Justia Maryland Supreme Court Opinion Summaries

In this case considering whether unprovoked flight in a high-crime area should no longer be considered a factor that gives rise to rebate articulable suspicion for a Terry stop, the Court of Appeals held that, under the totality of the circumstances, Defendant's rights under either the Fourth Amendment or Article 26 of the Maryland Declaration of Rights were not violated.Defendant, who was standing in an high-crime area in Baltimore City, fled when he saw an unmarked vehicle. Ultimately, detectives stopped Defendant and found a gun in his waistband. Defendant filed a motion to suppress, arguing that the detectives lacked reasonable suspicion to stop him based solely on his unprovoked flight in a high-crime area. The Supreme Court affirmed the denial of the motion, holding that, under under the totality of the circumstances analysis, a court may consider whether unprovoked flight is an indication of criminal activity that, together with evidence of a high-crime area and any other relevant factors, establishes reasonable suspicion for a stop, or whether unprovoked flight, under the circumstances of the case, is a factor consistent with innocence that adds little or nothing to the reasonable suspicion analysis. View "Washington v. State" on Justia Law

The Court of Appeals held that when a first-party, all-risk property insurance policy covers "all risks of physical loss or damage" to insured property from any cause unless excluded, coverage is not triggered when a toxic, noxious, or hazardous substance is physically present in the indoor air of that property, adheres to and can later be dislodged from physical items on the property, and causes a loss of the functional use of the property provided that the substance causes neither tangible, concrete, and material harm to the property nor deprivation of possession of the property.Insurer issued insurance policies to Insured covering policy periods in which Insured's stores were closed in connection with the COVID-19 pandemic. Insured submitted claims to Insurer under the policies for "physical loss or damage" to its covered property exceeding $700 million. Insurer denied the bulk of the claim, leading to this lawsuit. The Court of Appeals held the presence of Coronavirus in the air and on surfaces at Insured's properties did not cause "physical loss or damage" as that phrase is used in the policies. View "Tapestry, Inc. v. Factory Mutual Insurance Co." on Justia Law

The Court of Appeals affirmed the judgment of the court of special appeals affirming the circuit court's judgment affirming the decision of the Maryland Workers' Compensation Commission granting Respondent's request for compensation for his hernia, holding that the court of special appeals did not err.In granting Respondent's request for compensation, the Commission found that Respondent sustained an accidental injury during employment, that his current hernia was the result of the accidental injury, and that, as a result of the hernia, Respondent was totally disabled for several months. The circuit court and court of special appeals affirmed. The Court of Appeals affirmed, holding that the court of special appeals did not err when it (1) held that "definite proof" under L&E 9-504(a)(1) applies to the quality of evidence presented and not the standard of proof a claimant must meet; and (2) concluded that Respondent met his burden of persuasion when producing medical evidence to a preponderance of the evidence standard. View "United Parcel Service v. Strothers" on Justia Law

In this case arising from a dispute over the purchase of residential real property in Charles County, the Court of Appeals affirmed the decision of the court of special appeals affirming the judgment of the circuit court granting Sellers' motion to dismiss Purchaser's lawsuit alleging that Seller violated Md. Code Ann. Real. Prop. 14-117(a)(3)(ii) by imposing an amortized water and sewer charge longer than twenty years after the initial date of the sale of the property, holding that there was no error.In moving to dismiss this lawsuit, Seller argued that section 14-117(a)(3)(ii) applies only to real property located in Prince George's County. The Court of Appeals agreed and dismissed the case. The court of special appeals affirmed, thus declining to extend the geographic application of the statute beyond Prince George's County. The Court of Appeals affirmed, holding (1) the plain text of section 14-117(a)(3)(ii) indicates that the twenty-year amortization limit on deferred water and sewage costs only applies to Prince George's County; and (2) the legislative history of the statute confirms that the amortization provision only applies to Prince George's County. View "Elsberry v. Stanley Martin Companies" on Justia Law

In this appeal centering on the existence of a valid arbitration agreement the Court of Appeals affirmed the decision of the court of appeals reversing the judgment of the circuit court, holding that the circuit court erred in compelling arbitration of the question of whether the arbitration clause in the agreements at issue was valid.The arbitration clause in this case stemmed from transactions between lead paint tort plaintiffs who received structured settlements and affiliated factoring companies that specialize in purchasing structured settlement rights. Defendants filed motions to compel arbitration and stay the case, but Plaintiffs challenged the existence of a valid agreement to arbitrate. The trial court granted the motion to compel arbitration, finding that the arbitrator was to determine the issue of arbitrability. The Court of Special Appeals reversed. The Court of Appeals affirmed, holding that the circuit court erroneously compelled arbitration and that the issue of whether a valid arbitration agreement exists is an issue for the court to determine. View "Access Funding, LLC v. Linton" on Justia Law

The Court of Appeals affirmed the judgment of the court of special appeals reversing the decision of the post-conviction court determining that Appellant's trial counsel provided ineffective assistance by failing to object to certain incomplete or missing jury instructions, holding that defense counsel's failure to object to a "CSI effect" voir dire question did not render her performance constitutionally deficient.In 2007, Appellant was convicted by a jury of murder. In 2010 and 2011, the Court of Appeals held in three cases that a CSI effect message from the bench constituted reversible error. In 2014, Appellant filed a pro se petition for post-conviction relief arguing that he received ineffective assistance of counsel based on his counsel's failure to object to the trial court's CSI effect voir dire question. In 2020, the post-conviction court granted the petition for post-conviction relief and ordered a new trial. The court of special appeals reversed. The Court of Appeals affirmed, holding that under the professional norms that existed at the time of Appellant's trial, defense counsel's failure to object to a CSI-effect voir dire question did not render her performance constitutionally deficient. View "McGhee v. State" on Justia Law

The Court of Appeals vacated the judgment of the court of special appeals concluding that Appellant had waived his right to appeal the denial of his motion to suppress, holding that Appellant did not waive his right to appeal the suppression ruling.After he had been convicted of a crime of violence Appellant was indicted on charges of possessing a regulated firearm. Appellant filed a motion to suppress the gun and the loaded magazine recovered by law enforcement officers while conducting a warrantless search of his hotel room. Thereafter, the State filed a superseding indictment under a new case number to add additional charges. Appellant subsequently renewed his motion to suppress in the new case. The trial court denied the motion, and Appellant was convicted of first-degree assault and other crimes. The court of appeals affirmed, ruling that Appellant waived his challenge to the denial o this motion to suppress. The Court of Appeals remanded the case for further consideration, holding that defense counsel did not waive Appellant's right to appellate review of the denial of his motion to suppress. View "Huggins v. State" on Justia Law

The Court of Appeals agreed with the conclusions of the circuit court and the court of appeals that the record containing the "code key" assigning each judge a code for purposes of access to information about court proceedings and filings did not fall under the exception from public access in the Maryland Rules, holding that the code key was disclosable in response to the records request in this case.An online database Case Search, which is overseen by the Administrative Office of the Courts (AOC), provides public access to information regarding court proceedings. For cases in the District Court sitting in Baltimore City, the judge is identified by an alphanumeric code called the code key. The code key does not appear anywhere that is accessible to the public. Abell Foundation requested a copy of the code key from the AOC under the Maryland Public Information Act, but the AOC did not comply, citing the the exception for certain administrative records in Maryland Rule 16-905(f)(3), as it existed at the time. The circuit court granted summary judgment for Abell on judicial review, and the court of appeals affirmed. The Supreme Court affirmed, holding that the code key was disclosable in response to Abell's public records request and was not exempt from disclosure under the Maryland Rules. View "Administrative Office of the Courts v. Abell Foundation" on Justia Law

The Court of Appeals denied Petitioners' exceptions to the special magistrate's recommendation that their challenges to the most recent districting plan adopted by the General Assembly be rejected, holding that Petitioners' evidence fell short of the proof needed to establish the unconstitutionality of a redistricting plan.Early in 2022, the General Assembly adopted a new plan for State legislative districts. After four separate petitions were filed challenging the validity of that plan, a special magistrate enlisted by the Court conducted hearing and recommended that the challenges be rejected. The Court of Appeals denied the petitions, holding that Petitioners did not rebut the presumption of validity applied the legislative redistricting. View "In re 2022 Legislative Districting" on Justia Law

The Court of Appeals held that an injured tort claimant's rights under a general liability insurance policy do not vest until the claimant has obtained a judgment against, or entered into a qualifying settlement with, an insured.CX Reinsurance Company issued commercial general liability policies to several Baltimore residential Landlords that included coverage for bodily injuries resulting from lead paint exposure at the Landlords' rental properties. CX field contract rescission actions against the Landlords, which the parties settled. Under the terms of the rescission settlements, the coverage for lead paint-related losses was substantially reduced. Claimants alleged they suffered bodily injuries from lead paint exposure while residing in the Landlords' rental properties, but the majority of claimants had not obtained final judgments against, or entered into settlements with, the Landlords before CX and the Landlords settled. The lower courts ruled that the Claimants were intended beneficiaries of the polices. The Court of Appeals reversed in part, holding (1) the Claimants who did not hold final judgments against or enter into approved settlement agreements with the Landlords were not the intended beneficiaries under the policies; and (2) the Claimants who obtained final judgments against their Landlords prior to the settlements of the applicable rescission cases may enforce the pre-settlement terms of the policies. View "CX Reinsurance Co. v. Johnson" on Justia Law