Justia Maryland Supreme Court Opinion Summaries

The Court of Appeals affirmed Defendant's conviction of second-degree murder and possession of a firearm, holding that Defendant's contentions on appeal were unavailing.After a trial, the jury found Defendant guilty of second-degree murder and possession of a regulated firearm while under the age of twenty-one and not guilty of first-degree assault and use of a firearm in the commission of a crime of violence. On appeal, Defendant argued, among other things, that the guilty verdict as to second-degree murder and the not-guilty verdicts as to first-degree assault and use of a firearm in the commission of a crime of violence were inconsistent. The Court of Appeals affirmed, holding (1) the verdicts were not legally inconsistent; (2) the circuit court did not abuse its discretion in denying Defendant's motion for a new trial based on the jury having allegedly returned inconsistent verdicts; and (3) the evidence was sufficient to support the convictions. View "Williams v. State" on Justia Law

The Court of Appeals affirmed the judgment of the court of special appeals reversing the judgment of the circuit court granting summary judgment to Pabst Brewing Company (Pabst) and dismissing this breach of contract lawsuit brought by Frederick P. Winner, Ltd. (Winner), holding that the circuit court erred in its interpretation of the Successor Manufacturers Law (SML), Md. Code Ann., Alco. Bev. (AB) 5-201.Under a contract agreed upon in 1994, Winner and its predecessor entity distributed Pabst beer brands in Maryland. In 2014, Blue Ribbon, LLC purchased 100 percent of the stock of Pabst's parent entity. In 2015, Pabst terminated its contract with Winner, claiming that the termination was allowed under the SML. Winner disagreed and brought this lawsuit. The circuit court concluded that Blue Ribbon was permitted to cause Pabst to terminate its contract with Winner. The court of special appeals reversed. The Court of Appeals affirmed, holding (1) the SML applies only where the beer manufacturer that holds a Maryland license to distribute a brand of beer is replaced by another entity as the license hold with respect to that brand; and (2) Blue Ribbon did not qualify as a successor beer manufacturer, and Pabst did not have the right to terminate its contract with Winner without cause. View "Pabst Brewing Co. v. Frederick P. Winner, Ltd." on Justia Law

The Court of Appeals affirmed the decision of the court of special appeals affirming the judgment of the circuit court convicting Defendant of driving under the influence of alcohol per se and driving while impaired by alcohol, holding that the record supported a finding that police officers complied with the twenty-minute observation period set forth in COMAR 10.35.02.08G.Prior to trial, Defendant filed a motion in limine to exclude the results of a breath test on the ground that the twenty-minute observation period set forth in the COMAR regulation had not been complied with. The circuit court denied the motion. After he was convicted, Defendant appealed, arguing that the circuit court erred in admitting the results of the breath test. The court of special appeals affirmed. The Court of Appeals affirmed, holding (1) the alleged compliance or noncompliance with the twenty-minute observation period goes to the weight to be given to breath test results, not the admissibility; and (2) the circuit court made findings on the record that the officers complied with the twenty-minute observation period set forth in the COMAR regulation. View "Dejarnette v. State" on Justia Law

The Court of Appeals affirmed the decision of the court of special appeals finding that Petitioner waived his objections to the trial court's denial of his proposed voir dire questions, holding that Petitioner failed to preserve his claims based on Kazadi v. State, 223 A.3d 554 (2020).In Kazadi, the Court of Appeals held that, upon request, a court is required to ask potential jurors voir dire questions directed at a defendant's fundamental rights related to the burden of proof, the presumption of innocence, and the right not to testify and held that this ruling applied retroactively to cases pending on appeal so long as the relevant question was preserved for appellate review. In the instant case, which was pending when Kazadi was decided and in which the trial court declined Defendant's request to ask Kazadi voir dire questions, was whether Petitioner's claim based on the trial court's failure to ask questions required by Kazadi was properly reserved for appellate review. The Court of Appeals affirmed, holding that Petitioner's claims were not preserved for appellate review under Md. Rule 4-323(c). View "Lopez-Villa v. State" on Justia Law

The Court of Appeals held that a defendant's right to a unanimous jury verdict is violated when the State presents evidence of multiple incidents at trial to prove a single charged count in the absence of an election between the incidents or a special jury instruction.The court of special appeals affirmed the circuit court's judgment convicting Defendant of first-degree burglary, first-degree assault, and other crimes. At issue on appeal was whether the circuit court abused its discretion in failing to provide a supplemental instruction after the State argued in closing arguments that "the jury could rely on either of two distinct incidents to find [Defendant] guilty of the crimes that were charged as single counts." The court of special appeals determined that Defendant's encounters with the victim were part of a single continuous incident, and therefore, that a special unanimity instruction or election between incidents was not required. The Court of Appeals reversed, holding that Defendant's convictions did not meet this Court's constitutional standards for unanimity and must be vacated. View "Johnson v. State" on Justia Law

The Court of Appeals held that only the amount that a workers' compensation insurer actually pays for medical expenses is part of the statutory offset against underinsured motorist benefits.Michael Gilliam was injured in an automobile accident during the course of his employment and received payments from his employer's workers' compensation insurer and the other driver's liability insurer. Gilliam later sought to recover the amounts by which the other driver was underinsured from an insurance policy covering the vehicle he was driving. As required by Maryland law, the healthcare providers who treated Gilliam had generated bills in amounts greater than the amounts set by the Workers' Compensation Commission but accepted payments at those lower amounts in full satisfaction for their services. At issue was whether the difference between the bills' amounts and the workers' compensation insurer's payments constituted a "benefit" that Gilliam had "recovered" under the Workers' Compensation Act that was to be offset against any recovery Gilliam would obtain from the underinsured motorist coverage of the auto policy. The Supreme Court held that a difference between a higher face amount billed by a healthcare provider and the amount actually paid by the workers' compensation insurer was not part of that offset. View "Westfield Insurance Co. v. Gilliam" on Justia Law

The Court of Appeals affirmed the judgment of the court of special appeals affirming the judgment of the juvenile court ordering S.F. to attend school regularly without any suspensions as a condition of probation, holding that there was no error.S.F. entered an Alford plea to charges of second-degree assault and misdemeanor theft in the juvenile court. The juvenile magistrate in each case recommended probation, and an identical condition of probation for each case was for S.F. to attend school regularly without suspensions. The juvenile court denied S.F.'s exceptions and ordered the no-suspension condition of probation. The Court of Appeals affirmed, holding that the juvenile court did not abuse its discretion by ordering no school suspensions as a condition of probation. View "In re S.F." on Justia Law

The Court of Appeals affirmed the judgment of the court of special appeals affirming the judgment of the circuit court convicting Defendant of second-degree assault and misconduct in office, holding that there was no error.Specifically, the Court of Appeals held (1) where a conviction for misconduct in office is based on the corrupt doing of an unlawful act, the conviction for the "unlawful act" does not merge with the conviction for misconduct; and (2) there was sufficient evidence in the record to support Defendant's convictions for assault in the second degree and misconduct in office. View "Koushall v. State" on Justia Law

The Court of Appeals affirmed the judgment of the court of special appeals affirming Defendant's conviction for gross negligence involuntary manslaughter but reversing his conviction for depraved heart murder, holding that the evidence was insufficient to support the conviction for second-degree depraved heart murder.Specifically, the Court of Appeals held (1) the evidence was sufficient to support Defendant's conviction for involuntary manslaughter under both a gross negligence and failure to perform a legal duty theory of the offense; (2) legal duty involuntary manslaughter is not a lesser-included offense of depraved heart murder; and (3) Defendant's conduct did not constitute conduct that demonstrated an extreme indifference to the value of human life, and therefore, the evidence was not sufficient to support Defendant's conviction for second-degree depraved heart murder. View "Beckwitt v. State" on Justia Law

The Court of Appeals held that this Court's holding in Kazadi v. State, 223 A.3d 554 (2020), applies to cases in which a defendant had not yet noted an appeal when the opinion was issued in Kazadi but had preserved a Kazadi issue at trial and that the Kazadi issue in this case was preserved for appellate review.In Kazadi, the Court of Appeals held that, on request and during voir dire, a trial court must ask whether any prospective jurors are unwilling or unable to comply with the jury instructions on the fundamental principles of presumption of innocence, the defendant's right not to testify, and the State's burden of proof. The Court of Appeals in this case held that, in light of case law from the United States Supreme Court and this Court and considerations of fairness, the holding in Kazadi applies to cases in which there had not yet been a final disposition, regardless of whether a notice of appeal had been filed at the time the opinion in Kazadi was issued and in which the issue had been preserved for appellate review. View "Kumar v. State" on Justia Law