Justia Maryland Supreme Court Opinion Summaries

A jury convicted Petitioners Cyrus Beads and Joseph Smith of several crimes against the person of three victims as well as several related offenses, including use of a handgun in the commission of a crime of violence. The court of special appeals consolidated Petitioners' appeals and affirmed their convictions. The Supreme Court reversed, holding (1) the trial court erroneously overruled objections to unfairly prejudicial comments made by the prosecutor, (2) the trial court erroneously concluded that the cross-examination of Smith's trial counsel "opened" the door to testimony that Smith had previously been incarcerated, and (3) because the trial court failed to take any corrective actions in response to the improper arguments and inadmissible evidence, these erroneous rulings were not harmless. Remanded for a new trial. View "Beads v. State" on Justia Law

A jury convicted Petitioner Anthony Miller of two counts of second degree murder. The court of special appeals affirmed. Petitioner then filed a petition for writ of certiorari. The question Petitioner presented was whether the lower courts erred by ruling admissible a handwriting expert's testimony that Petitioner might have written the victim's signature on an important questioned document and that fact prevented Petitioner's elimination as a suspect in the case. The Court of Appeals granted the writ and affirmed, holding that the lower courts did not err in their conclusions that the handwriting expert's testimony was admissible as (1) because an expert opinion regarding handwriting need not be based on absolute certainty in order to be admissible, Petitioner was not unfairly prejudiced by the testimony even though the expert was unable to express the definite opinion that petitioner had forged the victim' signature on the document; and (2) Petitioner was not unfairly prejudiced by what occurred during the expert's redirect examination as the questions the expert was asked on cross-examination "opened the door" to the opinion that was elicited on redirect examination. View "Miller v. State" on Justia Law

A jury convicted Appellant Jody Miles of first-degree felony murder and related offenses, including robbery with a deadly weapon and use of a handgun in the commission of a crime of violence. Miles was sentenced to death. The Court of Appeals affirmed Appellant's convictions and sentence. Miles subsequently filed a motion to correct an illegal sentence, arguing that he was entitled to a new sentencing hearing on the ground that the jury should have been instructed that a death sentence cannot be imposed unless every juror is persuaded beyond a reasonable doubt that the aggravating circumstances outweigh the mitigating circumstances. The circuit court denied the motion. The Court of Appeals affirmed, holding that Appellant was not entitled to a new sentencing hearing as Maryland's capital sentencing procedure did not violate the Sixth Amendment. View "Miles v. State" on Justia Law

After a jury trial, Ronald Cox was convicted of multiple offenses related to a murder. The court of special appeals affirmed his convictions. The Court of Appeals granted Cox's petition for certiorari and affirmed, holding (1) the court of special appeals did not err in upholding the admission of hearsay testimony of a fellow inmate as (a) because the out-of-court statements were made voluntarily and were unprompted in casual conversation, they were not made with the primary purpose of creating an out-of-court substitute for trial testimony, and thus the statements were not testimonial and the Confrontation Clause did not bar their exclusion, and (b) the testimony was sufficiently attenuated from the taint of an earlier illegal search and arrest under the attenuation analysis set forth in Miles v. State, and (2) the evidence presented at trial was sufficient to allow a reasonable jury to find that Cox was guilty beyond a reasonable doubt. View "Cox v. State" on Justia Law

After a jury trial, William Langley was convicted of first-degree murder, use of a handgun in the commission of a crime of violence, and wearing or carrying a handgun. The court of special appeals affirmed. At issue on appeal was whether the admission into evidence of a recording of a 911 call violated Langley's confrontation rights where the call was placed after the offense had been completed and the alleged perpetrator had left the scene and where the caller indicated that she was aware that the police had been notified and were in the process of responding. Upon applying the U.S. Supreme Court's recent Michigan v. Bryant to the facts of the case, the Court of Appeals affirmed, holding that the statements in the 911 tape were non-testimonial for Confrontation Clause purposes, and thus, Langley's right to confrontation was not infringed by the admission of the statements. View "Langley v. State" on Justia Law

A landowner submitted a site development plan to the county planning board, proposing to construct a mixed-use condominium building. Joel Broida, who lived across the street from the landowner's parcel of land, filed a motion to deny approval of the site development plan. The planning board approved the plan. Broida appealed. A hearing examiner dismissed the appeal, holding that Broida lacked standing. Broida appealed. The board of appeals (Board) split evenly on the issue of Broida's standing and decided to re-vote at a later date. The landowner then filed a complaint for a declaratory judgment, declaring that the Board's split decision was final and required the appeal to be dismissed. The circuit court granted summary judgment in favor of the landowner. The court of special appeals reversed, holding that Broida had standing to appeal. The court therefore did not address whether there was a final Board decision. The Court of Appeals reversed, holding (1) there was no final administrative decision and, therefore, the landowner failed to exhaust its administrative remedies; and (2) because there was no final administrative decision, the lower courts erred in reaching the merits of the case, and the declaratory judgment action should have been dismissed. Remanded. View "Renaissance v. Broida" on Justia Law

The decedent in this case, Dorothy Faya, lived most of her life in Catonsville in Baltimore County. After suffering a fall, Faya was taken to University Speciality Hospital (USH) in Baltimore City, where she remained for eleven months until her death. Before the opening of an estate, USH filed a claim for the amount owed it with the register of wills in Baltimore City. The personal representative denied the claim filed in Baltimore City on the ground that it was invalid because Faya did not reside in the City at the time of her death. The Orphans' Court for Baltimore County agreed with the personal representative and entered judgment for the estate. The circuit court affirmed the judgment. The court of special appeals reversed, holding that Faya's bodily presence as an inhabitant of a Baltimore City health facility at the time of her death qualified her as a resident of the City when she died. The Court of Appeals affirmed, holding that under the facts of this case, Faya could be considered a resident of Baltimore City. View "Boer v. Univ. Specialist Hosp." on Justia Law

Armardo Atkins was convicted of second degree assault in circuit court. On appeal, Atkins argued that the trial judge abused her discretion by instructing the jury that the State was not required to shoulder its burden of persuasion by the use of certain categories of demonstrative evidence. The court of appeals affirmed the convictions. The Supreme Court reversed, holding that the instruction that the State need not use certain investigative and scientific techniques violated Atkins's constitutional rights to due process and a fair trial because it resulted in a non-neutral commentary on the evidence, or lack thereof, invaded the province of the jury, and relieved the State of its burden to prove guilt beyond a reasonable doubt. Remanded for a new trial. View "Atkins v. State" on Justia Law

Petitioners, Douglas and Vanessa Wietzke, filed a four-count complaint against the Chesapeake Conference Association of Seventh-Day Adventists (the Church), alleging nuisance, trespass, and negligence in connection with the construction of a new parking lot by the Church. The Wietzkes claimed the lot was the cause of continued flooding of their home and requested damages and injunctive relief. The circuit court granted the Church's motion for judgment on the negligence claim then entered judgment in favor of the Church on the nuisance and trespass claims. The court of special appeals affirmed. The Court of Appeals granted certiorari to answer several questions, most of which related to the trial judge's denial of several of the Wietzkes' requested jury instructions. The Court affirmed in part and reversed in part, holding (1) the trial court did not err in denying Wietzke's proposed jury instructions, (2) the model jury instructions requiring a finding of unreasonable conduct in a private nuisance action were a correct exposition of the law, and (3) the trial court erred in granting the Church's motion for judgment on the Wietzkes' negligence claim as the evidence could have supported a negligence claim. View "Wietzke v. Chesapeake Conference Ass'n" on Justia Law

Roger Greenberg was indicted and tried before a jury on five counts related to the care of Evelyn Zucker, to whom Greenberg had been married. During the proceeding against Greenberg, the trial judge permitted Greenberg's former lawyer, Mark Hessel, to testify as part of the State's case-in-chief. After Greenberg was convicted, he sought reversal on the grounds that the trial court allowed Hessel to testify without conducting a preliminary inquiry regarding the surrounding facts and circumstances of Hessel's representation of Greenberg, the complete circumstances related to Greenberg's possible waiver of privilege, and the scope of the prosecution's proposed use of the evidence at trial. The Court of Appeals granted certiorari and reversed, holding that the trial court erred in determining that Greenberg waived the attorney-client privilege and that the error was not harmless. Remanded for a new trial. View "Greenberg v. State" on Justia Law