Justia Maryland Supreme Court Opinion Summaries

Defendant Mario Gutierrez was charged with first-degree murder, first-degree assault, and use of a handgun in the commission of a crime of violence following the shooting death of the victim. At trial, witnesses testified that the incident was related to Defendant's affiliation with a street gang. The trial court permitted testimony of a gang expert who generally described the violent customs of the gang. The Court of Appeals affirmed, holding (1) expert testimony about the history, hierarchy, and common practices of a street gang is permissible where fact evidence establishes that the crime charged was gang-related and the probative value of the testimony is not substantially outweighed by any unfair prejudice to the defendant; and (2) the circuit court in this case did not abuse its discretion in permitting the gang expert to testify because ample fact evidence established a connection between the victim's shooting death and the street gang, and although the unfair prejudice of one of expert's statements outweighed its probative value, the error was harmless. View "Gutierrez v. State" on Justia Law

Petitioner was convicted by a jury of third-degree sexual assault and second-degree sexual assault. The victim was not referred for a sexual assault forensics exam. Before closing arguments, the trial judge gave a scientific evidence instruction instructing the jury that there was no legal requirement that the State utilize any specific investigative technique or scientific test to prove its case. Petitioner challenged the jury instruction on appeal. The court of special appeals affirmed. After the Court of Appeals granted certiorari in this case, it decided Atkins v. State, which stated that the most important consideration in evaluating whether a trial judge abused her discretion in giving a scientific evidence jury instruction was whether the instruction would run afoul of the prohibition against relieving the State of its burden where the the instruction's relation to the reasonable doubt standard was unclear. The Supreme Court reversed, holding (1) based on Atkins, no duty instructions are not per se improper, but (2) in the context of the present case, the trial court abused its discretion in giving such a jury instruction. Remanded for a new trial. View "Stabb v. State" on Justia Law

These two consolidated appeals involved two lawsuits, a derivative claim and a direct shareholder action, both arising from a series of stock transactions in two family corporations owned primarily by eight siblings. After the death of one of the sisters, the corporations attempted to repurchase her stock pursuant to the terms of a stock purchase agreement. The sister's estate refused. The corporations filed a declaratory judgment action, seeking enforcement of the agreement. Meanwhile, two siblings, aggrieved by an earlier stock transaction, filed a derivative action, alleging self-dealing and breach of fiduciary duty. The circuit court (1) granted summary judgment in favor of the corporations on the derivative action after deferring to the judgment of a special litigation committee (SLC); and (2) granted summary judgment to the corporation in the declaratory judgment proceeding. The Supreme Court (1) reversed the circuit court's judgment in the derivative action, holding that the court made an inadequate inquiry into the SLC's independence and the reasonableness of its procedures; and (2) reversed in part the circuit court's grant of summary judgment in the declaratory judgment action, holding that the circuit court erroneously applied res judicata to the issue. View "Boland v. Boland Trane Assocs." 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

Respondent Jeffrey Allen was twice tried and convicted on charges related to the robbery and murder of John Butler. Respondent was retried after the Court of Appeals affirmed the holding of the court of special appeals that Respondent was entitled to a new trial on the charge of felony murder. On retrial, the jury found Respondent guilty of first degree felony murder. Respondent argued on appeal that the trial court erred when it informed the jurors about his prior murder and robbery convictions, contending that the court's instructions amounted to the use of collateral estoppel against him. The court of special appeals agreed and reversed the felony murder conviction. The Court of Appeals affirmed, concluding that when the trial court informed the jury of Respondent's prior convictions, the court necessarily informed the jury that those two elements of felony murder were established as a murder of law, and thereby withdrew from the jury any consideration of them, which impermissibly estopped litigation on ultimate facts necessary to a finding that Respondent committed the crime charged, thereby impairing the function of the jury and depriving Respondent of his constitutional right to a trial by jury. Remanded for a new trial. View "State v. Allen" on Justia Law

The Maryland Real Estate Commission revoked the real estate licenses of Joel Pautsch pursuant to Md. Code Ann. Bus. Occ. & Prof. 17-322(b)(24)(i) based on Pautsch's convictions for child abuse. The circuit court affirmed after finding there was competent, material and substantial evidence to support the Commission's decision. The court of special appeals affirmed. The Court of Appeals affirmed, holding (1) there was substantial evidence upon which the Commission relief to support its finding that there was a nexus between Pautsch's convictions and his professional activities; and (2) the sanction was neither arbitrary nor capricious because Pautsch's crimes undermined his trustworthiness in dealing with the public during the course of providing real estate brokerage services and negatively impacted his character and reputation. View "Pautsch v. Real Estate Comm'n" 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

Petitioner Erik Stoddard was convicted by a jury of child abuse resulting in the death of a child and manslaughter. The Court of Appeals affirmed, holding (1) the trial court erred by placing an impermissible restriction on Petitioner's right against self-incrimination and infringing his right to due process when it required him to testify prior to the completion of the defense case or to forgo testifying at all, but this error was harmless under the circumstances of this case and did not prejudice Petitioner; and (2) the trial court did not err in admitting evidence of prior bad acts and a question implying that Petitioner posed a threat to another child. View "Stoddard v. State" on Justia Law

Petitioner Matthew Tracy was incarcerated when he wrote a letter to a potential witness in a criminal case against Petitioner's half brother. After the woman who received the letter turned it over to the State's county attorney, Petitioner was charged with retaliating against a witness and intimidating and/or influencing a witness based on the contents of the letter. Tracy was convicted of both charges. The court of special appeals affirmed. The Court of Appeals (1) reversed the court of special appeals' judgment affirming Petitioner's conviction for retaliating against a witness, holding that Petitioner was charged and convicted under an inapplicable statute; and (2) otherwise affirmed. Remanded. View "Tracy v. State" on Justia Law

A jury convicted Petitioner Terry Stevenson of conspiracy to commit attempted armed robbery and reckless endangerment. The court of special appeals affirmed the conspiracy conviction and reversed Petitioner's conviction for reckless endangerment. Petitioner filed a petition for writ of certiorari for the Court of Appeals' review, questioning whether conspiracy to attempt armed robbery was a cognizable crime because it was doubly inchoate and defied logic. The Court granted certiorari. After analyzing case law from several different jurisdictions, including its own jurisdiction, the Court of Appeals affirmed, holding that conspiracy to commit attempted armed robbery, a doubly inchoate crime, was a cognizable offense. View "Stevenson v. State" on Justia Law