Justia Maryland Supreme Court Opinion Summaries

In his sixth time before the court of appeals, Anthony Grandison, a prisoner on death row for his role in a pair of 1983 murders, presented various requests for relief. Grandison's previous appeals resulted in one order denying an appeal and four published opinions. Grandison subsequently filed numerous motions, the majority of which the circuit court dismissed. The court did grant Grandison's motion to fire two appointed attorneys, and Grandison proceeded pro se for part of the collateral proceedings. Grandison then argued that he had a right to counsel for those proceedings and requested that he be appointed counsel so that he could go back and litigate the denied collateral claims with the benefit of counsel. Grandison also appealed the denial of his various motions. The Supreme Court (1) held Grandison did not have a right to counsel during the collateral proceedings, and the circuit court did not err or abuse its discretion in allowing Grandison to discharge counsel and continue pro se; and (2) affirmed the denial and dismissal of Grandison's motions by the circuit court. View "Grandison v. State" on Justia Law

In 1990, Appellant Michael Washington was convicted by a jury of first degree rape and related offenses and was sentenced to life in prison. Appellant later petitioned for a search for DNA material pursuant to Md. Code Ann. Crim. Proc. 8-201, after which the sheriff's office conceded it had destroyed biological evidence relating to Appellant's conviction. A hearing judge denied Appellant's subsequent petitions relating to this destruction of evidence. The Supreme Court affirmed, holding (1) the lower court did not err in finding that the State performed a reasonable search for the requested biological identification; (2) the State's duty to preserve scientific identification evidence, pursuant to section 8-201(j) begins as of the date the statute was enacted and is not to be applied retroactively; (3) because the hearing judge did not err in determining that the scientific identification evidence was destroyed prior to the enactment date of the statute, the statute was not applicable and Appellant was not entitled to the relief provided; and (4) the lower court did not err in finding that Appellant's conviction did not rest upon unreliable scientific identification evidence and denying Washington's motion for a new trial on that basis. View "Washington v. State" on Justia Law

Plaintiffs were the widow of a decedent and the adult children of her marriage with the decedent. Plaintiffs asserted claims under the Wrongful Death Statute against University of Maryland Medical Systems Corporation (UMMSC). In their complaint, Plaintiffs did not identify or notify a stepson, Ricky Muti, whom the decedent had adopted during a prior marriage. The circuit court dismissed Plaintiffs' wrongful death claims arising from the failure to name Ricky as a "use" plaintiff in violation of Md. R. 15-1001. The court of special appeals held (1) Plaintiffs violated Rule 15-1001, and (2) the circuit court abused its discretion by denying Plaintiffs' leave to amend without first considering whether Ricky would be prejudiced by the denial. The Supreme Court vacated the judgment of the special court of appeals and remanded with instructions to reverse the judgment of the circuit court, holding that, under the totality of the circumstances, the circuit court abused its discretion in dismissing Plaintiffs' wrongful death claims as a sanction for the omission, where there was no basis for inferring that Ricky was omitted as a use plaintiff for the purpose of hiding the litigation from home or in the hope that Plaintiffs would increase their recovery. View "Univ. of Md. Med. Sys. Corp. v. Muti" on Justia Law

On two separate occasions, Respondent Edy Sanchez filed for benefits with the Workers' Compensation Commission while previous orders, in the same claim, were pending on appeal in the courts. The Commission decided that it lacked jurisdiction to consider Respondent's requests because of the pending appeals. The circuit court affirmed, holding that the Commission did not retain jurisdiction pending an appeal because the issues raised in the new filings did not fit within the jurisdictional provisions of Md. Code Ann. Lab. & Empl. 9-742. The court of special appeals reversed, holding that the Commission had jurisdiction over Respondent's new issues under section 9-736(b). The Court of Appeals affirmed, holding (1) under section 9-736(b), the Commission retains jurisdiction to hear new issues while other issues in the same claim are pending on appeal, so long as no evidence was taken or decision made on the new issues in the hearing from which the appeal was taken; and (2) section 9-742 was not intended to reduce the Commission's ongoing jurisdiction to grant relief, notwithstanding the appeal. View "Potomac Abatement, Inc. v. Sanchez" on Justia Law

This case stemmed from the judicial sale of a condominium owned by Petitioner and conducted by two court-appointed trustees that were employed by a law firm (collectively, Respondents). Following the sale, Petitioner filed a complaint, alleging breach of fiduciary duty involving actual fraud and breach of fiduciary duty involving constructive fraud by the trustees and alleging vicarious liability by the law firm. The trial judge granted Respondents' motion to dismiss, concluding that Respondents were entitled to qualified judicial immunity for their actions in connection with the sale. The court of special appeals (1) reversed with regard to Petitioner's allegations of actual fraud, and (2) affirmed with regard to the other causes of action on grounds of qualified judicial immunity. The Supreme Court affirmed in part and reversed in part, holding that Respondents were not entitled to absolute judicial immunity, and the concept of qualified public official immunity was inapplicable to the circumstances of this case. View "D'Aoust v. Diamond" on Justia Law

In McQuitty I, Dylan McQuitty, by and through his parents, successfully sued Ms. McQuitty's physician and his practice (collectively, Spangler) for having failed to obtain Ms. McQuitty's informed consent to treatment, which resulted in severe injuries to Dylan during his birth. In a series of post-trial motions following McQuitty I, Spangler moved to reduce the verdict in favor of the McQuittys. After the verdict but prior to resolution of the post-trial motions, Dylan died. The circuit court found that Dylan's death did not absolve the portion of the judgment allocated to Dylan's future medical expenses. The Court of Appeals held (1) the trial court properly denied Spangler's motions for post-trial relief; (2) the post-verdict death of Dylan did not absolve Spangler from the finality of the jury's award of future medical expenses; (3) the hospital, for which summary judgment was entered in its favor as to liability and damages during McQuitty I, was not a joint tort-feasor under Maryland's Uniform Contribution Among Tort-Feasors Act, such that its settlement release from the McQuittys did not entitle Spangler to a reduction of the judgment against them; and (4) post-judgment interest on the verdict accrued from the date of the original judgment. View "Spangler v. McQuitty" on Justia Law

Plaintiff, who had a latex allergy, asked her son's school to use non-powdered latex gloves so Plaintiff could enter the building safely. The school subsequently requested Plaintiff to withdraw her son from the school. Plaintiff filed a complaint against the school, alleging that the school had discriminated against her on the basis of a handicap and that the school had unlawfully retaliated against her request for accommodations. The jury returned a verdict in favor of Plaintiff. The court of special appeals reversed. The Supreme Court issued a writ of certiorari to consider whether discrimination because of a "handicap," within the meaning of the Maryland statutory provisions, should be construed strictly to create a demanding standard for qualifying as disabled, as certain federal cases had construed the term "disability" as used in the federal Americans with Disabilities Act. The Supreme Court reversed, holding (1) the court of special appeals erred in applying this standard to reverse the jury's verdict in this case; and (2) the jury was presented with sufficient evidence to determine that Plaintiff was the victim of discrimination because of a handicap under the Maryland statutory provisions. View "Meade v. Shangri-La P'ship" on Justia Law

Petitioner Elroy Matthews invoked Md. Rule 4-345(a) to challenge the legality of the sentence he received following his plea of guilty to certain charges as part of a plea agreement. Petitioner argued that the sentence was illegal because it exceeded the sentence to which the court had bound itself. The circuit court denied the motion without a hearing. The court of special appeals held that a challenge to the legality of a sentence on the ground that it violates a binding term of a plea agreement is not cognizable under Rule 4-345(a), and even if it were, the sentence Petitioner received was not illegal. The Court of Appeals reversed, holding (1) Rule 4-345(a) is an appropriate vehicle for challenging a sentence that is imposed in violation of a plea agreement to which the sentencing court bound itself; and (2) the sentence Petitioner was serving was illegal because it exceeded the sentencing cap to which the circuit court agreed to be bound. Remanded for resentencing. View "Matthews v. State" on Justia Law

The Maryland Insurance Commissioner approved a filing by Allstate Insurance Company and Allstate Indemnity Company (collectively, Allstate) giving notice of its intent to cease writing new property insurance policies in certain geographic areas of the state. The Commissioner concluded that the filing was subject to administrative review under Md. Code Ann. 19-107(a) and Md. Code Ann. Ins. 27-501(a) and that it satisfied the pertinent criteria under both statutes. The circuit court affirmed both aspects of the Commissioner's ruling. The court of special appeals affirmed but on alternative grounds, holding that section 27-501(a) did not apply to the filing and that, even if it did, the statute was not violated. The Court of Appeals affirmed but, again, on different grounds, holding (1) the Commissioner did not err in finding that section 27-501 did apply to the Allstate filing, and (2) the evidence was sufficient to support the Commissioner's decision. View "People's Ins. Counsel Div. v. Allstate Ins. Co." on Justia Law

A police officer was dispatched to investigate a two-car collision, where she determined that one of the cars involved in the collision was owned by Respondent, Dana Carpenter. After a post-crash investigation, the officer requested Carpenter to submit to a chemical breath test, and Carpenter refused. Following a hearing, an administrative law judge (ALJ) suspended Carpenter's license for refusal to submit to the breath test. The circuit court reversed the suspension, determining that the police officer did not possess reasonable grounds to detain Carpenter. The Court of Appeals reversed the district court, holding that, pursuant to Md. Code Ann. Transp. 16-205.1(b)(2), the ALJ's determination that the police officer had reasonable grounds to detain Carpenter was supported by substantial evidence and was not premised upon an erroneous conclusion of law. Remanded with directions to affirm the decision of the ALJ. View "Motor Vehicle Admin. v. Carpenter" on Justia Law