Justia Maryland Supreme Court Opinion Summaries

The decedent died intestate in 2021, leaving no close relatives. The decedent had a stepdaughter, Karen Ellis, who claimed she was equitably adopted by the decedent and sought to inherit his estate. Ellis alleged a father-daughter relationship with the decedent, who had been involved in her life since she was four years old. She claimed the decedent treated her as his daughter, referred to her children as his grandchildren, and made statements indicating she would inherit his estate.The Orphans’ Court for Montgomery County denied Ellis’s initial petition but later allowed her to refile. The court denied a motion for summary judgment by the decedent’s intestate heirs and transmitted seven issues to the Circuit Court for Montgomery County for a jury trial, including whether Ellis was equitably adopted.The Appellate Court of Maryland vacated the Orphans’ Court’s order, holding that a claimant must prove that the decedent intended to treat them as their own child and that the intent element is not necessarily an intent to adopt pursuant to the adoption statute. The court concluded that the orphans’ court should not have transmitted six of the seven issues to the circuit court, as they were factual in nature.The Supreme Court of Maryland reversed the Appellate Court’s judgment, holding that a claimant may establish the right to inherit under the doctrine of equitable adoption by demonstrating clear and convincing proof of the decedent’s intent to adopt and that the decedent acted in accord with that intent. The case was remanded to the Orphans’ Court for Montgomery County for further proceedings based on this standard. View "In re: Estate of Schappell" on Justia Law

Badlia Brothers, LLC, a check-cashing business, cashed 15 checks issued by the State of Maryland. These checks had already been paid by the State before Badlia presented them for payment. Some checks were deposited using a mobile app, creating "substitute checks," and then fraudulently or negligently presented to Badlia. Others were reported lost or stolen, leading the State to issue stop payment orders and replacement checks, which were then cashed by the original payees with Badlia. Badlia, unaware of the prior payments, presented the checks for payment, which the State refused.Badlia filed complaints in the District Court of Maryland, claiming the right to enforce the checks as a holder in due course. The court consolidated the cases, ruled that the State enjoyed qualified immunity, and dismissed the cases. The Circuit Court for Baltimore City reversed, holding that a check is a contract, and thus, the State had waived sovereign immunity. On remand, the District Court found that Badlia was a holder in due course entitled to enforce the checks. The Circuit Court affirmed, and the State petitioned for certiorari.The Supreme Court of Maryland held that the State has waived sovereign immunity for claims by a holder in due course seeking payment on an authorized State-issued check. The court affirmed the decision of the Circuit Court for Baltimore City, concluding that a check is a formal contract and that the State's waiver of sovereign immunity under § 12-201(a) of the State Government Article applies to such contracts. View "Comptroller of Md. v. Badlia Bros." on Justia Law

The case involves a seventeen-year-old named M.Z., who was adjudicated as a child in need of assistance (CINA) by the Circuit Court for Baltimore County due to behavioral issues and her mother's inability to manage her. M.Z. was placed in a therapeutic youth group home and later returned to her mother's custody. The Baltimore County Department of Social Services sought to terminate the CINA case, but M.Z.'s mother objected, citing ongoing behavioral concerns and the need for additional services.The Circuit Court for Baltimore County terminated the CINA case over the mother's objection, finding that the mother could adequately care for M.Z. and that the Department had exhausted its services. The mother appealed to the Appellate Court of Maryland, which dismissed the appeal, holding that the mother was not "aggrieved" by the termination since her custodial rights were restored.The Supreme Court of Maryland reviewed the case to determine whether a parent is entitled to appeal the termination of a CINA case over their objection. The court held that a parent is an "aggrieved party" entitled to appeal if they have not obtained the full relief sought in the juvenile court. The court emphasized that the CINA statute's purpose extends beyond parental rights to include the child's safety and well-being. The court found that the mother's interest in ensuring M.Z.'s safety and receiving necessary services was sufficient to make her an aggrieved party.The Supreme Court of Maryland reversed the judgment of the Appellate Court of Maryland and remanded the case for further proceedings to resolve the merits of the mother's appeal. View "In re M.Z." on Justia Law

In 1992, Abras Sandy Q. Morrison was convicted in the Circuit Court for Carroll County of first-degree murder, kidnapping, robbery, and related conspiracy charges. He was sentenced to life imprisonment without the possibility of parole for first-degree murder, with additional concurrent sentences for the other charges. The prosecutor had filed a notice of intent to seek a life without parole sentence more than thirty days before the trial. The court considered the facts, including Morrison's detailed confession and the pre-sentence report, before imposing the sentence.Morrison's convictions were affirmed by the Appellate Court of Maryland in 1993. He later filed two petitions for postconviction relief, which were denied by the circuit court in 1999. His application for leave to appeal was also denied. In 2023, Morrison filed a pro se petition for postconviction DNA testing under CP § 8-201, seeking to test a hair and a blood-stained towel, claiming the results could produce mitigating evidence regarding his sentence. The circuit court denied the petition without a hearing, and Morrison appealed.The Supreme Court of Maryland reviewed the case and affirmed the circuit court's decision. The court held that there was no reasonable probability that DNA testing of the hair would produce exculpatory or mitigating evidence relevant to Morrison's claim of wrongful sentencing. The court noted that Morrison's detailed confession and other evidence established his participation in the crime, and DNA testing would not negate his culpability. The court concluded that the circuit court did not err in denying the petition for DNA testing. View "Morrison v. State" on Justia Law

A woman was charged with murder and child abuse resulting in the death of her newborn after delivering the baby at home without her husband's knowledge. She claimed the baby was stillborn, while the State argued the baby died of asphyxiation at her hands. The woman had conducted internet searches about terminating her pregnancy months before the delivery and did not seek prenatal care.A jury in the Circuit Court for Howard County convicted the woman of second-degree murder and child abuse resulting in death, sentencing her to 30 years for murder and a concurrent 20 years for child abuse. The Appellate Court of Maryland affirmed the conviction, finding the evidence of internet searches and lack of prenatal care relevant to her intent and motive.The Supreme Court of Maryland reviewed the case to determine the relevance and prejudicial impact of the internet searches and lack of prenatal care. The Court held that the internet searches were irrelevant to show intent to kill or harm a newborn, as contemplating a legal abortion does not support an inference of intent to harm a person. Similarly, the Court found that the decision to forgo prenatal care was not probative of intent to harm a live child, as women forgo prenatal care for various reasons unrelated to criminal intent.The Court reversed the judgment of the Appellate Court and remanded the case to the circuit court for a new trial, emphasizing the need to carefully weigh the probative value against the potential prejudicial effects of such evidence. View "Akers v. State" on Justia Law

The decedent, Michael Gerard Schappell, died intestate in 2021, leaving no close relatives. He had a stepdaughter, Karen Ellis, who had been part of his life since she was four years old. Ellis claimed that she had a father-daughter relationship with the decedent and sought to be recognized as his heir under the doctrine of equitable adoption. She petitioned the Orphans’ Court for Montgomery County to be named the sole heir to the decedent’s estate.The Orphans’ Court denied Ellis’s initial petition but later allowed her to refile. The court then denied a motion for summary judgment filed by other potential heirs and transmitted seven issues to the Circuit Court for Montgomery County for a jury trial, including whether Ellis was equitably adopted by the decedent. The Appellate Court of Maryland vacated the Orphans’ Court’s order, holding that only the issue of equitable adoption should be transmitted to the circuit court, as it involved a mixed question of fact and law.The Supreme Court of Maryland reviewed the case and established a two-step test for equitable adoption. First, a claimant must demonstrate by clear and convincing evidence the decedent’s intent to adopt, which can be shown through an unperformed express agreement or other acts indicating intent. Second, the claimant must show that the decedent acted in accordance with this intent by treating the claimant as a natural or legally adopted child and representing this to the public.The Supreme Court reversed the judgment of the Appellate Court of Maryland and remanded the case to the Orphans’ Court for Montgomery County for further proceedings based on the new standard for equitable adoption. View "In re: Estate of Schappell" on Justia Law

The case involves two homebuyers, Wynton Sanders and Tosha Lindsey, who entered into contracts with SM Landover, LLC and SM Parkside, LLC, respectively, for the purchase of new homes. Both contracts included provisions for deferred water and sewer charges and a one-year statute of limitations for bringing any claims related to the contracts. The homebuyers later filed class action complaints alleging that the sellers failed to disclose required information about the deferred charges, as mandated by Maryland law.The Circuit Court for Prince George’s County consolidated the cases for pretrial purposes and dismissed the complaints with prejudice. The court found that the sellers did not need to register as home builders because Stanley Martin Companies, LLC, a registered home builder, was also a party to the contracts. The court also concluded that the homebuyers’ claims accrued at the time of contracting, making them time-barred under the one-year contractual limitations period.The Appellate Court of Maryland affirmed in part and reversed in part. It held that the one-year contractual limitations period was reasonable and that the homebuyers’ claims accrued at the time of settlement, not contracting. Therefore, the claims were timely. However, the court also held that the sellers did not need to register as home builders because a registered home builder was a party to the contracts.The Supreme Court of Maryland reviewed the case and held that the homebuyers’ claims accrued at the time of contracting. The court also held that the sellers were required to register as home builders under Maryland law, even though a registered home builder was a party to the contracts. Consequently, the sellers could not enforce the one-year contractual limitations period, making the homebuyers’ claims timely. The court affirmed in part and reversed in part the judgment of the Appellate Court of Maryland. View "SM Landover LLC v. Sanders" on Justia Law

The case involves three consolidated appeals concerning the constitutionality of the Child Victims Act of 2023, which retroactively eliminated the statute of limitations for child sexual abuse claims. The plaintiffs, who are alleged survivors of childhood sexual abuse, filed lawsuits against various institutions, including the Roman Catholic Archbishop of Washington, the Board of Education of Harford County, and The Key School, Inc. The defendants argued that the 2023 Act unconstitutionally abrogated their vested rights by reviving claims that were previously time-barred.In the Circuit Court for Prince George’s County, the court denied the Archbishop’s motion to dismiss, determining that the relevant statute was a statute of limitations, not a statute of repose, and thus did not create vested rights. The Circuit Court for Harford County reached a similar conclusion regarding the Board of Education of Harford County. In the United States District Court for the District of Maryland, the court certified the question of the 2023 Act’s constitutionality to the Supreme Court of Maryland without ruling on The Key School’s motion to dismiss.The Supreme Court of Maryland held that the 2017 statute, which the 2023 Act amended, was a statute of limitations rather than a statute of repose. The court reasoned that the statute of limitations is a procedural device that does not create vested rights, whereas a statute of repose creates substantive rights that cannot be retroactively abrogated. The court concluded that the 2023 Act did not retroactively abrogate vested rights and was constitutional as applied to the defendants. The court applied heightened rational basis review and found that the 2023 Act bore a real and substantial relation to addressing the problem of delayed reporting of child sexual abuse and the need for justice for survivors. The judgments of the lower courts were affirmed, and the certified question was answered in the negative. View "Archbishop of Washington v. Doe" on Justia Law

The case involves a proposed charter amendment in Baltimore City, known as the Baby Bonus Amendment, which would mandate a one-time payment of at least $1,000 to every eligible city resident upon the birth or adoption of a child. The Maryland Child Alliance, Inc. sponsored the petition for this amendment, which was certified by the Baltimore City Board of Elections for inclusion on the ballot for the November 2024 Presidential General Election.The Mayor and City Council of Baltimore, along with other city officials, filed a lawsuit in the Circuit Court for Baltimore City against the Baltimore City Board of Elections and the State Board of Elections, seeking judicial review, a writ of mandamus, declaratory judgment, and an injunction to prevent the Baby Bonus Amendment from being placed on the ballot. The circuit court granted the City’s motion for summary judgment, declaring the Baby Bonus Amendment unconstitutional as it violated Article XI-A, § 3 of the Maryland Constitution by removing meaningful discretion from the City over an area within its legislative purview and being legislative in nature rather than proper charter material.The Supreme Court of Maryland reviewed the case and affirmed the circuit court’s decision. The Court held that the Baby Bonus Amendment did not concern the form or structure of government and encroached upon the City’s police or general welfare powers, thus violating Article XI-A, § 3 of the Maryland Constitution. The Court also declined to sever the mandatory payment provision from the amendment, concluding that the dominant purpose of the amendment would not be achieved without the $1,000 payment provision, which abrogated the City’s law-making authority in violation of the Constitution of Maryland. View "Baltimore City Board of Elections v. Mayor and City Council of Baltimore" on Justia Law

Bonnie Campbell, a federal employee, and Michael Campbell, her ex-husband, entered into a divorce property settlement agreement in which Mr. Campbell waived his rights to Ms. Campbell's Thrift Savings Plan (TSP) account. Despite this agreement, Ms. Campbell did not remove Mr. Campbell as the beneficiary of her TSP account before her death. After her death, Mr. Campbell received the balance of the TSP account. The estate of Ms. Campbell (the Estate) sued Mr. Campbell for breach of contract to enforce the terms of the divorce settlement agreement.The Circuit Court for Montgomery County granted summary judgment in favor of the Estate on its breach of contract claim, awarding money damages. The court rejected Mr. Campbell's argument that the Federal Employees’ Retirement System Act of 1986 (FERSA) preempted the Estate's claim. The Appellate Court of Maryland reversed, holding that FERSA preempted the Estate's breach of contract claim.The Supreme Court of Maryland reviewed the case and held that FERSA does not preempt the Estate’s post-distribution breach of contract action. The court found that FERSA’s purposes, which include establishing a federal employee retirement plan and ensuring it is fully funded and financially sound, do not concern plan beneficiaries. The court also noted that FERSA’s provisions elevate the requirements of a qualifying state property settlement agreement over a deceased participant’s designated beneficiary, provided notice is given before payment. The court concluded that a post-distribution suit to enforce contractual obligations in a divorce property settlement agreement does not hinder any governmental interest in administrative convenience or avoiding double payment. The judgment of the Appellate Court was reversed, and the Circuit Court's judgment was affirmed. View "In re Isely" on Justia Law