Justia Maryland Supreme Court Opinion Summaries

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

The Court of Appeals affirmed the judgment of the court of special appeals reversing the circuit court's judgment in favor of Plaintiff in this personal injury case, holding that the court of special appeals did not err or abuse its discretion.Plaintiff, who was injured while shopping at a supermarket owned and operated by Defendant, brought this suit alleging negligence and negligent hiring, training, and supervision. A jury returned a verdict in favor of Plaintiff. The intermediate appellate court reversed, concluding that the circuit court erred in denying Defendant's motion for judgment made at the close of evidence and in giving a jury instruction on spoliation. The Court of Appeals affirmed, holding that the court of appeals (1) applied the correct standard of review when reviewing the circuit court's denial of Defendant's motion for judgment; (2) did not err in reversing the circuit court's denial of Defendant's motion for judgment; and (3) did not err in holding that the circuit court's spoliation instruction was prejudicial. View "Webb v. Giant of Maryland, LLC" on Justia Law

The Court of Appeals affirmed the judgment of the court of special appeals affirming Defendant's conviction of illegal possession of a firearm, holding that there was no error.Specifically, the Court of Appeals held (1) the scope of the State's mandatory disclosure obligations pursuant to Md. Rule 4-263(c)(2) does not include jail call recordings held by a state correctional facility that has not reported to the State in a particular case; (2) under the circumstances of this case, the State exercised due diligence in disclosing the jail call recordings; and (3) even if the State violated its discovery obligations through its late disclosure, the error was harmless. View "Alarcon-Ozoria v. State" on Justia Law

The Court of Appeals reversed the judgment of the court of appeals affirming Defendant's conviction of first-degree murder, holding that this Court's holding in Kazadi v. State, 223 A.3d 554 (Md. 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.In Kazadi, the Court of Appeals held that, on request and during voir dire, a trial court must asking whether prospective jurors are unwilling or unable to comply with the jury instructions on the fundamental principles of presumption of innocence, the State's burden of proof, and the defendant's right not to testify. The Court later stated that that the holding would apply to any cases pending on direct appeal when the opinion was filed and the relevant question had been preserved for review. In the instant case, the court of special appeals affirmed Defendant's first-degree murder conviction, concluding that the circuit court did not err in declining to ask Defendant's proposed voir dire questions. The Court of Appeals reversed, holding that the circumstances were satisfied for Kazadi to apply to this case. View "Kumar v. State" on Justia Law

The Court of Appeals held that an administrative law judge (ALJ) with the Maryland Office of Administrative Hearings erred in declining Petitioner's request to be represented by counsel at an administrative hearing regarding the approval to give Petitioner forced medication, holding that the ALJ erred.Petitioner, a patient at a psychiatric institution, refused to take prescribed psychotropic medication. After a panel approved forced medication, Petitioner requested a hearing. On the day of the hearing, Petitioner asked for counsel. The ALJ treated the request for counsel as a request for a postponement, concluding that there was not good cause to postpone the hearing, and convened the hearing with Petitioner unrepresented. The Court of Appeals reversed, holding (1) under the plain language of HG 10-708 an individual possesses a right to counsel upon request; (2) an on-the-record waiver colloquy of the kind required in a criminal case is unnecessary, but there must be verification that the individual has knowingly and voluntarily waived the right to counsel and elected to proceed without representation; and (3) the ALJ erred in declining Petitioner's request to be presented by counsel at the administrative hearing. View "Mercer v. Thomas B. Finan Center" on Justia Law

The Court of Appeals affirmed the judgment of the court of special appeals reversing the judgment of the circuit court denying Respondents' motion to dismiss Petitioner's petition for judicial review of the decision of the Workers' Compensation Commission summarily denying Petitioner's second request for modification of an earlier order, holding that the circuit court erred.The Commission issued an order approving Petitioner's request for four additional weeks of physical therapy for her left shoulder that was injured due to a workplace accident. More than three years later, Petitioner filed a request for modification of the earlier order denying her request for authorization of surgery. The Commission denied the request without a hearing. Petitioner then filed a second request for modification, which the Commission denied without a hearing. The circuit court denied Petitioner's petition for judicial review. The court of special appeals reversed. The Supreme Court affirmed, holding that the Commission's summary denial of Petitioner's request for modification was not subject to judicial review. View "Sanders v. Board of Education of Harford County" on Justia Law

The Court of Appeals affirmed Petitioner's convictions of perjury and misconduct in office, holding that this Court declines to abrogate the two-witness rule for "oath-against-oath" perjury cases and that there was sufficient evidence to support the convictions.Petitioner, a veteran officer in the Baltimore Police Department, was charged with perjury and misconduct in office based on allegedly false testimony he gave at a criminal trial. The circuit court found Defendant guilty, and the court of special appeals affirmed. Petitioner filed a petition for certiorari, arguing that the lower courts' bases for affirmance were erroneous, and the State filed a cross-petition for certiorari asking the Court to abrogate the two-witness rule prospectively. The Supreme Court affirmed, holding (1) the State met its burden of production under the two-witness rule in this case; and (2) the evidence was sufficient to sustain Petitioner's convictions for perjury and misconduct in office. View "O'Sullivan v. State" on Justia Law