Justia Maryland Supreme Court Opinion Summaries

The Court of Appeals reversed the decision of the court of special appeals reversing Defendant's conviction for various crimes related to the murders of two high school seniors, holding that the court of special appeals erred in reversing the convictions.On appeal, Defendant argued that the trial court abused its discretion when it refused to allow Defendant to cross-examine one of the State's witnesses about out-of-court statements allegedly made by one of his co-defendants and by allowing a lay witness to testify that a cellphone user such as himself has the ability to turn off location tracking associated with the user's Google accounts. The court of special appeals agreed and ordered a new trial. The Court of Appeals reversed, holding (1) the trial court did not abuse its discretion by limiting the proposed cross-examination; and (2) a user's ability to adjust the location tracking feature of a smartphone is within the understanding of the average lay person, and therefore, a witness whose testimony referred to that ability was not required to qualify as an expert. View "State v. Galicia" on Justia Law

The Court of Appeals reversed the judgment of the court of special appeals reversing Defendant's conviction for murder and related charges on the grounds that the trial court erred in admitting certain expert testimony, holding that the trial court did not abuse its discretion in admitting the expert testimony.At issue was the trial court's admission of expert testimony concerning the reverse projection photogrammetry analysis performed by the Federal Bureau of Investigation and the height estimate of the suspect resulting from that analysis. In reversing Defendant's conviction, the court of special appeals concluded that the height measurement was unreliable and therefore inadmissible under Rochkind v. Stevenson, 471 Md. 1 (2020), and Maryland Rule 5-702. The Court of Appeals reversed, holding that the trial court did not abuse its broad discretion in admitting the expert testimony in question. View "State v. Matthews" on Justia Law

The Court of Appeals reversed the decision of the court of special appeals reversing the judgment of the circuit court, sitting as the juvenile court, denying D.D.'s motion to suppress evidence of a loaded gun found by law enforcement officers in D.D.'s waistband, holding that there was no constitutional violation in this case.At issue in this case was whether this Court should extend the holding in Lewis v. State, 470 Md. 1 (2020), that the odor of marijuana alone does not provide probable cause to believe that the person is in possession of a criminal amount of the drug, to an investigatory detention. In reversing the juvenile court's denial of D.D.'s suppression motion, the court of special appeals held that the investigatory detention of D.D., which was based solely on the order of marijuana, violated the Fourth Amendment. The Court of Appeals reversed, holding (1) the odor of marijauna provides reasonable suspicion of criminal activity sufficient to conduct a brief investigatory detention; and (2) the officers in the instant case had reasonable suspicion to detain D.D., and therefore, the pat-down that led to the discovery of the gun on D.D. was also reasonable. View "In re D.D." on Justia Law

The Court of Appeals affirmed the decision of the court of special appeals affirming Defendant's convictions for first-degree felony murder, first-degree burglary, and the theft of a Jeep, holding that Defendant was not entitled to relief on his allegations of error.Specifically, the Court of Appeals held (1) Defendant's felony murder conviction was not preempted by the manslaughter by motor vehicle statute; (2) Defendant's sentence of life in prison with the possibility of parole was not unconstitutional under either the Eighth Amendment or Article 25 of the Maryland Declaration of Rights; and (3) Defendant was not entitled to an individualized sentencing proceeding under Miller v. Alabama, 567 U.S. 460 (2012). View "Harris v. State" on Justia Law

The Court of Appeals affirmed the decisions of the lower courts affirming a general permit that the Maryland Department of the Environment issued for operators of thirty-five small municipal separate storm sewer systems (MS4s) in Maryland, including Petitioner Queen Anne's County, which operated a small MS4, holding that conditions based on regulations of the Environmental Protection Agency (EPA) in the general permit for small MS4s are not unlawful simply because they may exceed the minimum requirements of the Clean Water Act.In Maryland Department of the Environment v. County Commissioners of Carroll County, 140 S. Ct. 1265 (2020), the Court of Appeals held that permits issued to counties that operated MS4s were lawful even if some permit conditions exceeded the minimum requirements of the Act. In the instant case, the circuit court for Queen Anne's County concluded that the decision in Carroll County addressed the issues raised by the County and affirmed the permit. The court of special appeals affirmed. The Court of Appeals affirmed, holding (1) the holdings of Carroll County applied in this case; and (2) an impervious surface restoration requirement in the permit, which was similar to but less onerous than a permit requirement assessed in Carroll County, did not unlawfully make the County responsible for discharges by third parties. View "Small MS4 Coalition v. Department of Environment" on Justia Law

The Court of Appeals affirmed the judgment of the court of special appeals reversing the trial court's grant of summary judgment in favor of Irwin Industrial Tool Company in this wrongful death and product liability action brought by the Estate of Richard Pifer, holding that the grant of summary judgment based on the determination that there was not admissible evidence on which to challenge Irwin's request for summary judgment was erroneous.The Estate brought this action alleging that Irwin sold Strait-Line marking chalk that contained asbestos and caused Pifer's death from mesothelioma. Irwin filed a pretrial motion in limine to exclude evidence regarding an analysis of Strait-Line chalk by the Estate's expert that had results in a finding of asbestos. The circuit court granted the motion as to some of the evidence and then entered summary judgment for the Estate. The court of special appeals reversed. The Supreme Court affirmed, holding (1) the evidence at issue was properly authenticated, and therefore, the circuit court abused its discretion in granting the Estate's motion in limine; and (2) the grant of summary judgment was erroneous. View "Irwin Industrial Tool v. Pifer" on Justia Law

The Court of Appeals answered a certified question of law by holding that Md. Code Comm. Law (CL) 12-1018(b) requires a credit grantor that is found to have knowingly violated Credit Grantor Closed End Credit Provisions (CLEC), CL 12-1001 et seq., to forfeit three times the amount of interest, fees, and charged collected in violation of the subtitle.This case concerned a borrower who purchased a motor vehicle and financed it by closed end credit pursuant to an agreement governed by CLEC. The federal district court issued a certified question of law regarding the calculation of damages under CL 12-1018(b). The Court of Appeals held that, based upon prior caselaw regarding CLEC, a plain language analysis of CL 12-1018(b), and a review of the pertinent legislative history, CL 12-1018(b) requires a credit grantor who has knowingly violated the CLEC to forfeit three times the amount of interest, fees, and charges collected in violation of CL 12-1018(b). View "Lyles v. Santander Consumer USA Inc." on Justia Law

The Court of Appeals affirmed the judgment of the court of special appeals, which affirmed Defendants' convictions of possessing a firearm, holding that the State provided sufficient evidence to establish that Defendants knew they were prohibited from possessing a firearm.Defendants Mashour Howling and Funiba Abangnelah each possessed a firearm at the time of arrest despite being disqualified to do so. In separate jury trials, both Defendants unsuccessfully requested that the respective circuit courts give a jury instruction incorporating the reasoning of Rehaif v. United States, 139 S. Ct. 2191 (2019), where the United States Supreme Court held that the federal statute required proof of knowledge of possession of a firearm and proof of knowledge of the defendant's status as a person prohibited from possessing a firearm. After Defendants were convicted the court of special appeals affirmed. The Court of Appeals affirmed, holding that the the circuit court did not abuse its discretion in declining to give Defendants' requested jury instructions. View "Howling v. State" on Justia Law

The Court of Appeals held that the circuit court did not err in ordering the City of Balitmore to execute a tax sale deed conveying legal title to the property to Ty Webb, LLC, the assignee of Thorton Mellon, LLC, the tax sale purchaser.The day after the circuit court entered a judgment foreclosing the right of redemption in connection with a tax sale proceeding pending in the circuit court Thorton Mellon executed an assignment purporting to assign Ty Webb its interest in the judgment and tax sale certificate. The Director refused to execute a tax deed to Ty Webb. Thornton Mellon then substituted its interest in the action to Ty Webb, which, as substitute plaintiff, filed a motion requesting an order directing the City to issue a tax sale deed to Ty Webb. The circuit court granted the motion, and the court of special appeals affirmed. The Court of Appeals affirmed, holding that the circuit court did not err in concluding that the certificate of sale and judgment were assignable and directing the City to execute the tax deed in favor of Ty Webb. View "Mayor & City of Baltimore v. Thornton Mellon, LLC" on Justia Law

The Court of Appeals answered a certified question of law by concluding that the then-Chief Judge Mary Ellen Barbara of the Court of Appeals acted within her authority and consistently with the Maryland Constitution when she issued an administrative order temporarily tolling statutes of limitations under Maryland law with respect to civil actions during the COVID-19 pandemic.On April 24, 2020, the Chief issued an administrative order that temporarily tolled statutes in civil cases during the state of emergency created by the COVID-19 pandemic. In a commercial dispute between the parties in this case, the timeliness of certain claims and the diversity jurisdiction of the federal court depended on the validity of the Chief Justice's administrative tolling order and whether the order violated the Maryland Declaration of Rights. The Court of Appeals held that the Chief Justice acted within her authority when she issued the administrative tolling order concerning the timeliness of the complaints filed in Maryland during the pandemic. View "Murphy v. Liberty Mutual Insurance Co." on Justia Law