Justia Maryland Supreme Court Opinion Summaries

Articles Posted in Government & Administrative Law
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At issue in this case was the State Center Project, a $1.5 billion redevelopment project intended to revitalize property owned by the State in Baltimore. In 2005, the State issued a public request for qualifications to solicit a master developer for the project. The State Center, LLC was chosen as the master developer. The Maryland Department of General Services (“DGS”), the Maryland Department of Transportation (“MDOT”) and the State Center, LLC negotiated for the Project, entering a series of agreements between 2007 and 2010 to complete the Project in a timely manner. In 2010, Plaintiffs, property owners in downtown Baltimore and taxpayers, filed suit against the DGS, MDOT, and the State Center and its subsidiaries, seeking a declaratory judgment that the formative contracts for the Project were void and seeking an injunction to halt the Project. The trial court voided the formative contracts, concluding that they violated the State Procurement Law. The Court of Appeals vacated the judgment of the circuit court and remanded with directions to dismiss Plaintiffs’ complaint with prejudice, holding that Plaintiffs’ claims were barred by the doctrine of laches due to an unreasonable delay in bringing their claims, causing prejudice to the defendants. View "State Ctr., LLC v. Lexington Charles Ltd. P’ship" on Justia Law

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Amafica Woodland lived in a residence owned and managed by the Housing Authority of Baltimore City (“HABC”) from her birth in 1995 until her mother and grandmother vacated the residence in 1997. In 2009, Woodland sued HABC, claiming injury from her exposure to lead paint at the residence and asserting compliance with the notice requirements of the Local Government Tort Claims Act (“LGTCA”). The trial court allowed the case to proceed to trial, finding substantial compliance and good cause for Woodland’s failure to provide written notice of her intent to sue within 180 days of injury. A jury subsequently found in favor of Woodland. The Court of Appeals affirmed, holding that the trial court (1) erred in finding that Woodland had substantially complied with the LGTCA’s notice requirements, but the court’s alternate finding that Woodland had good cause for failing to comply made this error moot; and (2) erred in considering material not in evidence as part of its ruling that Woodland met the good cause exception for non-compliance with the LGTCA notice requirement, but this error was harmless. View "Housing Auth. of Baltimore City v. Woodland" on Justia Law

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In 2006, the Comptroller of Maryland issued assessments of tax and interest against Petitioners, two out-of-state subsidiary corporations, based on Petitioners’ relationship with their Maryland parent, Petitioners’ substance as corporations, and all of the entities’ activity in Maryland. The tax court affirmed. Petitioners appealed, arguing, among other things, that Maryland did not have the authority to tax Petitioners because they did not have a sufficient nexus with Maryland for the Comptroller’s assessment of taxes to be constitutional. The court of special appeals upheld the Comptroller’s assessments. The Supreme Court affirmed, holding that the tax court did not err in (1) concluding that the Comptroller had authority to tax Petitioners under the Court’s holding in Comptroller of the Treasury v. SYL, Inc., which allows the Comptroller and tax court to find nexus when a subsidiary lacks economic substance, because Petitioners did not have economic substance as separate business entities; and (2) upholding the apportionment formula used by the Comptroller in its assessment of Petitioners. View "Gore Enter. Holdings, Inc. v. Comptroller of Treasury" on Justia Law

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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

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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

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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

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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

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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

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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

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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