Justia Maryland Supreme Court Opinion Summaries

A group of Baltimore City registered voters, led by Anthony J. Ambridge, filed a petition seeking judicial review of a proposed amendment to the Baltimore City Charter, known as "Question F," which was to appear on the 2024 general election ballot. The petitioners argued that the proposed charter amendment was not proper "charter material" and that the ballot language was not understandable. The Maryland State Board of Elections opposed the petition, arguing that the claims were barred by laches and that the judicial review mechanism used by the petitioners was inappropriate.The Circuit Court for Anne Arundel County ruled in favor of the petitioners, determining that the claims were not barred by laches and could be raised under the judicial review mechanism. The court found that Question F violated Article XI-A of the Maryland Constitution as it was not proper charter material and that the ballot language was not easily understandable by voters. The court ordered that the results of Question F should not be certified.The Supreme Court of Maryland reviewed the case and held that EL § 9-209(a) is not a proper mechanism to challenge whether a proposed charter amendment is proper charter material or whether the ballot language meets the standards for understandability. The Court also held that the petitioners' claims were barred by laches due to the unreasonable delay in filing the petition, which caused prejudice to the State Board, the City, and the electorate. The Court further concluded that the ballot language conveyed, with minimum reasonable clarity, the actual scope and effect of the measure, allowing voters to make an informed choice. The Supreme Court of Maryland reversed the circuit court's order and remanded the case for entry of judgment in favor of the appellants. View "State Bd. of Elections v. Ambridge" on Justia Law

Caruso Builder Belle Oak, LLC entered into a contract with Ronalda Sullivan on July 17, 2015, for the sale of a property in Prince George’s County, Maryland. The property was subject to deferred private water and sewer assessments, and Caruso provided a disclosure that was allegedly noncompliant with Maryland’s Real Property Article § 14-117(a)(3)(i). The parties settled on the contract on February 24, 2016. On February 22, 2019, Sullivan filed a complaint against Caruso seeking monetary penalties under § 14-117(b)(2)(i) for the noncompliant disclosure.The Circuit Court for Prince George’s County dismissed Sullivan’s complaint, ruling that her claim was barred by Maryland’s three-year statute of limitations, which began to run on the date of the contract, July 17, 2015. Sullivan appealed, and the Appellate Court of Maryland reversed the circuit court’s decision, holding that the statute of limitations began to run on the date of settlement, February 24, 2016, making Sullivan’s claim timely.The Supreme Court of Maryland reviewed the case and held that a seller’s violation of § 14-117(a)(3)(i) gives rise to a cause of action because the purchaser suffers an informational harm. The court determined that the statute of limitations began to run on the date of the contract, July 17, 2015, because Sullivan knew or should have known of the noncompliant disclosure at that time. Therefore, her claim filed on February 22, 2019, was barred by the three-year statute of limitations. The Supreme Court of Maryland reversed the Appellate Court’s decision and remanded with instructions to affirm the Circuit Court’s dismissal of Sullivan’s complaint. View "Caruso Builder Belle Oak v. Sullivan" on Justia Law

The case involves Isiah Hollins, who was convicted of second-degree assault following an altercation with Alexander Alvarenga at a McDonald's restaurant in Rockville, Maryland. On November 16, 2021, Hollins, a supervisor, and Alvarenga, an employee, engaged in a fight during which Hollins stabbed Alvarenga multiple times with a knife. Hollins was charged with attempted first-degree murder and related assault charges but argued self-defense, claiming Alvarenga was the initial aggressor due to his violent character.In the Circuit Court for Montgomery County, Hollins sought to introduce evidence of Alvarenga's propensity for violence, including prior assault convictions and past fights, to support his self-defense claim. The trial court denied Hollins's request to cross-examine Alvarenga about a recent unrelated incident and refused to give a non-pattern jury instruction regarding Alvarenga's violent character. The jury acquitted Hollins of attempted first-degree murder and first-degree assault but convicted him of second-degree assault. Hollins was sentenced to ten years in prison, with two years suspended, and five years of probation.Hollins appealed to the Appellate Court of Maryland, which affirmed his conviction. The appellate court agreed that the trial court erred in refusing the jury instruction solely because it was not a pattern instruction but concluded that the evidence did not support the instruction. Hollins then petitioned for a writ of certiorari.The Supreme Court of Maryland reviewed the case and held that the trial court abused its discretion by refusing to consider the requested jury instruction on the basis that it was not a pattern instruction. The court found that there was "some evidence" that Alvarenga had a character trait for violence, which could allow the jury to infer that he was the initial aggressor. The Supreme Court of Maryland reversed the judgment of the Appellate Court and remanded the case for a new trial. View "Hollins v. State" on Justia Law

In 2000, Adnan Syed was convicted of the murder of Hae Min Lee and sentenced to life in prison plus 30 years. In 2022, the State’s Attorney for Baltimore City moved to vacate Syed’s conviction, citing new evidence and alleged Brady violations. Young Lee, the victim’s brother, was given less than one business day’s notice of the vacatur hearing, which he attended remotely. The court granted the motion to vacate and ordered the State to either retry Syed or enter a nolle prosequi (nol pros) within 30 days. The State later entered a nol pros, effectively dismissing the charges against Syed.Young Lee appealed the vacatur order, arguing that his rights as a victim’s representative were violated due to insufficient notice and the inability to attend the hearing in person. The Appellate Court of Maryland vacated the circuit court’s order, reinstated Syed’s convictions, and remanded for a new hearing, holding that the entry of the nol pros did not moot Lee’s appeal and that Lee had the right to reasonable notice and to attend the hearing in person.The Supreme Court of Maryland affirmed the Appellate Court’s decision, holding that the entry of the nol pros did not moot Lee’s appeal. The Court concluded that a victim has the right to be heard at a vacatur hearing under CP § 11-403, which applies to hearings where the alteration of a sentence is considered. The Court also held that Lee’s rights were violated due to insufficient notice and the inability to attend the hearing in person. The case was remanded to the Circuit Court for Baltimore City for further proceedings, starting from the point immediately after the State’s Attorney filed the motion to vacate. View "Syed v. Lee" on Justia Law

The case involves a historic Black burial ground in Montgomery County, Maryland, known as Moses Cemetery. The land, which contains the remains of many individuals, including formerly enslaved persons, was sold and developed into an apartment complex and parking lot in the 1960s. The development process desecrated the burial ground, and it is likely that human remains are still interred there. The current owner of the property is the Housing Opportunities Commission of Montgomery County (HOC). The plaintiffs, including descendants of those buried in Moses Cemetery and a local church, sought to challenge HOC's plan to sell the land to a developer.The Circuit Court for Montgomery County granted the plaintiffs' request for a preliminary injunction to prevent the sale and later issued a writ of mandamus compelling HOC to file an action under Maryland's Business Regulation Article § 5-505 before selling the property. The court found that there was overwhelming evidence of the burial ground's existence and that many bodies likely remain on the property.The Appellate Court of Maryland reversed the circuit court's decision, holding that § 5-505 is an optional procedure for selling burial grounds and does not impose a mandatory duty on HOC to file an action before selling the land. The Appellate Court reasoned that the statute is designed to allow certain burial grounds to be sold free from claims but does not require this procedure to be followed in all cases.The Supreme Court of Maryland affirmed the Appellate Court's judgment in part and reversed it in part. The Court held that the common law of burial places in Maryland provides an appropriate framework for disputes regarding burial grounds and that extraordinary relief in the form of a writ of mandamus was not appropriate. The Court remanded the case to the circuit court, allowing the plaintiffs to seek leave to amend their complaint to state a claim for relief based on an alleged violation of specific rights protected under the common law of burial places. The Court also held that § 5-505 does not abrogate the common law of burial places and provides an optional procedure for selling burial grounds. View "BETHESDA AFRICAN CEMETERY COALITION, v. HOUSING OPPORTUNITIES COMMISSION OF MONTGOMERY COUNTY" on Justia Law

In 2000, Adnan Syed was convicted of the murder of Hae Min Lee and sentenced to life in prison plus 30 years. In 2022, the State’s Attorney for Baltimore City moved to vacate Syed’s conviction, citing new evidence and alleged Brady violations. Young Lee, the victim’s brother, was given less than one business day’s notice of the vacatur hearing, which he attended remotely. The court granted the motion to vacate and ordered the State to either retry Syed or enter a nolle prosequi (nol pros) within 30 days. The State later entered a nol pros, effectively dismissing the charges against Syed.Young Lee appealed the vacatur order, arguing that his rights as a victim’s representative were violated due to insufficient notice and the inability to attend the hearing in person. The Appellate Court of Maryland vacated the circuit court’s order, reinstated Syed’s convictions, and remanded for a new hearing, holding that the nol pros did not moot Lee’s appeal and that Lee had the right to reasonable notice and to attend the hearing in person.The Supreme Court of Maryland affirmed the Appellate Court’s decision, holding that the entry of the nol pros did not moot Lee’s appeal. The court ruled that a victim has the right to be heard at a vacatur hearing under CP § 11-403, which includes hearings where the alteration of a sentence is considered. The court also held that Lee’s rights were violated due to insufficient notice and the inability to attend the hearing in person. The case was remanded to the Circuit Court for Baltimore City for further proceedings, starting from the point immediately after the State’s Attorney filed the motion to vacate. View "Syed v. Lee" on Justia Law

In 2002, Steven Anthony Thomas was indicted for three hotel robberies in Charles County, Maryland. He pleaded guilty to two counts of armed robbery and one count of second-degree burglary, resulting in a total sentence of 40 years. In 2014, his sentence for the first armed robbery was reduced to 12.5 years, triggering a new five-year period for filing a motion to modify his sentence under Maryland Rule 4-345(e). Thomas filed a timely motion in 2015, which the court held in abeyance. He supplemented his motion multiple times, but the court took no action before the five-year period expired in December 2019.The Circuit Court for Charles County eventually held a hearing in 2021 and concluded it lacked authority to revise the sentence after the five-year period. The Appellate Court of Maryland reversed, relying on Schlick v. State, which held that the circuit court retained fundamental jurisdiction over a timely-filed motion even after the five-year period expired.The Supreme Court of Maryland reviewed the case and overruled Schlick v. State. The court held that under Rule 4-345(e), a circuit court does not have jurisdiction to revise a sentence more than five years after its imposition. The court emphasized that the rule's language is unambiguous and imposes a strict temporal limit. The court also clarified that deferring a motion to reduce a sentence for the full five-year period is equivalent to denying it within that period. Consequently, the Supreme Court of Maryland reversed the Appellate Court's decision, affirming that the circuit court lacked authority to modify Thomas's sentence after the five-year deadline. View "State v. Thomas" on Justia Law

A hospital and a physician entered into a settlement agreement to resolve a dispute over the suspension of the physician's clinical privileges. The agreement required the hospital to submit a report to a regulatory authority using specific language agreed upon by both parties. The hospital, however, selected codes for the report that generated additional text, which the physician claimed contradicted and was inconsistent with the agreed language. The physician sued for breach of the settlement agreement.The Circuit Court for Montgomery County granted summary judgment in favor of the hospital, ruling that the settlement agreement did not restrict the hospital's selection of codes for the report. The Appellate Court of Maryland disagreed, holding that a reasonable person would understand the hospital's obligation to report using specific language to preclude it from including contradictory and materially inconsistent language. The Appellate Court vacated the summary judgment, finding that whether the hospital breached its obligation was a question for the jury.The Supreme Court of Maryland reviewed the case and affirmed the Appellate Court's decision. The court held that the hospital's obligation to report using specific, agreed-upon language precluded it from including additional language that contradicted and was materially inconsistent with the agreed language. The court also affirmed that the physician's claim regarding the hospital's failure to provide a timely hearing was released in the settlement agreement. The case was remanded for further proceedings to determine if the hospital's actions constituted a breach of the settlement agreement. View "Adventist Healthcare v. Behram" on Justia Law

In 1999, Mark McCloy was convicted under 18 U.S.C. § 1512(c)(1) for tampering with a potential witness in an EEOC proceeding. In 2021, he applied to purchase a handgun in Maryland, stating he had no disqualifying convictions. The Maryland State Police (MSP) disapproved his application, determining his federal conviction was equivalent to a disqualifying Maryland crime under CR § 9-305.McCloy appealed the MSP's decision to the Office of Administrative Hearings (OAH). The Administrative Law Judge (ALJ) found that 18 U.S.C. § 1512(c)(1) was not equivalent to CR § 9-305 but sua sponte determined it was comparable to CR § 9-306, affirming the MSP's disapproval. McCloy sought judicial review in the Circuit Court for Queen Anne’s County, which affirmed the ALJ’s decision but on the grounds that CR § 9-305 was the appropriate equivalent Maryland crime.The Appellate Court of Maryland affirmed the circuit court’s decision, holding that the relevant Maryland law for determining equivalency is the law in effect at the time of the application, not the conviction. The court used a two-step approach to determine equivalency, comparing the elements of the statutes and considering whether a reasonable mind could conclude the statutes prohibit similar conduct.The Supreme Court of Maryland reversed the Appellate Court’s decision. It held that the relevant Maryland law for determining whether an out-of-State crime is disqualifying is the law in effect when the application is submitted. The court adopted a modified categorical approach, comparing the elements of the out-of-State crime with the Maryland crime. If the elements are broader, the MSP must have conclusive evidence of the acts forming the basis of the conviction to determine if those acts would support a conviction under a disqualifying Maryland crime. The court concluded that McCloy’s federal conviction was not equivalent to a disqualifying Maryland crime and remanded the case with instructions to reverse the MSP’s disapproval of McCloy’s firearm application. View "In the Matter of McCloy" on Justia Law

The case involves Thomas Dwayne Cook, who was convicted of first-degree assault and reckless endangerment for attacking Lieutenant Aubrey Fletcher while serving a prison sentence. Cook sought post-conviction DNA testing of a shirt he wore during the incident, claiming that the DNA results could support his self-defense claim and challenge the severity of the victim's injuries.The Circuit Court for Somerset County denied Cook's petition for DNA testing without a hearing, stating that there was overwhelming evidence of Cook's guilt and that DNA testing would not produce exculpatory or mitigating evidence. Cook appealed this decision, arguing that the court applied the wrong standard and that he should have been allowed to respond to the State's answer to his petition.The Supreme Court of Maryland reviewed the case and affirmed the lower court's decision. The court held that Cook did not demonstrate a reasonable probability that DNA testing would produce exculpatory or mitigating evidence. The court found that even if the DNA testing showed the blood on Cook's shirt was his own, it would not support his self-defense claim or negate the severity of the victim's injuries. The court also held that the Circuit Court did not err in denying the petition without waiting for Cook's response to the State's answer, as the rules do not require the court to wait for such a response before ruling.In conclusion, the Supreme Court of Maryland affirmed the Circuit Court's denial of Cook's petition for post-conviction DNA testing, finding no reasonable probability that the testing would produce exculpatory or mitigating evidence. View "Cook v. State" on Justia Law