Justia Maryland Supreme Court Opinion Summaries

In this case, Charles Mitchell was convicted by a jury in the Circuit Court for Baltimore City of sexually abusing his nine-year-old daughter. During voir dire, Mitchell's defense counsel requested the court to ask potential jurors if they had concerns about a child testifying and if they believed a child could lie about such a serious crime. The court only asked the first part of the question, omitting the second part. The jury found Mitchell guilty, and he was sentenced to 25 years in prison, with all but five years suspended.The Appellate Court of Maryland affirmed the conviction, holding that Mitchell had preserved his claims of error related to voir dire. The court noted that trial courts have broad discretion in voir dire but must ask questions reasonably likely to reveal specific cause for disqualification. The Appellate Court, bound by the precedent set in Stewart v. State, ruled that questions about the credibility of child-witnesses did not support disqualification for cause and thus found no abuse of discretion in the trial court's refusal to ask the second part of the proposed question.The Supreme Court of Maryland reviewed the case and abrogated part of its decision in Stewart v. State, recognizing that significant changes in the law had occurred. The court held that bias regarding a child witness could be a specific cause for disqualification of a juror when the child's testimony is crucial to the trial. The court ruled that the trial court abused its discretion by not rephrasing the defense's question to properly inquire about potential juror bias against child-witnesses. The Supreme Court of Maryland reversed the Appellate Court's decision and remanded the case for a new trial. View "Mitchell v. State" on Justia Law

In this case, law enforcement conducted a 55-minute interview with Tony Blake, who was terminally ill, regarding a drug trafficking operation. Blake made several statements implicating both himself and the defendant, Lamont Smith. The State sought to admit the entire interview as a declaration against penal interest, arguing that the statements were so interwoven that they could not be separated. Defense counsel objected, arguing that not all statements were self-inculpatory to Blake and that the statements were severable.The Circuit Court for Wicomico County admitted the entire interview without parsing each statement to determine its admissibility. The court treated the interview as a single statement and ruled it admissible as a declaration against penal interest. At trial, the interview was played for the jury, and Smith was found guilty on multiple charges related to possession and conspiracy to distribute controlled dangerous substances.On appeal, the Appellate Court of Maryland held that the trial court erred by admitting the entire interview without conducting the required parsing analysis to determine the admissibility of each statement. The court vacated Smith’s convictions, finding that the trial court failed to follow the process established in State v. Matusky, which requires a statement-by-statement analysis to determine if each statement is genuinely self-inculpatory.The Supreme Court of Maryland affirmed the Appellate Court’s decision, holding that the trial court must break down the narrative and determine the separate admissibility of each statement. The court emphasized that the test for admissibility is whether a reasonable person in the declarant’s circumstances would have believed the statement was adverse to their penal interest at the time it was made. The court concluded that Smith adequately preserved his objection to the trial court’s failure to undertake the required parsing process. View "State v. Smith" on Justia Law

The case involves Christopher Mooney, who was convicted of second-degree assault, reckless endangerment, and various firearm-related offenses following the nonfatal shooting of Joshua Zimmerman in Baltimore City. Zimmerman testified that he was shot in the back while sitting in his vehicle. A video recorded by a nearby camera, which depicted the events surrounding the shooting, was admitted into evidence over Mooney's objection.In the Circuit Court for Baltimore City, the jury found Mooney guilty based on the video evidence and Zimmerman’s testimony. Mooney appealed, arguing that the video was not properly authenticated because Zimmerman did not witness the entire event depicted in the video. The Appellate Court of Maryland affirmed the convictions, holding that the video was properly authenticated through a combination of Zimmerman’s testimony and circumstantial evidence.The Supreme Court of Maryland reviewed the case to determine whether the video was properly authenticated. The Court held that the "reasonable juror" test applies to the authentication of videos, meaning there must be sufficient evidence for a reasonable juror to find by a preponderance of the evidence that the video is what it is claimed to be. The Court concluded that videos can be authenticated through circumstantial evidence under Maryland Rule 5-901(b)(4).The Court found that the video was properly authenticated through Zimmerman’s testimony and circumstantial evidence. Zimmerman testified that the video accurately depicted the events he witnessed, and Detective Liu testified about the video’s origin. The Court held that the combination of this testimony and the circumstantial evidence was sufficient for a reasonable juror to find that the video was a fair and accurate depiction of the shooting and the surrounding events. The Supreme Court of Maryland affirmed the judgment of the Appellate Court. View "Mooney v. State" on Justia Law

Pauline Bennett, the settlor of a revocable living trust, engaged attorney Thomas Gentile to draft her estate planning documents. Initially, the trust instrument provided for the distribution of her properties, including a specific property, Wissahican, to her daughter Audrey upon her death. Later, due to concerns about Audrey's financial mismanagement, Pauline amended the trust to remove Audrey as a beneficiary and intended to sell Wissahican to fund her care. After Pauline's death, a dispute arose between her daughters, Madelyn and Audrey, over the ownership of Wissahican.The Circuit Court for Montgomery County ruled that the 2017 trust instrument, which provided Wissahican to Audrey, was still in effect, and thus Audrey was entitled to the property. Madelyn, as the successor trustee, then pursued claims against Gentile for legal malpractice, alleging that his negligent drafting of the 2019 trust instrument caused her to lose Wissahican. The circuit court granted summary judgment in favor of Gentile, holding that the strict privity rule barred Madelyn's claims and that she was not a third-party beneficiary of the attorney-client relationship between Pauline and Gentile.The Supreme Court of Maryland reviewed the case and affirmed the circuit court's decision. The court held that the strict privity rule, as established in Noble v. Bruce, remains good law, meaning that a third party not in privity with an attorney cannot sue for negligence absent fraud or collusion. The court also concluded that Madelyn did not qualify as a third-party beneficiary because the primary intent of Pauline's engagement with Gentile was to ensure her own financial security and to exclude Audrey, not to benefit Madelyn directly. Therefore, Madelyn's claims against Gentile were barred, and the summary judgment in favor of Gentile was affirmed. View "Bennett v. Gentile" on Justia Law

Aaron Jarvis was involved in a physical altercation with his brother-in-law, Ethan Durrett, which resulted in Jarvis stabbing Durrett. The incident occurred after a heated exchange of text messages regarding a family dispute. Jarvis claimed he acted in self-defense, fearing for his safety due to Durrett's aggressive behavior and larger physical stature. Jarvis testified that he brandished a knife to deter Durrett and that the stabbing was accidental during a struggle.The Circuit Court for Cecil County instructed the jury on perfect self-defense but declined to instruct on imperfect self-defense. Jarvis was acquitted of attempted murder charges but convicted of first-degree assault and other lesser offenses. He was sentenced to 15 years of incarceration, with all but 10 years suspended, and five years of supervised probation.The Appellate Court of Maryland held that the trial court erred in not instructing the jury on imperfect self-defense, given that it had instructed on perfect self-defense. However, the court deemed this error harmless, reasoning that an acquittal of attempted murder was more favorable than a mitigated conviction of attempted voluntary manslaughter.The Supreme Court of Maryland reviewed the case and held that the trial court did not err in declining to instruct the jury on imperfect self-defense. The court found no evidence that Jarvis subjectively believed his use of deadly force was necessary for his safety. Jarvis's testimony indicated that the stabbing was accidental, and there was no evidence to support that he believed stabbing Durrett was necessary for self-defense. Consequently, the Supreme Court affirmed the judgment of the Appellate Court. View "Jarvis v. State" on Justia Law

Citizens of a town submitted a document they claimed was a petition for a referendum to reverse a zoning ordinance that reclassified certain properties. The document contained 1,051 signatures but did not mention the ordinance number or request a referendum. The town's Board of Commissioners reviewed the document and determined it did not meet the requirements of the town's charter for a valid petition for referendum. The citizens then refiled the document with a cover page referencing the ordinance and requesting a referendum, but the signature pages remained unchanged.The Circuit Court for Harford County ruled that the Commissioners' determination was invalid because they did not first verify the signatures and did not act by ordinance or resolution. The court ordered the town to verify the signatures and proceed with the referendum process if the signatures were valid.The Supreme Court of Maryland reviewed the case and held that the Commissioners correctly determined the document did not meet the charter's requirements. The court found that the charter did not require the Commissioners to verify signatures before determining the petition's validity. The court also held that the Commissioners were authorized to make their determination by a verbal motion, which was memorialized in the meeting minutes, and did not need to adopt an ordinance or resolution.The Supreme Court of Maryland vacated the Circuit Court's judgment and remanded the case for entry of a declaratory judgment consistent with its opinion, affirming that the citizens were not entitled to a writ of mandamus or permanent injunctive relief. View "Town of Bel Air v. Bodt" on Justia Law

Shelly Blackston underwent a liposuction procedure performed by Dr. Alva Roy Heron, Jr. in Virginia. During the procedure, she experienced severe pain, which Dr. Heron attempted to alleviate with additional anesthesia. After returning to her home in Maryland, Blackston continued to suffer pain and developed an infection, leading to hospitalization and multiple surgeries. She filed a lawsuit in the Circuit Court for Prince George’s County, Maryland, alleging medical malpractice and failure to obtain informed consent.The Circuit Court for Prince George’s County held a five-day trial, after which the jury found in favor of Blackston on both claims. The jury awarded her $2,300,900 in damages, including $2,000,000 in non-economic damages. Petitioners filed post-trial motions, including a motion for statutory remittitur, arguing that Maryland’s cap on non-economic damages should apply. The circuit court granted the motion in part, reducing the non-economic damages to $755,000, consistent with Maryland’s statutory cap.The Appellate Court of Maryland reversed the circuit court’s decision, holding that Virginia’s damages cap applied because the injury occurred in Virginia where the procedure took place. The court reasoned that the infection, which constituted the injury, was introduced during the surgery in Virginia.The Supreme Court of Maryland affirmed the Appellate Court’s decision, holding that Virginia substantive law applied under the doctrine of lex loci delicti, which requires the application of the law of the state where the last element of the tort occurs. The court found sufficient evidence that Blackston suffered a cognizable injury during the surgery in Virginia, making Virginia’s damages cap applicable. Thus, the judgment of the Appellate Court of Maryland was affirmed. View "Doctor's Weight Loss Centers, Inc. v. Blackston" on Justia Law

Darryl Edward Freeman was charged with multiple counts related to the killing of Bradley Brown, including first-degree murder, armed robbery, and conspiracy. During the trial in the Circuit Court for Charles County, Detective Corey Wimberly testified about the meaning of the slang terms "lick" and "sweet licks," which he defined as "a robbery" and "an easy target for robbery," respectively. Freeman objected, arguing that Wimberly was not qualified as an expert to provide such definitions. The court overruled the objection and allowed the testimony.Freeman was convicted on all counts, with some counts later merged for sentencing purposes. He appealed to the Appellate Court of Maryland, which affirmed the convictions. The Appellate Court held that Wimberly's testimony was expert in nature but concluded that the circuit court had "implicitly" accepted him as an expert by overruling Freeman's objection.The Supreme Court of Maryland reviewed the case to determine whether the circuit court properly allowed Wimberly to testify about the slang terms as either an expert or a lay witness. The court held that Wimberly's testimony was permissible as lay opinion under Maryland Rule 5-701, as defining the slang term "lick" was within the understanding of a layperson and did not require specialized knowledge. The court concluded that the circuit court did not abuse its discretion in allowing the testimony and affirmed the judgment of the Appellate Court of Maryland. View "Freeman v. State" on Justia Law

A commercial tenant and landlord entered into a contract for the construction and lease of a warehouse, with the landlord also acting as the general contractor. The contract included a waiver of subrogation, where both parties waived subrogation against each other for certain losses, including those caused by their subcontractors. After the warehouse sustained weather damage, the tenant’s insurer sought to recoup insurance payments by suing the subcontractors.The Circuit Court for Baltimore City granted summary judgment in favor of the subcontractors, concluding that they were intended beneficiaries of the waiver of subrogation in the contract between the tenant and landlord. The court did not consider any extrinsic evidence regarding the parties' intent. The Appellate Court of Maryland reversed this decision, finding that the waiver of subrogation in the contract did not unambiguously benefit the subcontractors and that the subcontractors were not intended third-party beneficiaries.The Supreme Court of Maryland reviewed the case and held that the waiver of subrogation in the contract between the tenant and landlord did not extend to the subcontractors. The court found that the language of the waiver was unambiguous and did not show an intent to benefit the subcontractors. However, the court found that the waiver of subrogation included in the subcontracts was ambiguous regarding whether it applied to the tenant’s insurer’s claims against the subcontractors. Therefore, the court held that extrinsic evidence was needed to determine the parties' intent regarding the scope of the subrogation waiver in the subcontracts.The Supreme Court of Maryland affirmed the Appellate Court's decision, reversing the Circuit Court's summary judgment in favor of the subcontractors, and remanded the case for further proceedings to consider extrinsic evidence. View "Lithko Contracting v. XL Insurance America, Inc." on Justia Law

Citizens of a town submitted a document to the town's Board of Commissioners, seeking a referendum on a zoning ordinance that reclassified certain properties. The document contained 1,051 signatures and requested the reversal of the zoning changes. However, it did not reference the specific ordinance or request a referendum vote. The Commissioners determined that the document did not meet the requirements of the town's charter for a valid petition for referendum.The Circuit Court for Harford County reviewed the case and ruled that the Commissioners' determination was invalid. The court found that the Commissioners should have submitted the document to the Board of Election Judges for verification of signatures before making any determination on its validity. The court also ruled that the Commissioners' action by verbal motion was insufficient and that they should have acted by ordinance or resolution.The Supreme Court of Maryland reviewed the case and held that the Commissioners correctly determined that the document did not meet the charter's requirements for a valid petition for referendum. The court found that the charter did not require the Commissioners to submit the document to the Board of Election Judges for signature verification before making a threshold determination of its validity. The court also held that the Commissioners were authorized to make their determination by verbal motion, as memorialized in the meeting minutes.The Supreme Court of Maryland vacated the Circuit Court's judgment and remanded the case for entry of a declaratory judgment consistent with its opinion. The court concluded that the citizens were not entitled to a writ of mandamus or permanent injunctive relief. View "Town of Bel Air v. Bodt" on Justia Law