Justia Maryland Supreme Court Opinion Summaries

After Hospital declined to renew the privileges of Physician due to repeated complaints about Physician, Physician sued for damages. Hospital claimed immunity under the Health Care Quality Improvement Act (HCQIA). The circuit court granted summary judgment to Hospital, and the court of special appeals affirmed. The Court of Appeals granted certiorari to answer whether in the context of a summary judgment proceeding, the presumption of HCQIA immunity is rebutted upon the showing of material facts in dispute regarding the physician's reporting of substandard medical care and attempts to improve the quality of the care in the hospital system. The Court affirmed, holding (1) evidence of retaliation will not prevent summary judgment on HCQIA immunity unless it can permit a rational trier of fact to conclude that (i) the defendant failed to comply with the standards for immunity set forth in 42 U.S.C. 11112(a), or (ii) the action was not a "professional review action" under 42 U.S.C. 11151(9); and (2) in this instance, Physician did not produce evidence sufficient to convince a rational trier of fact that Hospital failed to satisfy the standards for immunity set forth in HCQIA, and therefore, summary judgment was warranted. View "Freilich v. Upper Chesapeake Health Sys." on Justia Law

After Leon Coleman failed to perform eight construction contracts for detached homes, he was convicted of eight counts of theft by deception and eight counts of failure to escrow under Deposits on New Homes Subtitle (Act). The court of special appeals reversed, holding that the Act did not apply and that there was insufficient evidence of intent to support the theft convictions. The Court of Appeals affirmed, holding (1) the evidence was insufficient to conclude that Coleman intentionally deprived buyers of their property, as required under the theft statute; and (2) the plain meaning of the Act indicated that it did not apply to Coleman. View "State v. Coleman" on Justia Law

Roy Allen died in 2005. After a drawn-out legal struggle, the orphans' court approved an account of his estate in 2009. Before the personal representative (Appellee) would make the distribution under that account, she required that Allen's children sign a document releasing her from liability related to her duties as personal representative. Allen's sons (Appellants) refused to sign and return the document. The orphans' court ordered Appellants to sign, but they again refused. The court of special appeals affirmed the order of the orphans' court. The Court of Appeals affirmed, holding (1) Md. Code Ann. Est. & Trusts 9-111 entitles a personal representative to obtain a release when she requests one; and (2) an orphans' court may order heirs and legatees to sign such releases when requested. View "Allen v. Ritter" on Justia Law

Catherine and Edward Johnson created an inter vivos trust, which named Catherine a trustee. After Edward died, Catherine's stepson, James Johnson, a beneficiary of the trust, filed a petition in the circuit court requesting, inter alia, that the court assume jurisdiction over the trust and require that Catherine file an accounting. The court granted the petition and ordered that Catherine provide an accounting to James. The court of special appeals affirmed. The Court of Appeals vacated the court of special appeals, holding that the trial court's order was not appealable as a final judgment because it did not decide any issue concerning the parties' rights. Remanded with directions to dismiss the appeal. View "Johnson v. Johnson" on Justia Law

Employee filed a complaint against Employer, claiming (1) racial and sex discrimination after Employer required her to undergo an independent medical examination for a gynecological condition, and (2) retaliatory termination of her employment. A jury held for Employee on the issues of sex discrimination and retaliatory termination. Employee was awarded damages and attorney's fees. The court of special appeals reversed, holding that Employee's claims were preempted by the Labor-Management Relations Act, and even if they were not, Employee failed to adduce sufficient evidence of her claims. The Court of Appeals reversed, holding (1) the court of special appeals' erred in determining that Employee's retaliation claim was preempted where it was independent of a collective-bargaining agreement; (2) the court of special appeals erred in its analysis of the comparator evidence in the context of Employee's claim of disparate treatment; (3) Employee presented legally sufficient evidence that she was subject to retaliatory treatment. View "Taylor v. Giant of Maryland, LLC" on Justia Law

Petitioner Gary Smith was convicted at a jury trial of depraved heart second-degree murder and use of a handgun in the commission of a felony. The principle issue at trial was whether the decedent was murdered or committed suicide. Smith appealed, contending, inter alia, that the trial court erroneously excluded certain defense evidence relating to the decedent's state of mind. The Court of Special Appeals affirmed, concluding that the excluded evidence was too remote and not reliable. The Court of Appeals granted certiorari and reversed, holding that the trial court abused its discretion in admitting prosecution evidence of the decedent's 'normal' state of mind but refusing to admit equally relevant defense evidence of the decedent's 'depressed' state of mind. Remanded for a new trial. View "Smith v. State" on Justia Law

Petitioner Gerald Titus was convicted by a jury of obstructing and hindering a police officer in the performance of his duty, driving under the influence of alcohol per se, driving while impaired by alcohol, and giving a false or fictitious name to a uniformed police officer. The Court of Special Appeals affirmed Petitioner's conviction and sentence. The Court of Appeals reversed Petitioner's conviction for obstructing and hindering, holding that the evidence presented by the State at trial with regard to this offense was insufficient to prove the necessary elements beyond a reasonable doubt because there was no evidence at trial to show how Petitioner's conduct actually obstructed or hindered a law enforcement officer in performing his duties. View "Titus v. State" on Justia Law

The Board of Physicians sanctioned Petitioner, a medical doctor, upon finding that Petitioner violated several subsections of Md. Code Ann. Health Occ. 14-404 when he falsely indicated on an application for renewal of his medical license that he was not involved in a medical malpractice action. The circuit court and court of special appeals affirmed. The Court of Appeals affirmed, holding (1) the Board did not err in either its interpretation of Md. Code Regs. 10.32.02.03.C(7)(d) or its application of that regulation to the statement of Petitioner's counsel that Petitioner would be in court on a date proposed to conduct an unrelated case resolution conference; (2) the Board properly decided that Petitioner violated section 14-404(1)(3) by failing to include on his application the pendency of the malpractice action; and (3) the Board did not err in determining that the term "willful" means intentional for purposes of section 14-404, and the record contained substantial evidence that Petitioner willfully made false statements in connection with his involvement in a medical malpractice action in his application for license renewal. View "Kim v. Bd. of Physicians" on Justia Law

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