid firefighter employed by Respondent, Montgomery County. Petitioner filed a claim pursuant to the Maryland Workers’ Compensation Act, claiming that he sustained injuries in an accident that occurred when he was traveling to work on his motorcycle after leaving physical training. The Maryland Workers’ Compensation Commission disallowed Petitioner’s claim, finding that Petitioner did not sustain an injury arising out of and in the course of employment. The circuit court upheld the Commission’s decision, ruling that Petitioner was not entitled to workers’ compensation because the injury occurred while “he was coming and going” to work. The court of special appeals affirmed. The Court of Appeals vacated the judgment of the court of special appeals, holding that Petitioner’s injury arose out of and in the course of his employment and was covered by the Workers’ Compensation Act because (1) Petitioner’s travel was incidental to his employment, which travel cannot be excluded from coverage by application of the going and coming rule; and (2) “but for” his travel between work-related sites Petitioner would not have been injured. View "Roberts v. Montgomery County" on Justia Law

Plaintiffs were employees of a State psychiatric hospital who had been laid off and were not rehired in order of seniority when the hospital later filled vacancies for positions comparable to those previously occupied by Plaintiffs. An administrative law judge denied Plaintiffs’ grievance, concluding that Plaintiffs were not entitled to be rehired under a reinstatement process. The circuit court affirmed. The court of special appeals remanded the case for further factfinding, concluding (1) there is no statutory preference for reinstatement, as opposed to recruitment, in the State Personnel Management System, but if an agency decides to fill vacancies through recruitment, it must follow statutory procedures, including public notice and transparency as to the selection criteria; and (2) it was not clear whether the agency in this case complied with those criteria. The Court of Appeals affirmed by adopting the opinion of the court of special appeals and adding an endorsement to the court of special appeal’s opinion to remove any doubt as to the standing of that decision as the law of the State. View "Sturdivant v. Dep’t of Health & Mental Hygiene" on Justia Law

In two cases, Montgomery County took a portion of properties owned by Respondents. Because the parties disputed the value paid for either taking the County filed a complaint for condemnation. During the proceedings, the circuit court imposed discovery violation sanctions precluding Respondents from introducing evidence as to the fair market value of the taken properties. Respondents were therefore unable to generate a genuine issue of material fact concerning the County's appraisal valuations. As a result, the circuit court granted summary judgment for the County on the issue of just compensation. The court of special appeals reversed, concluding that summary judgment on the question of just compensation is not available in condemnation proceedings because a property owner cannot be deprived of the constitutional right to have a jury determine just compensation. The Court of Appeals reversed, holding (1) permitting summary judgment does not violate the constitutional right to have the opportunity for a jury trial to ascertain just compensation in compensation actions provided the landowner litigates the case according to the Maryland Rules; and (2) summary judgment was properly granted in each case because there was no genuine dispute of material fact and the County was entitled to judgment as a matter of law. View "Montgomery County v. Soleimanzadeh" on Justia Law

A state trooper pulled over Respondent's vehicle for failing to obey a traffic control device. When the trooper approached the vehicle, he detected a "moderate odor" of an alcoholic beverage on Respondent's breath. The trooper placed Respondent under arrest and, after Respondent refused to take an alcohol content test, Respondent was subjected to a suspension of his driver's license. An administrative law judge affirmed the suspension. The circuit court reversed, holding that the record was "deplete of any sufficient indicia of alcohol use" to establish reasonable grounds for a request to take an alcohol content test. The Court of Appeals reversed, holding that a moderate odor of alcohol emanating from the person of a motorist, alone, constitutes reasonable grounds to request the motorist to take an alcohol test. View "Motor Vehicle Admin. v. Spies" on Justia Law

Plaintiffs here were employees who had been laid off from their jobs at a State psychiatric hospital and, when the hospital filled vacancies for positions comparable to those previously occupied by the laid-off employees, were not rehired in order of seniority. An administrative law judge denied Plaintiffs' grievance, concluding that they did not have a right to be rehired under a reinstatement process. The circuit court affirmed. The court of special appeals remanded the case for further factfinding, concluding (1) there is no statutory preference for reinstatement, as opposed to recruitment, in the State Personnel Management System; but (2) if an agency elects to fill vacancies through recruitment, it must follow statutory procedure that includes public notice and transparency as to the selection criteria. The Court of Appeals affirmed, holding (1) the lower court correctly analyzed the legal issue concerning the interpretation of State personnel law; and (2) because the record did not definitely answer the question whether the agency in this case was filling vacancies by a reinstatement process, rather than recruitment, remand for further factfinding was appropriate. View "Sturdivant v. Dep't of Health & Mental Hygiene" on Justia Law

In 2011, the La Plata Town Council passed four resolutions, including an annexation resolution acquiring a tract of land. Several citizens of La Plata subsequently published a petition to refer the Council's annexation resolution to referendum. The town manager declared that sufficient signatures had been submitted. As such, the annexation resolution was suspended and all four resolutions were referred to referendum. Several referendum opponents filed a petition for judicial review of the manager's report validating the signatures and advancing the referendum to a vote. The circuit court judge ruled in favor of the referendum opponents, holding, inter alia, that although the petition for referendum presented foremost a land annexation resolution, the inclusion of the additional resolutions invalidated the petition. The Court of Appeals vacated the opinion and remanded, holding (1) where the petition for referendum contained legislative enactments that were collateral to the land annexation resolution but did not obfuscate the subject matter of the petition for referendum, the additions do not invalidate the petition; and (2) the town manager acted within his authority when he published Town policies for the validation and verification of signatures for referendum. View "Town of La Plata v. Faison-Rosewick LLC" on Justia Law

Respondent was a driver of a motor vehicle that was involved in a crash. The officer that responded to the accident arrested Respondent and requested that he take a blood test to determine alcohol concentration after noticing a "strong odor of alcoholic beverage emitting from the person and breath" of Respondent. An ALJ subsequently suspended Respondent's driver's license for ninety days. The circuit court reversed, concluding that only if the accident was Respondent's fault that an inference could be drawn, in combination with the odor of alcohol, that there were reasonable grounds to conclude Respondent was under the influence of alcohol or intoxicated. The Court of Appeals reversed, holding that the police officer's certification that a strong odor of an alcoholic beverage was present on Respondent's breath and person constituted reasonable grounds to request an alcohol content test. Remanded. View "Motor Vehicle Admin. v. Sanner" on Justia Law

CareFirst, Inc., a nonstock, nonprofit Maryland corporation, is a holding company with two subsidiaries that provides health insurance for millions of Maryland residents. State law confers broad authority on the Maryland Insurance Commissioner to oversee its operation and adherence to its mission. This case arose from the termination of Leon Kaplan, a former executive of CareFirst. CareFirst declined to pay part of the post-termination compensation set forth in Kaplan's employment contract, reasoning that the compensation was not for "work actually performed," as that standard had been interpreted by the Commissioner. The Commissioner affirmed the decision not to pay the benefits, concluding that the payments would violate Md. Code Ann. Ins. 14-139. The Court of Appeals affirmed, holding (1) the Commissioner's determination was not preempted by ERISA; (2) the Commissioner's construction of the insurance code was legally correct; and (3) there was substantial evidence to support the Commissioner's determination in this case. View "Md. Ins. Comm'r. v. Kaplan" on Justia Law