Justia Maryland Supreme Court Opinion Summaries

A farm in Talbot County, Maryland, was the subject of nuisance complaints from neighboring residents due to offensive odors and swarms of insects. The farm, owned by Arthur L. Foster, Sr., and later managed by his son, Arthur L. Foster, Jr., began receiving Class A biosolids and soil conditioners from Denali Water Solutions in January 2021. These materials were stored and applied to the farm, causing strong, foul odors and a midge infestation, which led to numerous complaints from nearby residents.The Talbot County Agricultural Resolution Board (the Board) conducted an investigation and held hearings to determine whether the practices at the farm were generally accepted agricultural practices under Talbot County's Right to Farm (RTF) law, Chapter 128 of the Talbot County Code (TCC). The Board found that the application and stockpiling of the materials were generally accepted agricultural practices and issued recommendations to mitigate the odor.The Circuit Court for Talbot County reversed the Board's decision, finding that the agricultural operations on the farm had not been in existence for one year or more when the complaints were filed, as required by Maryland's RTF law, Md. Code Ann., Cts. & Jud. Proc. § 5-403. The court remanded the case to the Board with instructions to find that the operations did not benefit from protection under the RTF laws.The Appellate Court of Maryland reversed the Circuit Court's decision, holding that the expanded use of soil conditioners and biosolids at the farm was a protected activity under both the state and county RTF laws. The court found substantial evidence supporting the Board's decision that the practices were generally accepted agricultural practices and did not violate public health, safety, and welfare.The Supreme Court of Maryland reversed the Appellate Court's decision, holding that the Board's findings were not supported by substantial evidence. The court found that the Board failed to make necessary findings regarding the public health, safety, and welfare impacts of the practices and did not adequately consider whether the stockpiling of materials for use at other locations was a generally accepted agricultural practice. The case was remanded for further proceedings consistent with the Supreme Court's opinion. View "In re: Foster Farm" on Justia Law

Jamal Antoine Williams was charged with promoting a criminal organization after standing watch while a gang leader spray-painted a gang-related message on public property and posing for pictures in front of the graffiti. The criminal organization in question was the Rollin 30s Crips, a set of the transnational gang known as the Crips. Williams admitted to previous membership in the Crips and was identified as a participant in the graffiti incident through video surveillance and social media posts.In the Circuit Court for Montgomery County, Williams waived a jury trial and pled not guilty with an agreed statement of facts. The court found him guilty of promoting a criminal organization under CR § 9-805 and sentenced him to five years’ incarceration, with all but six months suspended, followed by supervised probation. Williams appealed, and the Appellate Court of Maryland affirmed his conviction, interpreting "promote" broadly to include his actions.The Supreme Court of Maryland reviewed the case and held that CR § 9-805 is a general intent crime, requiring the State to prove that the defendant knew the organization was a "criminal organization" as defined by the statute. The court further held that the statute applies only to individuals who exercise a leadership role in the criminal organization or, if not members, exercise discretionary authority in connection with the act of promotion. The court found that the evidence was insufficient to prove that Williams had a leadership role or exercised discretionary authority in the gang. Consequently, the Supreme Court of Maryland reversed the conviction and directed the lower court to enter a judgment of acquittal. View "Williams v. State" on Justia Law

A former Baltimore police officer, Christopher Nguyen, was charged with reckless endangerment for failing to prevent an assault on Wayne Brown by Kenneth Somers. Nguyen arrived at the scene to find Brown injured and Somers admitting to the assault. While Nguyen was investigating, Somers kicked Brown in the head. Nguyen was charged for not preventing this spontaneous assault.In the Circuit Court for Baltimore City, Nguyen was convicted of reckless endangerment after a bench trial. The court found that Nguyen had a duty to protect Brown and that his failure to prevent the assault was a gross departure from the standard of conduct expected of a reasonable officer. The Appellate Court of Maryland affirmed the conviction, holding that Nguyen had a duty to protect Brown as a member of the public and that his conduct constituted reckless endangerment.The Supreme Court of Maryland reviewed the case. The court held that the State failed to prove that Nguyen had a legal duty to protect Brown from an unforeseeable assault by Somers. The court noted that the common law duties of police officers do not extend to protecting individuals from spontaneous and unforeseeable assaults by third parties. Additionally, the court found that the State did not establish a special relationship between Nguyen and Brown that would create a duty to protect. Consequently, the Supreme Court of Maryland reversed the judgment of the Appellate Court, finding that the State did not meet its burden of proving a legal duty under the circumstances. View "Nguyen v. State" on Justia Law

Henry Walters bequeathed the Walters Art Gallery, adjacent property, and all their contents to the Mayor and City Council of Baltimore in 1931. The City established a board of trustees to manage the assets, and in 1933, the General Assembly incorporated the Trustees of the Walters Art Gallery as an educational corporation with full control over the property. The Board has since operated the Walters Art Gallery, now known as the Walters Art Museum, for public benefit.The Circuit Court for Baltimore City ruled in favor of the plaintiffs, Walters Workers United and AFSCME, who sought to compel the Board to produce records under the Maryland Public Information Act (MPIA). The court concluded that the Board was a governmental instrumentality subject to the MPIA. The Appellate Court of Maryland affirmed this decision, emphasizing the Board's public purpose, City ownership of the property, and financial support from the City.The Supreme Court of Maryland reviewed the case and reversed the lower courts' decisions. The Court held that the Board is not a governmental unit or instrumentality under the MPIA. The Court emphasized the Board's operational independence, its fiduciary role in carrying out a private donor's charitable intent, and the lack of substantial City control over its operations. The Court concluded that the Board's relationship with the City does not make it a governmental instrumentality subject to the MPIA. The case was remanded to the Appellate Court of Maryland with instructions to remand to the Circuit Court for further proceedings consistent with this opinion. View "Walters Art Gallery v. Walters Workers United" on Justia Law

Everett Robinson was transferred to Canton Harbor Healthcare Center, a skilled nursing facility, for follow-up care after a stroke. During his stay, he developed pressure ulcers, which allegedly worsened after his transfer to other facilities, leading to his death. Felicia Robinson, his widow, and his surviving children filed a complaint against Canton Harbor, alleging negligence in allowing the pressure ulcers to develop and worsen, causing his wrongful death. They submitted a certificate of a qualified expert, signed by registered nurse Anjanette Jones-Singh, attesting that Canton Harbor breached the standard of care, causing the pressure ulcers.The Circuit Court for Baltimore City dismissed the complaint, ruling that as a registered nurse, Jones-Singh was not qualified to attest to the proximate cause of Robinson's pressure ulcers. The Robinsons appealed, and the Appellate Court of Maryland vacated the dismissal, holding that a registered nurse is not disqualified per se from attesting that a breach of nursing standards proximately caused pressure ulcers. The case was remanded for further proceedings.The Supreme Court of Maryland affirmed the Appellate Court's judgment. The court held that a registered nurse may attest in a certificate that a breach of nursing care standards at a skilled nursing facility proximately caused a pressure ulcer, provided the nurse relies on a pre-existing diagnosis and does not make a medical diagnosis. The court also held that a registered nurse meets the peer-to-peer requirement to attest to breaches of nursing care standards but not to the standards applicable to physicians. The case was allowed to proceed based on the certificate provided by Nurse Jones-Singh. View "Canton Harbor Healthcare v. Robinson" on Justia Law

In 2020, the Maryland General Assembly passed the Housing Opportunities Made Equal (HOME) Act, which added "source of income" to the list of prohibited considerations in housing rental or sale. The appellant, a housing voucher recipient, applied to rent an apartment in the appellee's complex. The appellee applied a minimum-income requirement, combining all sources of income to determine if the total exceeded 2.5 times the full gross rent. The appellant's combined income, including her voucher, did not meet this threshold, leading to the rejection of her application. The appellant sued, claiming the minimum-income requirement constituted source-of-income discrimination under § 20-705.The Circuit Court for Baltimore County granted summary judgment to the appellee, finding that the appellee's policy did not discriminate based on the source of income but rather on the amount of income. The court ruled that the appellee neutrally applied its income qualification criteria and rejected the appellant based on the amount of her income, not its source.The Supreme Court of Maryland reviewed the case and held that the appellee's counting of voucher income in the same manner as other income sources did not entitle it to summary judgment. The court found that this approach did not resolve the appellant's disparate impact claim, which asserts that a facially neutral policy has a disparate impact on a protected group without a legitimate, nondiscriminatory reason. The court vacated the judgment of the circuit court and remanded the case for further proceedings consistent with its opinion, emphasizing the need to address the disparate impact analysis. View "Hare v. David S. Brown Enterprises" on Justia Law

In early 2019, G.K. and K.K. purchased a homeowners insurance policy from Travelers Home and Marine Insurance Company for their residence. The policy included an anti-assignment clause prohibiting assignment without the insurer's consent. In May 2020, after the policy expired, the Policyholders reported roof damage from a 2019 storm and hired Featherfall Restoration, LLC to repair it. Travelers denied the claim, citing wear and tear. The Policyholders then assigned their claim to Featherfall, which Travelers refused to recognize due to the anti-assignment clause.Featherfall filed a complaint with the Maryland Insurance Administration (MIA), asserting its right to act in place of the Policyholders. The MIA upheld Travelers' denial, stating the anti-assignment clause invalidated the assignment. Featherfall requested a hearing, arguing the clause should not apply to post-loss assignments. The MIA Commissioner granted summary decision in favor of Travelers, finding the assignment invalid and Featherfall not entitled to a hearing.Featherfall sought judicial review in the Circuit Court for Baltimore City, which affirmed the MIA's decision and denied declaratory relief. The Appellate Court of Maryland also affirmed, holding that anti-assignment clauses apply to post-loss assignments and that Featherfall lacked standing.The Supreme Court of Maryland reviewed the case and held that the anti-assignment clause did not prohibit the assignment of a post-loss claim. The court distinguished between the policy itself and a claim arising under it, noting that a claim is a chose in action and thus assignable. The court reversed the lower courts' decisions and remanded the case to the MIA for further proceedings consistent with this opinion. View "In re Petition of Featherfall Restoration" on Justia Law

The case involves Travis Rashad Shepperson, who was convicted in 2009 of first- and second-degree sexual offenses, use of a handgun in the commission of a crime of violence, robbery with a dangerous weapon, robbery, and theft. A key piece of evidence at trial was a DNA result showing the presence of the victim’s DNA on the barrel of a gun found in Shepperson’s possession. Sixteen years later, DNA testing on a different portion of the same gun barrel sample detected no DNA, leading Shepperson to file a motion for a new trial based on these new test results.The Circuit Court for Prince George’s County denied Shepperson’s motion for a new trial. The court found that the new DNA test results did not contradict the earlier DNA profile introduced at trial and did not undermine the State’s theory of the case. Additionally, the new result pertained to an act for which Shepperson was acquitted and bore no connection to the sex offenses for which he was convicted. Therefore, the court concluded that the new DNA result did not create a substantial possibility of a different verdict and did not warrant a new trial in the interest of justice.The Supreme Court of Maryland reviewed the case and affirmed the lower court’s decision. The court held that the postconviction court did not abuse its discretion in denying Shepperson’s motion for a new trial. The new DNA evidence was not considered favorable as it did not refute the State’s theory or materially undermine the evidence presented at trial. Furthermore, the absence of detectable DNA on a previously untested portion of the gun barrel swab did not materially undermine the evidence presented at trial. Thus, the new DNA result neither contradicted the State’s theory of the case nor created a substantial possibility that the jury would have reached a different verdict. View "Shepperson v. State" on Justia Law

In this case, the husband filed for an absolute divorce, and the wife counterclaimed. The parties attempted mediation but did not reach a settlement. The wife’s counsel later sent a settlement package to the husband’s counsel, which included a Voluntary Separation and Property Settlement Agreement, a promissory note, and a guaranty. The cover letter specified that the husband needed to sign the agreement and note by the end of the day on September 25, 2020. The husband signed the documents on September 28, 2020, and filed an amended complaint for divorce based on mutual consent, incorporating the agreement.The Circuit Court for Anne Arundel County found that the husband had timely accepted the wife’s offer and that a binding settlement agreement was formed. The court granted the husband’s motion to enforce the settlement agreement and entered a judgment for absolute divorce based on mutual consent, incorporating but not merging the agreement into the judgment. The wife appealed, and the Appellate Court of Maryland reversed the circuit court’s judgment, finding that the husband had not timely accepted the wife’s offer and that no contract was formed.The Supreme Court of Maryland reviewed the case and affirmed the Appellate Court’s judgment. The court held that the wife’s offer was conditioned on the husband signing the agreement and note by September 25, 2020, and that the husband’s failure to meet this deadline meant that no contract was formed. The court also found no evidence that the wife had waived the deadline. The court concluded that the husband’s signing of the documents on September 28, 2020, constituted a counteroffer, which the wife was not obligated to accept. View "Pattison v. Pattison" on Justia Law

Sergey Danshin was charged with the murder of Javier Gonzalez-Mena, which occurred outside a hotel room in Montgomery County, Maryland. Danshin claimed he acted in defense of Christina Jones, who he believed was in imminent danger from Gonzalez-Mena. Danshin's recorded statement to the police, introduced by the State at trial, indicated that he shot Gonzalez-Mena because he believed Jones was in immediate danger of death or serious bodily harm, and that his actions were necessary to protect her.The Circuit Court for Montgomery County denied Danshin's request to instruct the jury on the defense of others, concluding there was no evidence of an imminent threat to Jones. The jury convicted Danshin of first-degree premeditated murder, use of a firearm in the commission of a felony, and illegal possession of a firearm. Danshin's motion for a new trial was denied.The Appellate Court of Maryland affirmed the conviction, holding that there was not "some evidence" to support the defense of others instruction because Danshin denied shooting Gonzalez-Mena. The court relied on the precedent that inconsistent defenses, such as denying the act while claiming justification, do not warrant such an instruction.The Supreme Court of Maryland reviewed the case and held that there was some evidence to support the defense of others instruction. The court noted that Danshin's statements to the police provided sufficient evidence that he believed Jones was in imminent danger and that his actions were necessary to protect her. The court reversed the judgment of the Appellate Court and remanded the case for a new trial, instructing the lower court to provide the jury with the defense of others instruction. View "Danshin v. State" on Justia Law