Justia Maryland Supreme Court Opinion Summaries

This case arose from an altercation between Petitioner Kimberly Jones and two deputy sheriffs during the deputies' attempt to serve an arrest warrant for an individual at the home of Petitioner. Petitioner filed a complaint against the deputies and the State, claiming that the State was negligent in its training of the two deputies. The jury returned a verdict finding the State liable for the deputies' negligent training and awarded Petitioner damages. The court of special appeals (CSA) reversed, concluding that there was legally insufficient evidence that the State breached any duty to Petitioner in connection with the tort of negligent training and supervision. The Supreme Court reversed the CSA and remanded with directions to affirm the judgment of the circuit court, holding that Petitioner presented legally sufficient evidence of her claim that the State was liable to her in tort for the negligent training of the two deputies. View "Jones v. State" on Justia Law

Plaintiffs were the widow of a decedent and the adult children of her marriage with the decedent. Plaintiffs asserted claims under the Wrongful Death Statute against University of Maryland Medical Systems Corporation (UMMSC). In their complaint, Plaintiffs did not identify or notify a stepson, Ricky Muti, whom the decedent had adopted during a prior marriage. The circuit court dismissed Plaintiffs' wrongful death claims arising from the failure to name Ricky as a "use" plaintiff in violation of Md. R. 15-1001. The court of special appeals held (1) Plaintiffs violated Rule 15-1001, and (2) the circuit court abused its discretion by denying Plaintiffs' leave to amend without first considering whether Ricky would be prejudiced by the denial. The Supreme Court vacated the judgment of the special court of appeals and remanded with instructions to reverse the judgment of the circuit court, holding that, under the totality of the circumstances, the circuit court abused its discretion in dismissing Plaintiffs' wrongful death claims as a sanction for the omission, where there was no basis for inferring that Ricky was omitted as a use plaintiff for the purpose of hiding the litigation from home or in the hope that Plaintiffs would increase their recovery. View "Univ. of Md. Med. Sys. Corp. v. Muti" on Justia Law

On two separate occasions, Respondent Edy Sanchez filed for benefits with the Workers' Compensation Commission while previous orders, in the same claim, were pending on appeal in the courts. The Commission decided that it lacked jurisdiction to consider Respondent's requests because of the pending appeals. The circuit court affirmed, holding that the Commission did not retain jurisdiction pending an appeal because the issues raised in the new filings did not fit within the jurisdictional provisions of Md. Code Ann. Lab. & Empl. 9-742. The court of special appeals reversed, holding that the Commission had jurisdiction over Respondent's new issues under section 9-736(b). The Court of Appeals affirmed, holding (1) under section 9-736(b), the Commission retains jurisdiction to hear new issues while other issues in the same claim are pending on appeal, so long as no evidence was taken or decision made on the new issues in the hearing from which the appeal was taken; and (2) section 9-742 was not intended to reduce the Commission's ongoing jurisdiction to grant relief, notwithstanding the appeal. View "Potomac Abatement, Inc. v. Sanchez" on Justia Law

This case stemmed from the judicial sale of a condominium owned by Petitioner and conducted by two court-appointed trustees that were employed by a law firm (collectively, Respondents). Following the sale, Petitioner filed a complaint, alleging breach of fiduciary duty involving actual fraud and breach of fiduciary duty involving constructive fraud by the trustees and alleging vicarious liability by the law firm. The trial judge granted Respondents' motion to dismiss, concluding that Respondents were entitled to qualified judicial immunity for their actions in connection with the sale. The court of special appeals (1) reversed with regard to Petitioner's allegations of actual fraud, and (2) affirmed with regard to the other causes of action on grounds of qualified judicial immunity. The Supreme Court affirmed in part and reversed in part, holding that Respondents were not entitled to absolute judicial immunity, and the concept of qualified public official immunity was inapplicable to the circumstances of this case. View "D'Aoust v. Diamond" on Justia Law

In McQuitty I, Dylan McQuitty, by and through his parents, successfully sued Ms. McQuitty's physician and his practice (collectively, Spangler) for having failed to obtain Ms. McQuitty's informed consent to treatment, which resulted in severe injuries to Dylan during his birth. In a series of post-trial motions following McQuitty I, Spangler moved to reduce the verdict in favor of the McQuittys. After the verdict but prior to resolution of the post-trial motions, Dylan died. The circuit court found that Dylan's death did not absolve the portion of the judgment allocated to Dylan's future medical expenses. The Court of Appeals held (1) the trial court properly denied Spangler's motions for post-trial relief; (2) the post-verdict death of Dylan did not absolve Spangler from the finality of the jury's award of future medical expenses; (3) the hospital, for which summary judgment was entered in its favor as to liability and damages during McQuitty I, was not a joint tort-feasor under Maryland's Uniform Contribution Among Tort-Feasors Act, such that its settlement release from the McQuittys did not entitle Spangler to a reduction of the judgment against them; and (4) post-judgment interest on the verdict accrued from the date of the original judgment. View "Spangler v. McQuitty" on Justia Law

Plaintiff, who had a latex allergy, asked her son's school to use non-powdered latex gloves so Plaintiff could enter the building safely. The school subsequently requested Plaintiff to withdraw her son from the school. Plaintiff filed a complaint against the school, alleging that the school had discriminated against her on the basis of a handicap and that the school had unlawfully retaliated against her request for accommodations. The jury returned a verdict in favor of Plaintiff. The court of special appeals reversed. The Supreme Court issued a writ of certiorari to consider whether discrimination because of a "handicap," within the meaning of the Maryland statutory provisions, should be construed strictly to create a demanding standard for qualifying as disabled, as certain federal cases had construed the term "disability" as used in the federal Americans with Disabilities Act. The Supreme Court reversed, holding (1) the court of special appeals erred in applying this standard to reverse the jury's verdict in this case; and (2) the jury was presented with sufficient evidence to determine that Plaintiff was the victim of discrimination because of a handicap under the Maryland statutory provisions. View "Meade v. Shangri-La P'ship" on Justia Law

Respondents, the owner of the City Paper and a reporter, published two articles in the City Paper that reported on a double murder. Petitioner, Nicholas Piscatelli, who was mentioned unflatteringly in the articles, perceived that his reputation had been injured thereby and he had been portrayed in a false light. Piscatelli sued Respondents for damages based on defamation and false light claims. The circuit court granted Respondents' motion for summary judgment. The court of special appeals affirmed. The Supreme Court affirmed, holding that the manner in which Respondent published the statements placed them within the protection of fair reporting and fair comment privileges, and consequently, Piscatelli's claims were not actionable. View "Piscatelli v. Smith" on Justia Law

Katherine Lewis filed a medical malpractice suit against her former psychiatrist, Dr. Jeremy Waletzky, for injuries she allegedly sustained as a result of medications he prescribed to her. Lewis did not comply with various administrative filing requirements set forth in the Health Care Malpractice Claims statute (the Act) before filing her complaint in the district court. Waletzky filed a motion to dismiss the complaint, arguing that Lewis was required to have complied with the Act's filing requirements. Lewis responded that she was not subject to the act because the injury occurred in Washington, D.C., and therefore, D.C. law governed her malpractice suit. The district court granted Waletzky's motion to dismiss after invoking the public policy exception to lex loci delicti. The Court of Appeals granted certification to answer whether Maryland recognizes the public policy exception to lex loci delicti based on the Act. The Supreme Court held (1) the filing provisions at issue in this case were procedural, mandating application of those requirements under Maryland choice-of-law principles, as the law of the forum; and (2) therefore, the doctrine of lex loci delicti did not apply under the circumstances. View "Lewis v. Waletzky" on Justia Law

Petitioner Mary Thomas slipped and fell on black ice that occurred in the premises of her apartment complex. Thomas filed a negligence action against the owner of the apartment complex and the apartment management company (collectively, Respondents). The circuit court granted summary judgment for Respondents based on Petitioner's alleged assumption of the risk. The Supreme Court reversed, holding that the trial judge erred by ruling, as a matter of law, that Petitioner assumed the risk. The issue of Petitioner's assumption of the risk, including her knowledge of the risk of slipping on black ice, and the voluntariness of her conduct in using the front steps as she exited her apartment building, were questions of fact to be resolved by the jury. View "Thomas v. Panco Mgmt. of Md." on Justia Law

While making a delivery during the course of his employment, Appellant George Pool walked through a stream of running water that flowed across a parking lot. As a result, Appellant slipped and fell on black ice and suffered injuries. Appellant sued Defendants, the construction company that allegedly pumped the water into the parking lot and the owner of the parking lot, alleging negligence. Several additional defendants were subsequently added. The trial judge granted summary judgment in favor of the original defendants and the two defendants named in Appellant's amended complaint on the ground that Appellant had assumed the risk of his injury. Appellant appealed. The Court of Appeals (1) reversed summary judgment entered in favor of the original defendants because Appellant did not assume the risk of his injury as a matter of law; (2) affirmed the grant of summary judgment in favor of one later-named defendant and the dismissal in favor of the other later-named defendant; and (3) disavowed the reasoning related to assumption of the risk in Allen v. Marriott Worldwide Corp. View "Poole v. Coakley & Williams Constr., Inc." on Justia Law