Justia Maryland Supreme Court Opinion Summaries

In 1974, Appellant Douglas Arey was convicted of first-degree murder and use of a handgun in the commission of a felony. In 2002, Arey filed a petition for postconviction DNA testing of evidence related to his conviction. The circuit court dismissed the petition, concluding that the evidence related to Arey's conviction no longer existed. The Court of Appeals reversed the dismissal of Arey's petition, holding (1) the circuit court's ruling that the State had performed a reasonable search for biological evidence relating to Arey's conviction was premature; and (2) the circuit court erred in ruling on Arey's petition for testing only two days after the State submitted an affidavit from a key witness because the court's ruling did not give Arey a reasonable opportunity to respond to the factual allegations contained in that affidavit prior to dismissal. Remanded. View "Arey v. State" on Justia Law

Petitioner Enrique Silva was convicted by a jury of two counts of first-degree premeditated murder. At trial, the State called three witnesses who were present at the crime scene, one of whom was an admitted accomplice to the murders. The other two witnesses denied involvement in the crime. The trial court denied Petitioners' request to instruct the jury that the two witnesses denying involvement were accomplices as a matter of law and, consequently, their testimony linking Petitioner to the murders required corroboration in order to be credited. The court of appeals affirmed the convictions, holding that the trial court correctly denied Petitioners' requested jury instruction. The Court of Appeals granted certiorari and affirmed, holding that Petitioner was not entitled to the requested instruction. View "Silva v. State" on Justia Law

Respondent and Cross Petitioner (Respondent), a former church employee, filed a sixteen-count civil action against Petitioners and Cross Respondents (Petitioners), including a church and a bishop, claiming that she was the victim of sexual harassment and employment discrimination. The circuit court granted Petitioners' motion to exclude all evidence of Respondent's job performance, citing the First Amendment's ministerial exception. After dismissing certain counts on the ground that they were barred by the statute of limitations, the court granted summary judgment to Petitioners. The court of special appeals reversed in part and remanded, concluding that Respondent was entitled to a new trial on four of her claims, which the court found were timely filed under the continuing violation doctrine. The Supreme Court granted writ of certiorari and affirmed in part and vacated in part, holding (1) Respondent's claims of hostile work environment and gender discrimination were not barred by the statute of limitations or the ministerial exception; and (2) the remainder of Respondent's claims at issue would necessarily involve judicial inquiry into church governance, and such an inquiry was prohibited by the First Amendment. Remanded. View "Prince of Peace Lutheran Church v. Linklater" on Justia Law

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