Justia Maryland Supreme Court Opinion Summaries

The Court of Appeals affirmed the judgment of the appellate court reversing the decision of the circuit circuit court that examination of data contained on Defendant's hard drive was not a search in violation of the Fourth Amendment, holding that the government violated Defendant's Fourth Amendment rights in this case.Defendant voluntarily consented to government agents seizing his laptop computer, creating a copy of its hard drive, and searching the data on it. After the copy was made but before the government examined the data Defendant withdrew his consent. Defendant moved to suppress the evidence from the forensic examination of the copy of his laptop's hard drive. The circuit court denied the motion. On appeal, Defendant asserted that he had a legitimate expectation of privacy in the mirror-image copy of his laptop hard drive. The appellate court agreed and reversed. The Court of Appeals affirmed, holding (1) Defendant had a reasonable expectation of privacy in the data contained on his hard drive; (2) because the government did not examine the data before Defendant withdrew his consent Defendant did not lose his reasonable expectation of privacy in the data; and (3) the government conducted an unreasonable search by examining the data without any authority to do so. View "State v. McDonnell" on Justia Law

The Court of Appeals reversed Petitioner's conviction for first-degree murder and use of a handgun in the commission of a crime, holding that the circuit court erred in permitting a firearms examiner to testify, without qualification, that bullets left at a murder scene were fired from a gun that Petitioner had acknowledged was his, and the error was not harmless.In arguing that the circuit court abused its discretion in permitting the firearms examiner's testimony Petitioner cited reports, studies, and testimony calling into question the reliability of firearms identification analysis. The Court of Appeals agreed with Petitioner and reversed and remanded the case for a new trial, holding (1) the reports, studies, and testimony presented to the circuit court demonstrated that the firearms identification methodology employed in this case could not reliably support an unqualified conclusion that the bullets were fired from a particular firearm; and (2) this Court was not convicted, beyond a reasonable doubt, that the error in no way influenced the verdict. View "Abruquah v. State" on Justia Law

The Court of Appeals vacated the judgment of the appellate court affirming the decision of the circuit court denying Appellant's motion to dismiss the charges against him after this Court remanded his case to the circuit court with instructions to grant his petition for writ of actual innocence and to conduct a new trial, holding that it was not possible for the Court to meaningfully evaluate whether Appellant suffered irreparable prejudice for which dismissal of the charges was the only feasible remedy.Appellant was convicted of first-degree murder. After Appellant's petition for writ of actual innocence was denied, the Court of Appeals concluded that the circuit court erred in denying the petition. Before his retrial, Appellant moved to dismiss the charges based on due process and double jeopardy violations. The circuit court denied the motion, after which Appellant and the State entered into a plea agreement. The appellate court affirmed the denial of Appellant's motion to dismiss. The Court of Appeals vacated the judgment and remanded the case, holding that, given that the new trial ordered by the Court did not take place, it was not possible for this Court to assess beyond mere speculation what the evidence might have consisted of at retrial. View "Smith v. State" on Justia Law

The Court of Appeals affirmed the judgment of the appellate court concluding that the circuit court erred in determining that there was no public road over the parcel of real property in St. Mary's County at issue in this case but did not err in determining that the County owned the property in fee simple absolute, holding that the appellate court did not err.The trustee of the Wilkinson Family Trust sued the Board of County Commissioners of St. Mary's County asserting ownership of the property at issue. The circuit court found that the County owned the property in fee simple absolute and that no public road existed on the property. The appellate court vacated the judgment and remanded the case. The Court of Appeals affirmed, holding that the appellate court (1) did not err in concluding that the County owned the property in fee simple absolute; and (2) did not err in holding that, as a matter of law, a public road was established on the property by dedication. View "Bd. of County Commissioners v. Aiken" on Justia Law

The Court of Appeals affirmed in part and reversed in part the judgment of the appellate court deciding the merits of Defendant's appeal and affirming Defendant's conviction for voluntary manslaughter and related offenses, holding that the constitutional right to a fair trial extends to appellate proceedings, that the appellate court erred in deciding the merits of Defendant's appeal, and that a new trial was required.During Defendant's appeal, the appellate court compared Defendant, an African American man, to the mythical monster Grendel in Beowulf. On appeal to the Court of Appeals Defendant argued that this reference evoked racist tropes of African Americans and that other passages in the appellate court's dicta deprived him of his constitutional right to a fair and impartial appellate process. The Court of Appeals remanded the case for a new trial, holding (1) the right to fair and impartial judges extends to appellate proceedings; and (2) the appellate court erred in concluded that the exclusion of certain evidence was harmless because its exclusion was harmful, reversible error. View "Belton v. State" on Justia Law

The Court of Appeals affirmed the judgment of the circuit court denying Petitioner's petition for post-conviction DNA testing pursuant to Md. Code Ann. Crim. Proc. 8-201(b)(1), holding that Petitioner was not entitled to relief on his allegations of error.Petitioner was convicted of first-degree murder and other offenses and sentenced to life imprisonment plus a term of 150 years' imprisonment. In his post-conviction petition, Petitioner asserted that there was a reasonable probability that DNA testing of certain evidence had the scientific potential to produce exculpatory or mitigating evidence. The circuit court denied the petition. The Court of Appeals affirmed, holding that the circuit court properly denied the petition because the record and testimony reflected that any results of testing the subject evidence would not produce exculpatory or mitigating evidence. View "Satterfield v. State" on Justia Law

The Court of Appeals remanded this case to the circuit court for entry of a declaratory judgment that Jacob Bennett was qualified to serve as a member of the Harford County Council while simultaneously being employed as a teacher by the Harford County Board of Education, holding that Bennett was entitled to relief.Harford County brought suit seeking a declaratory judgment that Bennett was not qualified to serve on the Harford County Council. Bennett filed a counterclaim seeking injunctive and declaratory relief and a writ of mandamus. The circuit court ruled that Bennett was precluded from serving on the Harford County Council. The Court of Appeals granted relief and ordered that Bennett was not precluded from serving as a member of the Harford County Council. View "Bennett v. Harford County" on Justia Law

The Court of Appeals affirmed the judgment of the appellate court dismissing Appellant's appeal of the circuit court's ruling affirming the judgment of the Maryland Commission on Civil Rights finding no probable cause to believe that Krav Maga MD, LLC (KMMD) engaged in disability discrimination, holding that the appellate court correctly dismissed Appellant's appeal.Appellant alleged that KMMD, her gym, engaged in disability discrimination by deleting a comment that Appellant had posted on the gym's Facebook account relating to her disability and then later by terminating her membership. The Commission ultimately found no probable cause the find that KMMD had discriminated against Appellant based on her disability. The circuit court affirmed the Commission's finding of no probable cause. On appeal, the appellate court ruled that it lacked jurisdiction to consider Appellant's appeal. The Court of Appeals affirmed, holding that the appellate court correctly dismissed Appellant's appeal. View "Rowe v. Md. Comm'n on Civil Rights" on Justia Law

The Court of Appeals affirmed the judgment of the circuit court holding that Md. Code Ann., Elec. Law 8-103(b)(1) is constitutional, determining that the State Board of Elections had proven the existence of emergency circumstances, and permitting the State Board to begin canvassing absentee ballots on Oct. 1, 2022, holding that there was no error.In connection with the November 8, 2022 general election the State Board petitioned the circuit court to authorize local boards of election to begin canvassing absentee ballots on October, 2022, seeking the authority under section 8-103(b)(1). The State Board alleged that emergency circumstances existed that interfered with the electoral process because the State's combined experience with absentee ballots and elections led to the conclusion that the volume of absentee ballots it was likely to receive during the 2022 general election could not be processed in a timely manner if local board could not start canvassing the ballots until after the election. Daniel Cox intervened and opposed the petition, arguing that section 8-103(b)(1) violates separation of powers principles and that the forecasted problems did not constitute "emergency circumstances." The circuit could granted judgment for the State Board. The Court of Appeals affirmed, holding that the Cox was not entitled to relief on his assignments of error. View "In re Petition for Emergency Remedy of Bd. of Elections" on Justia Law

The Court of Appeals affirmed Defendant's conviction of sexual abuse of a minor under Md. Code Ann., Crim. Law (CR) 3-602, holding that, under the applicable standard of review, the evidence was sufficient for a rational juror to find that, with his in-classroom conduct, Defendant, a thirty-year-old substitute teacher, engaged in an act that involved sexual exploitation of a minor.Defendant indulged in a sexually exploitative relationship with A.G., a twelve-year-old student, during out-of-school hours. The appellate court reversed Defendant's conviction for sexual abuse of a minor on the grounds that he had not "said or implied anything sexual" in his conversation with A.G. in school. The Court of Appeals reversed, holding (1) the occurrence of sexual exploitation outside of the perpetrator's time of responsibility for supervision of the minor may be used to establish child sexual abuse under CR 3-602, but there must be a showing that the perpetrator engaged in an act relating to, affecting or that was a part of the sexual exploitation while the perpetrator was responsible for the care, custody, or supervision of the minor; and (2) the evidence demonstrated that Defendant's in-school conduct fell within the meaning of the language of the statute. View "State v. Krikstan" on Justia Law