Justia Maryland Supreme Court Opinion Summaries

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

While making a delivery during the course of his employment, Appellant George Pool walked through a stream of running water that flowed across a parking lot. As a result, Appellant slipped and fell on black ice and suffered injuries. Appellant sued Defendants, the construction company that allegedly pumped the water into the parking lot and the owner of the parking lot, alleging negligence. Several additional defendants were subsequently added. The trial judge granted summary judgment in favor of the original defendants and the two defendants named in Appellant's amended complaint on the ground that Appellant had assumed the risk of his injury. Appellant appealed. The Court of Appeals (1) reversed summary judgment entered in favor of the original defendants because Appellant did not assume the risk of his injury as a matter of law; (2) affirmed the grant of summary judgment in favor of one later-named defendant and the dismissal in favor of the other later-named defendant; and (3) disavowed the reasoning related to assumption of the risk in Allen v. Marriott Worldwide Corp. View "Poole v. Coakley & Williams Constr., Inc." on Justia Law

Employee received two knee injuries while working as a firefighter for Employer. Employee filed claims with the Worker's Compensation Commission, requesting disability compensation for the loss of income stemming from each injury. The Commission ordered that Employee should receive temporary partial disability compensation for the period in which he worked light duty after both injuries. Employer sought judicial review. At issue before the circuit court was whether a loss of Employee's ability to work overtime, and its associated loss in overtime compensation, qualified as a lessening of Employee's wage earning capacity for the purposes of Md. Code Ann. Lab. & Empl. 9-615(a). The circuit court affirmed the Commission's order, ruling that the term "wage earning capacity" could fairly include overtime compensation. The Court of Appeals affirmed, holding (1) the term "wage," as used in the phrase "wage earning capacity" in section 9-615(a), includes compensation paid for overtime hours worked prior to temporary partial disability; and (2) the Commission correctly determined that Employee's wage earning capacity was "less," under section 9-615(a), entitling him to compensation payment in accordance with the calculation scheme set forth in that section. View "Montgomery County v. Deibler" on Justia Law