Justia Maryland Supreme Court Opinion Summaries

Articles Posted in Maryland Court of Appeals
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The Maryland State Conference of NAACP Branches (NAACP), pursuant to the Public Information Act, requested certain records from the Maryland State Police Department (State Police) to ensure State Police officers did not engage in racial profiling during traffic stops and searches. Although the State Police did provide the NAACP with reports detailing the number and status of racial profiling complaints, the reports did not contain information concerning the State Police's own internal investigations of these complaints, as it considered those records portions of personnel files. The circuit court concluded that the records constituted personnel records but that they should be disclosed with redaction of names and identification. The court of special appeals held that the unredacted records were not exempt from disclosure, as the files did not constitute personnel records of an individual. The Court of Appeals affirmed but for different reasons, holding (1) the disclosure of unredacted records was not properly before the court of special appeals; and (2) the redacted records were not personnel records, and therefore, the circuit court did not err in its judgment. View "Md. Dep't of State Police v. Md. State Conf. of NAACP Branches" on Justia Law

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Petitioner filed a complaint against Respondent for unfair and deceptive trade practices and for common law fraud. Petitioner's complaint was based on an automobile warranty he purchased from Respondent that expired more than two years earlier than he had been led to believe. Petitioner purported to bring his action on behalf of others similarly situated. Before Petitioner filed a motion to certify the class, however, Respondent paid to extend Petitioner's warranty. The circuit court (1) denied Petitioner's motion for class certification, finding that because he had been made whole, Petitioner was no longer a member of any class; (2) granted in part Respondent's motion for summary judgment, finding Petitioner's claim moot; and (3) granted Petitioner attorney's fees for the period before and after Respondent tendered Petitioner individual relief. The Court of Appeals affirmed in part and reversed in part, holding (1) Respondent's tender of individual compensatory relief to Petitioner did not require the court to deny class certification; (2) an award of punitive damages is not foreclosed by the tender of individual compensatory damages; and (3) an award of attorney's fees to Petitioner under a fee-shifting provision of the Consumer Protection Act is not limited to fees incurred before the tender. View "Frazier v. Castle Ford, Ltd." on Justia Law

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The Church of Jesus Christ of Latter-day Saints requested that it be exempt from paying property tax on an apartment complex it owned in Maryland to house missionaries. The county supervisor of assessments concluded that the apartment complex did not qualify for a property tax exemption under Md. Code Ann. Tax-Prop. 7-204 because the complex was not exclusively used as a "parsonage" or a "convent." The Maryland tax court upheld the decision. The circuit court reversed, determining that the complex qualified as both a parsonage and a convent. The Court of Appeals affirmed, holding that the tax court applied the wrong standard in assessing whether the apartment complex constituted a convent. Remanded for the tax court to issue an order granting the exemption. View "Green v. Church of Jesus Christ of Latter-day Saints" on Justia Law

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Respondent was injured while performing his job as a school police officer in Baltimore City. After the City terminated his employment, Respondent applied for line-of-duty disability retirement. A hearing examiner denied Respondent's application, concluding that Respondent did not satisfy the eligibility requirements of Baltimore, Md., Code 22, 9(j), which requires a claimant to prove he sustained at least a fifty percent total impairment as the direct result of a line-of-duty accident. The hearing examiner concluded that Respondent did not satisfy the statutory requirements because the impairment to Respondent's back was not independent of all other causes, reasoning that Respondent's degenerative disc disease contributed to the disability of his back. The circuit court reversed, and the court of special appeals affirmed. The Court of Appeals affirmed, holding that Respondent's preexisting condition did not preclude him from qualifying for line-of-duty disability retirement because he proved that fifty percent of his total level of disability was the direct result of the injury he sustained while performing in the line of duty. View "Employees' Ret. Sys. of City of Baltimore v. Dorsey" on Justia Law

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Petitioners filed a petition for judicial review of the Baltimore City Council's approval of a planned unit development (PUD) with a Wal-Mart supercenter. Both Petitioners' residences were approximately 0.4 miles away from the PUD. The Mayor and City Council of the City, the owners of the property, and the developers of the PUD (Respondents) filed motions to dismiss, alleging that Petitioners lacked standing to challenge the PUD. The circuit court granted Respondents' motions and dismissed Petitioners' petition for review. The court of special appeals affirmed, concluding that Petitioners did not qualify for prima facie aggrieved status and that they had failed to show any special aggrievement different from the general public. The Supreme Court granted certiorari and held that the circuit court did not err in its judgment, as Petitioners failed to allege specific facts that they had been specially aggrieved in a manner different than the public generally. View "Ray v. Baltimore" on Justia Law

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In Powell I, Plaintiff sued Doctor and others for medical malpractice. The circuit court granted summary judgment to Appellees in 2007. The appellate court held that the appropriate remedy was to dismiss the suit. The Supreme Court affirmed, vacated the grant of summary judgment, and remanded for dismissal. By the time the complaint was dismissed in 2011, the statute of limitations had expired on the merits of the substantive claims. In Powell II, Plaintiff filed a second, identical statement of claim in 2007. The circuit court granted Defendants' motion for summary judgment in 2008 under the doctrine of res judicata. In 2011, Plaintiff filed in Powell II a motion to reopen case and vacate judgment, arguing that the circuit court's reliance on the preclusive effect of the decision in Powell I was faulty. The circuit court denied the motion. The Supreme Court accepted certification and held (1) in Powell II, the judge did not err in granting summary judgment because, at the time, the doctrine of res judicata barred the maintenance of the litigation based on the 2007 grant of summary judgment in Powell I; and (2) the circuit court did not err in denying Plaintiff's motion to reopen case and vacate judgment. View "Powell v. Breslin" on Justia Law

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On behalf of himself and a proposed class of others similarly situated, Plaintiff filed an action challenging the legality of Ticketmaster's collection of a service charge on a concert ticket he purchased for a concert in the city. The complaint was based on provisions of the Baltimore City Code. The Supreme Court accepted certification to answer questions of law and held (1) if a ticket agency is authorized in writing by a licensed exhibitor to sell tickets as an agent of the exhibitor, the ticket agency is not required to be licensed; (2) the Code prohibits the collection of a service charge, in addition to the established price printed on the ticket, in connection with the original sale of the ticket by the exhibitor, and is not limited to ticket resales; (3) the Code does not permit anyone other than a ticket agency licensed under the Code to collect anything more for a ticket than the established price printed on the ticket plus taxes; and (4) a common law action for money had and received will lie to recover money paid in excess of that allowed by statute if the agreement pursuant to which it has been paid has not been fully consummated. View "Bourgeois v. Live Nation Entm't, Inc." on Justia Law

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Petitioner, a Mexican immigrant who did not speak or comprehend English, was convicted of first degree murder and related offenses. Before trial, Petitioner sought suppression of a statement he made connecting him to the murder. On appeal, Petitioner argued that the State failed to prove that he was properly advised of, and validly waived, his Miranda rights. The court of special appeals concluded that the record developed at the suppression hearing sufficed to permit the court to rule that the Miranda warnings and Petitioner's waiver complied with constitutional dictates. The Supreme Court affirmed, holding that the suppression court reasonably could find, from the totality of the evidence offered by the State, that the State proved both that proper Miranda warnings were adequately conveyed to Petitioner and that he knowingly and voluntarily waived those rights before he was interrogated and made the statement he sought to suppress. View "Gonzalez v. State" on Justia Law

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Petitioner, an LLC, sought an exception from the Charles County Zoning Regulation to build an office building, gun range, and driving track on a parcel of land in a rural community in the County. The property was subject to zoning restrictions prohibiting such activity except as authorized through a special exception. In deciding Petitioner's application, the Board conducted one trip to the property in question. The Board allowed representatives from the LLC as well as two citizens to attend but prohibited any other members of the public from attending and kept no transcript or other record of that which transpired. The Board then granted Petitioner's application. Various individuals filed a petition for judicial review. The circuit court affirmed. The court of special appeals reversed, holding that the Board improperly conducted the visit to the property in a manner that was closed to the public. The Supreme Court affirmed, holding (1) the site visit constituted a "meeting", which was required to be open to the public; and (2) because the Board violated the open meeting provisions of the Maryland Code, the Charles County Code, and its own Rules of Procedure, the matter should be remanded for a new hearing. View "WSG Holdings, LLC v. Bowie" on Justia Law

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Defendant entered a plea of not criminally responsible to charges of first-degree attempted murder and was found incompetent to stand trial. Defendant was committed to the Perkins Hospital for several years waiting to become competent to stand trial. The charges against him were eventually dismissed pursuant to Md. Code Crim. Proc. 3-107(a), which requires dismissal of charges upon passage of certain time period. The State subsequently re-indicted Defendant, who was again found incompetent and placed at Perkins for another round of incompetency-to-stand-trial (IST) treatment. Defendant challenged his re-indictment, arguing that the State could not continue to confine him by re-indicting him on the same charges that were required to be dismissed. The appellate court reversed. The Supreme Court vacated the appellate court's ruling and remanded, holding (1) section 3-107 expressly provides that a dismissal of charges is without prejudice; but (2) nevertheless, Defendant's IST committment was improper, as (i) the passage of five years without Defendant's becoming competent and the resulting dismissal of his original charges under section 3-107 created the presumption that Defendant could not be restored to competency, and (ii) ordering Defendant in IST commitment, while the presumption that he was unrestorable was in place, was error. View "State v. Ray" on Justia Law