Justia Maryland Supreme Court Opinion Summaries

Peter Toland, a Maryland resident, filed a complaint to establish custody of his daughter, Erika, who lived with her maternal grandmother, Akiko Futagi, in Japan. The mother of Erika, having previously been awarded custody by a Japanese court, died in 2007. A Japanese decree issued thereafter, and without notice to Toland, appointed Futagi as the guardian of Erika. Toland subsequently amended his complaint and alleged that Maryland was the appropriate forum to determine custody under the Maryland Uniform Child Custody Jurisdiction and Enforcement Act. The circuit court dismissed Toland's complaint, concluding (1) the Japanese guardianship decree did not constitute a violation of Toland's due process rights; and (2) Japan was the home state of Erika under the Act because Erika had lived exclusively in Japan for her entire life. The Court of Appeals affirmed, holding (1) the circuit court's dismissal of Toland's complaint did not violate his due process rights, as they were not implicated by the Japanese decree; and (2) the circuit court properly applied the Act to conclude that it should not exercise jurisdiction over Toland's complaint to establish custody, as the child had no connection with Maryland, and Japan had not declined custody jurisdiction. View "Toland v. Futagi" on Justia Law

Petitioner Ricky Washington was convicted by a jury of first degree rape and related offenses. Petitioner appealed, claiming, inter alia, that the trial court had abused its discretion in declining to ask during voir dire of the jury panel whether any prospective juror would be more likely to believe a witness solely by virtue of the witness having served in the military or being employed by the military. The court of special appeals affirmed. The Court of Appeals affirmed, holding (1) only certain questions are mandatory during voir dire of a jury panel if they are directly related to the facts and circumstances of the case; (2) based on the circumstances of this case, Petitioner's proposed question was not mandatory, and thus, it was within the discretion of the trial court whether to pose the question to the jury trial; and (3) the trial court did not abuse its discretion in denying Petitioner's request to ask the question. View "Washington v. State" on Justia Law

Petitioner Curtis Alston was convicted of first degree murder and related offenses and sentenced to life in prison without parole for first degree murder and lesser terms for the other offenses. Later, the postconviction trial court vacated Alston's convictions and sentences and granted him a new trial. Forty-four days after the entry of the final judgment in the postconviction case, the State filed a motion to reconsider. The court did reconsider its earlier judgment and denied Alston's petition for postconviction relief, thereby re-imposing Alston's original convictions and sentences. Alston then commenced the present case by filing a motion to correct illegal sentences, claiming he was entitled to relief under Md. R. 4-345(a), which provides that a court may correct an illegal sentence at any time. The circuit court denied the motion, and the court of special appeals affirmed. The Court of Appeals reversed, holding (1) the postconviction trial court's re-imposition of Alston's original sentences, after having vacated those sentences and having ordered a new trial, was unlawful; and (2) the court's illegal action was cognizable under Rule 4-345(a). Remanded to correct the imposition of the illegal convictions and sentences. View "Alston v. State" on Justia Law

After being pulled over for a routine traffic stop, Petitioner Tyrone Smith was convicted of driving without a license. Petitioner was convicted under Md. Code Ann, Transp. 16-101(a) (the statute), which contains three parts. Petitioner appealed, claiming that the State must prove all three parts of the statute as elements of the offense beyond a reasonable doubt. The Court of Appeals affirmed, holding that the State need only prove the first part of the statute to convicted a defendant of driving without a license, and that the second and third parts are affirmative defenses that must be raised by a defendant. View "Smith v. State" on Justia Law

Petitioner Elliott McClain was convicted by a jury of first degree murder and related offenses. At trial, the State offered into evidence an audiotape of a prior statement by a State's witness without explicitly offering at that time a theory for its admission. The trial court admitted that audiotape, reasoning that it was admissible as either a prior consistent statement or a prior inconsistent statement. The Court of Appeals affirmed, holding that the trial court did not err (1) in admitting the audiotape statement as a prior inconsistent statement pursuant to Md. R. Evid. 5.802.1(a); and (2) in sending to the jury room during deliberations, absent a specific request from the jury, the audiotape statement of the witness and other prior audiotape statements that were admitted into evidence. View "McClain v. State" on Justia Law

Md. R. Evid. 5-804(b)(1) allows for the admission of "former testimony" hearsay when the party against whom the declarant's statement is offered had an opportunity to develop the testimony at a prior action or proceeding. Petitioner Leon Dulyx was found guilty by a jury of aiding and abetting a robbery and aiding and abetting theft under $500. Petitioner appealed, contending that the circuit court erred under Rule 5-804(b)(1) and the Confrontation Clause in allowing the State to introduce at trial testimony of a witness taken during a pre-trial hearing to suppress the witness's extrajudicial identification of Petitioner. The court of special appeals affirmed the judgments. The Court of Appeals reversed, holding that the court of special appeals erred when it held that Petitioner was given a "full and fair opportunity" to cross-examine the witness despite substantial limitations placed on Petitioner's ability to question him. Consequently, the witness's testimony at that hearing was not admissible at Petitioner's trial under the "former testimony" hearsay exception. Remanded. View "Dulyx v. State" on Justia Law

Respondents Wayne Singleton and his eight-year-old son were passengers in a bus when the bus left the road and collided with a tree. Respondents sued Petitioner, the District of Columbia, alleging that it was liable vicariously for the negligence of its assumed employee, the driver. Respondents produced at trial only themselves as witnesses and argued that res ipsa loquitur supplied an adequate inference of negligence to complete their prima facie case. The trial judge granted the District's motion for judgment. The Court of Appeals affirmed, holding that under the circumstances of this case, Respondents failed to show that they were entitled to an inference of negligence, as Respondents' evidence failed to demonstrate that negligence on the part of the bus driver was more probably than not the cause of the accident or to eliminate other potential causes of the accident. View "Dist. of Columbia v. Singleton" on Justia Law

Petitioner Charles Phillips was arrested and subjected to a custodial interrogation. After about forty-five minutes of conversation, Petitioner expressed a desire to consult with an attorney. Following that expression, a police detective continued to engage Petitioner in conversation, during which Petitioner indicated a desire to continue talking to the detective and ultimately made a number of incriminating statements. Petitioner was subsequently convicted of first degree murder and armed robbery. The court of special appeals affirmed. The Supreme Court granted Petitioner's petition for certiorari to determine whether his inculpatory statements were elicited in violation of Edwards v. Arizona. The Court of Appeals reversed, holding that the conversation that ensued after Petitioner's invocation of his right to an attorney constituted a prohibited interrogation, and thus, Petitioner's inculpatory statements should have been suppressed. View "Phillips v. State" on Justia Law

In this custody modification proceeding, Joanna Davis was ordered by the circuit court to pay her ex-husband, Michael Petito, $30,773 in attorneys' fees and costs because the trial court determined she was in a better financial position than Petito due to Davis having received pro bono representation by the Sexual Assault Legal Institute (SALI), whereas Petito had accumulated over $70,000 in legal fees as a result of retaining private counsel. The court of special appeals affirmed. The Court of Appeals reversed, holding that the court's consideration that Davis was represented on a pro bono basis in order to award attorneys' fees to Petito, who had retained counsel, was erroneous under Md. Code Ann. Fam. Law 12-103. Remanded. View "Davis v. Petito" on Justia Law

After the IRS concluded its audit of the Baltimore Orioles Limited Partnership's tax returns for years 1993-1999 and adjusted various partnership items, the personal income tax liability of Wanda King, one of the limited partners, was lessened and she became eligible for a state tax refund totaling $173,364. King filed a claim for refund, but the Comptroller of the Treasury denied it, stating that the refund claim was not timely filed because the IRS's final report regarding adjustments to King's personal tax liability had been issued more than a year before King filed her refund. On appeal, the Maryland tax court ruled in favor of the Comptroller. The circuit court reversed the tax court, and the court of special appeals reversed. The Supreme Court affirmed the court of special appeals, holding (1) the statute of limitations applicable to King's refund claim began to run when the IRS issued to her certain forms on January 3, 2006, and accordingly, King's refund claim had to have been filed within one year of that date; and (2) thus, King's submission on February 2, 2007 was untimely. View "King v. Comptroller" on Justia Law