Justia Maryland Supreme Court Opinion Summaries

Articles Posted in Maryland Court of Appeals
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Following a bench trial, Petitioner was convicted of sexual abuse of a minor and attempted sexual abuse of a minor. The convictions arose from messages thirty-eight-year-old Petitioner wrote to an eight-year-old student professing his love for her. The court of special appeals affirmed the convictions. The Court of Appeals upheld Petitioner's convictions, holding (1) the lower courts did not err in holding that Petitioner did not enjoy a reasonable expectation of privacy in his work desk for purposes of a Fourth Amendment challenge to a search of the desk; (2) sexual abuse of a minor can be committed by the exchange of non-sexually explicit letters and drawings; and (3) a rational trier of fact could have found the essential elements of child sexual abuse beyond a reasonable doubt. View "Walker v. State" on Justia Law

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Plaintiff contracted mesothelioma allegedly from exposure to asbestos fibers brought into her home on the clothing of her grandfather, who was exposed to asbestos-laden products during the course of his employment. Plaintiff sued her grandfather's employer (Employer), asserting strict liability and negligence claims. After a trial, a judgment was entered against Employer for more than $5 million. Employer appealed, claiming, among other things, that it had no duty to warn Plaintiff. The Court of Appeals reversed, holding that, at the relevant time back in 1968-69, there was no duty to warn persons such as Plaintiff of the danger of exposure to the dust on her grandfather's clothes. Remanded. View "Georgia Pac., LLC v. Farrar" on Justia Law

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Defendants were tried jointly and convicted of numerous crimes arising from a shooting in Baltimore that left one man dead and two other individuals wounded. The court of special appeals reversed the judgments against both men. Defendants were retried jointly before a jury and were again convicted. The court of special appeals affirmed, for the most part, the judgments of conviction of both Defendants. Defendants appealed, contending, among other things, that where an internal affairs investigator for the police found "facts sustained" against officers, the trial court erred (1) in refusing to permit the defense to inspect internal investigation division files concerning misconduct by certain law enforcement officers, and (2) at trial, in refusing to allow the defense to cross-examine the officers about the misconduct. The Supreme Court reversed with instructions to vacate the judgments of conviction and remand the case for retrial, holding that the denial of access to potentially significant impeachment evidence and the subsequent denial of an opportunity to demonstrate a reasonable actual basis for cross-examination was not harmless beyond a reasonable doubt. View "Fields v. State" on Justia Law

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Plaintiff was a soccer player who had volunteered to assist in coaching a team of young soccer players in a program of the Soccer Association of Columbia (Defendant). Plaintiff was injured when the soccer goal, which was not anchored to the ground, fell on top of him after he grabbed the upper crossbar. Plaintiff subsequently filed a negligence complaint against Defendant. Defendant asserted the defense of contributory negligence. The trial court entered judgment in favor of Defendant, finding that because both parties were negligent, Plaintiff was barred from any recovery. Plaintiff appealed, arguing that the Court of Appeals should abrogate Maryland's long-established common law principle of contributory negligence. The Court of Appeals affirmed, holding that the Court would not change the common law and abrogate the contributory negligence defense in negligence actions in the face of the General Assembly's repeated refusal to do so. View "Coleman v. Soccer Ass'n of Columbia" on Justia Law

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County Council enacted a bill providing that Appellant forfeited his councilmanic position, concluding that Appellant had moved his residence from his councilmanic district to a correctional facility in South Carolina after having been convicted of failing to file a federal tax return. Appellant challenged the authority of the County Council to expel him as a member based upon its interpretation of the term "residence" in the County Charter as a "temporary place of abode." The circuit court granted summary judgment for the County and County Council. The Court of Appeals reversed, holding that "residence" in the Charter embodies the notion of domicile, such that Appellant did not move his residence by virtue of his five-month incarceration. View "Jones v. Anne Arundel County" on Justia Law

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This case arose out of a domestic altercation between Husband and Wife. Wife filed a petition for protection from domestic violence against Husband. The district court issued a final protective order against Husband. Prior to the expiration of the protective order, Wife filed a motion to extend the order. Two days after the expiration of the protective order, the district court scheduled a hearing on the motion. After the hearing, the district court extended the protective order. The circuit court affirmed, reasoning that, as long as a motion to extend a protective order is filed during the term of the order, that protective order may be extended even if a hearing on the motion is held after the protective order has expired. The Supreme Court reversed, holding that Md. Code Ann. Fam. Law 4-507(a) does not permit a court to extend an expired protective order even when the motion to extend the order was timely filed during the term of the order. View "La Valle v. La Valle" on Justia Law

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After a jury trial, Petitioner, who had a prior non-violent felony conviction, was convicted of wearing and carrying a handgun and two counts of possession of a regulated firearm by a person with a prior conviction. The court of special appeals vacated as duplicitous Petitioner's conviction and sentence for one count of possession of a regulated firearm by a person previously convicted. The Supreme Court (1) vacated Petitioner's sentence for possession of a regulated firearm, holding that Petitioner was wrongful subjected to an enhanced penalty under Md. Code Ann. art. 27, 449(e), which requires that a predicate prior conviction be for a crime that is both violent and felonious; and (2) held that the rule of lenity required that Petitioner be sentenced in accordance with Md. Code Ann. Crim. Law 5-622(c) rather than section 449(e) because both penalty provisions proscribe the same conduct, but section 5-622(c) mandates a lesser penalty, and the legislature did not clearly express how the two statutes were intended to interface. Remanded for resentencing. View "Alston v. State" on Justia Law

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Plaintiff filed this action for negligence and assault against Defendant. Upon reaching a verdict, the jury foreman answered the court clerk's questions about the negligence count by using the verdict sheet submitted to and completed by the jury. The trial court found Defendant to be negligent based on these answers. However, it was not until after the jury was dismissed that the judge received the jury's completed copy of the verdict sheet, upon which the jury indicated that it intended to award damages. The trial judge enrolled the verdict sheet as the jury's verdict, awarding damages accordingly. The court of appeals vacated the award because that portion of the jury's verdict had not been announced in open court. The Supreme Court reversed, holding (1) after a jury verdict is orally announced, the verdict is subject to a judge's revisory powers; (2) revision is permissible only when the intent of the jury is manifest beyond doubt; and (3) the trial judge properly exercised his discretion in revising the verdict to include the award of damages as shown on the verdict sheet, as the revision effectuated the intent of the jury. View "Turner v. Hastings" on Justia Law

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In 2009, Respondents, residents of the Jacksonville community, were awarded damages by a jury for an Exxon contractor's puncture of an underground gasoline feed line at an Exxon Mobil-owned gasoline service station. Several thousand gallons of gasoline leaked into the local underground aquifer and contaminated the source of the wells supplying water to Respondents' households. The Supreme Court affirmed in part and reversed in part the damages award and ordered all costs to be paid pro rata by Respondents. Respondents subsequently filed a motion for reconsideration. Exxon responded with an amended request for bond premium costs seeking reimbursement. The Supreme Court denied the motion for reconsideration and Exxon's request but changed the mandate in Ford to order that the parties shall bear their own costs, concluding that requiring Respondents to bear $1 million in premium bond costs was unreasonable under the circumstances. View "Exxon Mobil Corp. v. Ford" on Justia Law

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Plaintiffs, in two separate lawsuits, sued a medical doctor and medical center for medical negligence, lack of informed consent, and fraud. Prior to the trial date, Defendants successfully moved to bifurcate the trials. The administrative judge of the circuit court vacated the trial judge's orders bifurcating the trials and reassigned the cases to another judge for trial. Defendants filed a petition for writ of mandamus or prohibition to reverse the administrative judge's orders. The Court of Appeals vacated the administrative judge's orders and reinstated the orders of the trial judge, holding that, under the circumstances, the administrative judge did not have the authority to review and vacate the trial judge's decision to bifurcate the trials and to unilaterally reassign the cases. View "St. Joseph Med. Ctr. v. Circuit Court (Turnbull)" on Justia Law