Justia Maryland Supreme Court Opinion Summaries

The Court of Appeals vacated Defendant's convictions for second-degree assault and second-degree child abuse by a custodian, holding that Defendant, an Afrian American man, was prejudiced by the fact that the Sheriff's deputies who served as courtroom bailiffs during his trial wore thin blue line face masks, as required by the Sheriff.On appeal, Defendant argued that the bailiffs' display of the thin blue line flag on their face masks violated his Sixth Amendment right to a fair trial. The court of special appeals affirmed the convictions, concluding that the display of the thin blue line flag did not violate Defendant's right to a fair trial. The Court of Appeals vacated Defendant's convictions, holding that the bailiffs' display of the thin blue line flag and the pro-law enforcement message that it conveyed was inherently prejudicial to Defendant's constitutional right to a fair trial. View "Smith v. State" on Justia Law

The Court of Appeals reversed the judgment of the court of special appeals affirming the decision of the circuit court granting summary judgment in favor of Defendants in this case involving violent peer conflicts between adolescents in middle school, holding that the circuit court erred.Plaintiffs filed a five-count complaint against several school defendants and the Board of Education for Dorchester County, alleging violations of their daughter's state constitutional right to due process and other causes of action stemming from their daughter's bullying by other students. The circuit court granted summary judgment for Defendants, and the court of special appeals affirmed. The Court of Appeals reversed, holding (1) the Act does not preempt CJ § 5-518, and Plaintiffs' negligence claims against the individual school employees were not preempted by federal law; (2) the educational malpractice doctrine does not apply to Plaintiffs' negligent supervision claims; and (3) material disputes of fact precluded the entry of summary judgment. View "Gambrill v. Bd. of Education of Dorchester County" on Justia Law

The Court of Appeals held that the Forest Conservation Act of 1991 (the Act) and regulations promulgated by the Maryland Department of Natural Resources (DNR) required a right to appeal the approval of a forest conservation plan and that a county agency's approval of a forest conservation plan is a "final decision" for appeal purposes.At issue before the Court of Appeals was whether the approval of a forest conservation plan, as well as an associated waiver that authorizers a developer to remove trees that would otherwise be protected under the Act, is a final agency decision subject to independent judicial review under the Harford County Forest Conservation Program. The Court of Appeals reversed the decision of the court of special appeals with directions to remand the case for further proceedings in the circuit court, holding that the Act and regulations promulgated by DNR require a right to appeal the approval of a forest conservation plan and that a county agency's approval of a forest conservation plan is a "final decision" for appeal purposes. View "Chesapeake Bay Foundation, Inc. v. CREG Westport I, LLC" on Justia Law

The Court of Appeals affirmed the decision of the court of special appeals affirming the judgment of the circuit court denying Petitioner's motion to correct an illegal sentence, holding that Petitioner's claim did not fall within the category of claims cognizable under Maryland Rule 4-345(a).In 2002, Petitioner pled guilty to committing two murders when he was seventeen years old and was sentenced to two consecutive life sentences. Citing the Supreme Court's decision in Miller v. Alabama, 567 U.S. 460 (2012), and its progeny, Petitioner asserted that his sentence did not include a "meaningful opportunity to obtain release based on demonstrated maturity and rehabilitation" because Maryland parole laws do not provide a right to State-furnished counsel to assist an inmate during the parole process. The lower courts rejected Petitioner's arguments. The Court of Appeals affirmed, holding that Petitioner's argument that he has a right to State-furnished counsel at a future parole hearing was not cognizable as grounds for a motion to correct an illegal sentence. View "Farmer v. State" on Justia Law

The Court of Appeals affirmed the decision of the court of special appeals affirming the judgment of the circuit court denying Appellant's motion to correct an illegal sentence, holding that Appellant's sentencing proceeding complied with the constitutional protections recognized in recent decisions of the Supreme Court.In 2010, Petitioner was convicted of first-degree felony murder and other crimes for his involvement in a burglary at the age of sixteen that resulted in a murder. Petitioner was sentenced to life in prison with all but sixty years suspended for the murder conviction and will be eligible for parole at the time he is forty-two years old. In 2017, Petitioner filed a motion to correct an illegal sentence, arguing that his sentence violated the Eighth Amendment, as interpreted in recent decisions of this Court and the Supreme Court. The circuit court denied the motion, and the court of special appeals affirmed. The Supreme Court affirmed, holding that Petitioner's sentence did not amount to a de facto sentence of life without parole, and his sentence was not grossly disproportionate. View "Jedlicka v. State" on Justia Law

The Court of Appeals held that ambiguity in a sentencing court's remarks about a juvenile offender's post-offense conduct and character, when made before the Supreme Court issued its decisions governing the sentencing of a juvenile offender to life without the possibility of parole, requires that the offender receive a new sentencing hearing for purposes of the Eighth Amendment.Petitioner was seventeen years old when he committed a series of murders. In Maryland, Petitioner pled guilty to six counts of first-degree murder. The sentencing court sentenced him to the maximum sentence of six terms of life in prison without the possibility of parole. After the Supreme Court decided Miller v. Alabama, 567 U.S. 460 (2012), Petitioner filed a motion to correct an illegal sentence. The circuit court denied the motion. The Supreme Court remanded the case, holding that because opposing inferences could be drawn as to whether the sentencing judge determined that Petitioner was not "the rare juvenile offender whose crimes reflects irreparable corruption" for whom the Eighth Amendment allows a sentence of life without parole. View "Malvo v. State" on Justia Law

The Court of Appeals ruled that the Board of Appeals of Baltimore County erred in reversing an administrative law judge's determination that substantial changes existed between an original development plan and a later proposed development plan, holding that, contrary to the Board's conclusion, the doctrine of collateral estoppel did not bar approval of the later-proposed development plan.After a hearing, the Board issued an opinion concluding that the ALJ erred as a matter of law in ruling that the most recent development plan modification at issue was not barred by collateral estoppel. The circuit court reversed the Board's decision, concluding that the Board misapplied the law and misconstrued the facts in making its decision. The court of special appeals reversed. The Court of Appeals reversed, holding that the Board erred in concluding that collateral estoppel barred the approval of the most recent development plan. View "Becker v. Falls Road Community Ass'n" on Justia Law

The Court of Appeals vacated the judgment of the court of special appeals reversing the decision of the trial court granting summary judgment to Defendants in this professional malpractice action, holding that the circuit court mistakenly applied Meda v. Brown, 318 Md. 418 (1990), in excluding Plaintiff's experts.In their motion for summary judgment, Defendants argued that there was no evidence or medical circumstances sufficient to allow an expert opinion "inference" that surgical negligence occurred in the underlying matter. After finding that the testimonies of Plaintiffs' expert witnesses were not admissible the Supreme Court granted summary judgment for Defendants. The court of special appeals reversed, finding that the trial court erred as a matter of law in excluding Plaintiff's expert witnesses. The Court of Appeals remanded the case with instructions to reverse the circuit court's judgment, holding that the circuit court erred in excluding the testimony of Plaintiff's expert witnesses. View "Frankel v. Deane" on Justia Law

The Court of Appeals affirmed the judgment of the circuit court denying Petitioner's complaint seeking an injunction and declaratory relief to enjoin a student member on the Board of Education of Howard County from exercising any voting power and a declaration that the election process for the student member violates the Maryland Constitution, holding that there was no error.After relying on remote learning for schooling during the Covid-19 pandemic, at the end of 2020, the Board of Education of Howard County held votes on motions to resume in-person instruction. Each motion failed by a stalemate vote, with the student member causing the stalemate. After the Board decided to continue with remote learning Petitioners brought this action seeking an injunction and a declaration that the statute creating the student member on the Board is unconstitutional. The circuit court granted summary judgment for the Board, and the court of appeals affirmed. The Supreme Court affirmed, holding that the provisions of section 3-701 of the Education Article concerning the student member position on the Board do not violate the Maryland Constitution. View "Spiegel v. Board of Education of Howard County" on Justia Law

The Court of Appeals reversed the judgment of the court of special appeals reversing Defendant's sentence on the ground that the district court's failure to advise Defendant of the duration of his probation, as required by Maryland Rule 4-346(a), rendered the sentence illegal, holding that the violation of Rule 4-346(a) did not render the sentence illegal.In imposing Defendant's split sentence of twenty-five years, suspending five years, the court mentioned probation but failed to advise Defendant of the probation's duration. However, the court did include a five-year term and conditions of probation in a probation order signed by Defendant and his counsel before leaving the courtroom. The court of special appeals reversed and remanded to the circuit court to strike the five-year probation from the sentence. The Court of Appeals reversed, holding that the sentencing judge's error constituted clear error, but not one that rendered the sentence illegal. View "State v. Bustillo" on Justia Law