Justia Maryland Supreme Court Opinion Summaries

Appellants Benedict J. Frederick, III, Matthew W. Wyskiel, III, and Stacie Teal-Locust challenged the Baltimore City Board of Elections' decision to reject a proposed charter amendment petition sponsored by Renew Baltimore. The proposed amendment sought to cap Baltimore City's real property tax rate, decreasing it incrementally over seven years. The current tax rate is $2.248 per $100 of assessed value, and the amendment aimed to reduce it to $1.20 per $100 by fiscal year 2032.The Election Director for the City Board approved the petition format but did not assess its legality. Renew Baltimore submitted the petition with 23,542 signatures, exceeding the required 10,000. However, the Election Director later deemed the amendment deficient, citing a conflict with section 6-302(a) of the Tax-Property Article, which grants the Mayor and City Council the authority to set property tax rates. The Circuit Court for Baltimore City upheld this decision, ruling that the amendment was not proper charter material and violated section 6-302(a).The Supreme Court of Maryland reviewed the case and affirmed the Circuit Court's decision. The Court held that the proposed charter amendment was impermissible because it violated section 6-302(a) of the Tax-Property Article by allowing citizens to establish the tax rate, which is a power vested in the Mayor and City Council. Additionally, the Court noted that section 49 of Article II of the Baltimore City Charter prohibits voters from initiating legislation related to property taxation. Therefore, the proposed amendment could not be presented on the November 2024 general election ballot. View "Frederick v. Balt. City Bd. of Elections" on Justia Law

An investor, Snowden Investment LLC, was denied its contractual right to purchase a membership interest in two companies, Boomerang Franchise LLC and Ashburn Indoor Play LLC, both related to a children's indoor play facility business called Hyper Kidz. The right was stipulated in a Loan and Security Agreement with Maryland Indoor Play, LLC (MIP), which required MIP to notify Snowden of new ventures and offer an opportunity to invest. Snowden was not given the required notice for either Boomerang or Ashburn.The Circuit Court for Howard County granted summary judgment to Snowden on liability for breach of contract and awarded specific performance for Boomerang and compensatory damages for Ashburn. Snowden's expert valued the damages for Ashburn at $453,333 using a "fair value" approach, which the court accepted. The court also ordered specific performance for Boomerang, requiring the Founders to offer Snowden the opportunity to invest on the same terms as the original members.The Supreme Court of Maryland reviewed the case and found that the Circuit Court erred in its rulings. The court held that the proper measure of damages for the breach of the investment right should be general damages, calculated using the fair market value of the interest at the time of the breach, not "fair value" as used by Snowden's expert. The court also found that specific performance was not appropriate for Boomerang because the Circuit Court failed to consider all relevant facts and circumstances, including whether Snowden was ready, willing, and able to meet the terms of membership.The Supreme Court of Maryland reversed the judgment for specific performance regarding Boomerang and vacated the compensatory damages award for Ashburn, remanding the case for further proceedings consistent with its opinion. The court also vacated the award for attorneys' fees, costs, and interest, instructing the Circuit Court to revisit these in light of the new findings. View "Maryland Indoor Play v. Snowden Investment" on Justia Law

In this case, Erica Hall and Nicholas Houser, who married in 2012 and have one minor child, sought an absolute divorce in 2020. They presented three agreements to the Circuit Court for Anne Arundel County, including one that proposed no child support and waived arrears. The court rejected this agreement, stating it was not in the child's best interest and ordered Mr. Houser to pay child support and arrears to Ms. Hall, who was the primary custodian.The Appellate Court of Maryland affirmed the circuit court's decision, rejecting the parents' agreement regarding child support and upholding the award of child support and arrears. Both parties then petitioned the Supreme Court of Maryland for a writ of certiorari.The Supreme Court of Maryland held that parents cannot waive the issue of child support and arrears, even in a bilateral agreement, because child support is a legal obligation, and the right to receive it belongs to the child, not the parents. The court also held that a parent's fundamental right to determine the care, custody, and control of their children does not include the ability to waive child support, as it is a parental obligation, not a right. Therefore, lawfully ordered child support does not violate a parent's fundamental rights.Additionally, the court found that the trial court did not abuse its discretion in rejecting the parents' agreement to pay no child support, as the parties failed to provide sufficient justification for their request. The Supreme Court of Maryland affirmed the judgment of the Appellate Court, maintaining the child support order. View "In re Marriage of Houser" on Justia Law

Robert L. Fooks was convicted by the Circuit Court for Wicomico County for violating Section 5-133(b)(2) of the Public Safety Article, which prohibits firearm possession by individuals convicted of a common law crime and sentenced to more than two years in prison. Fooks, who had a prior conviction for constructive criminal contempt and a sentence exceeding four years, argued that this statute violated his Second Amendment rights.The Circuit Court denied Fooks's motion to dismiss the firearms-related counts, and he entered a conditional guilty plea to two counts, reserving his right to appeal the Second Amendment issue. The Appellate Court of Maryland upheld the statute's constitutionality, affirming Fooks's convictions. Fooks then sought review from the Supreme Court of Maryland.The Supreme Court of Maryland affirmed the lower court's decision, holding that Section 5-133(b)(2) is consistent with the Second Amendment. The court noted that the statute is effectively a prohibition on firearm possession by felons, which the U.S. Supreme Court has repeatedly identified as presumptively lawful. The court also found that such prohibitions are consistent with the nation's historical tradition of firearm regulation, which has long included disarming individuals deemed to present a special danger, including those who have committed serious crimes. The court concluded that the statute is constitutional both on its face and as applied to Fooks. View "Fooks v. State" on Justia Law

The case involves a dispute over a parcel of land situated at the border of adjoining properties in Owings Mills, Maryland. Dr. Sharon Saunders owns one property, while Steven and Ellen Gilman own the neighboring property. The Gilmans claimed ownership of the disputed land through adverse possession, having maintained and used the land for several decades. In 2018, the Gilmans constructed a fence on the disputed property, prompting Dr. Saunders to commission a property survey and subsequently file a lawsuit to establish the boundary line and seek damages for trespass and other tort claims.The Circuit Court for Baltimore County ruled in favor of the Gilmans, declaring them the absolute owners of the disputed property by adverse possession. The court ordered the Gilmans to prepare and file an amended deed and plat reflecting their ownership. Dr. Saunders appealed the decision, but the Appellate Court dismissed the appeal, stating that the order was not a final judgment and did not fall under any exceptions allowing for an interlocutory appeal.The Supreme Court of Maryland reviewed the case to determine whether the Appellate Court erred in its decision. The Supreme Court held that the Circuit Court's order declaring the Gilmans as owners by adverse possession and directing the preparation of a deed was immediately appealable under Maryland Code, Courts & Judicial Proceedings Article §§ 12-303(1) and 12-303(3)(v). The Supreme Court reversed the Appellate Court's dismissal and remanded the case for further proceedings to address the merits of Dr. Saunders's appeal. View "Saunders v. Gilman" on Justia Law

Stephen Zimmerman pled guilty to second-degree assault and was sentenced to ten years, with all but the time served in pretrial detention suspended, and placed on three years of supervised probation. In October 2022, Zimmerman was charged with violating his probation. The District Court of Maryland in Frederick County found him in violation, revoked his probation, and imposed a seven-year custodial sentence. Zimmerman appealed de novo to the Circuit Court for Frederick County, which also found him in violation and imposed the same seven-year sentence. Zimmerman’s motion for a new trial was denied, and he subsequently filed a pro se “Motion for Appeal.”The Appellate Court of Maryland docketed Zimmerman’s motion as an application for leave to appeal and directed the State to respond. The State moved to transfer the appeal to the Supreme Court of Maryland, arguing that the Appellate Court lacked jurisdiction. The Appellate Court granted the motion, reasoning that further appellate review of a circuit court decision issued in its appellate capacity must be pursued in the Supreme Court of Maryland.The Supreme Court of Maryland held that the Appellate Court of Maryland lacked jurisdiction to consider Zimmerman’s appeal. Under § 12-305 of the Courts and Judicial Proceedings Article, the Supreme Court has exclusive appellate jurisdiction over final judgments of a circuit court entered in the exercise of its appellate jurisdiction over District Court cases. Therefore, any further review must be sought by petition for a writ of certiorari to the Supreme Court of Maryland. The Court affirmed the Appellate Court’s decision to transfer the case and instructed Zimmerman to file a proper petition for writ of certiorari within 30 days if he sought further review. View "Zimmerman v. State" on Justia Law

Seamus Coyle was convicted of first-degree murder, conspiracy to commit first-degree murder, and use of a handgun in the commission of a crime of violence. He was sentenced to life imprisonment. Due to a conflict of interest, the Office of the Public Defender (OPD) assigned a panel attorney to represent Coyle in his direct appeal to the Appellate Court of Maryland, which affirmed his convictions. The panel attorney discussed filing a petition for a writ of certiorari with Coyle and the OPD and was authorized to file the petition but failed to do so. Coyle then petitioned for postconviction relief, alleging ineffective assistance of counsel.The Circuit Court for Baltimore County denied Coyle’s petition for postconviction relief, finding that the issues raised on appeal were neither novel nor important from a public policy standpoint and that there was no possibility that the Supreme Court of Maryland would have granted certiorari. Coyle’s application for leave to appeal was granted, but the Appellate Court of Maryland affirmed the circuit court’s judgment, concluding that Coyle did not have a right to counsel for filing a petition for a writ of certiorari and thus was not deprived of due process.The Supreme Court of Maryland reviewed the case and held that, based on the plain language of the Maryland Public Defender Act, where an attorney is authorized by the OPD to represent an indigent defendant in filing a petition for a writ of certiorari, the attorney must provide effective assistance of counsel. The Court concluded that the panel attorney’s conduct in failing to file the petition fell below an objective standard of reasonableness and constituted deficient performance under Strickland v. Washington. The Court held that prejudice is established because the defendant was deprived of the opportunity to have the petition considered. The judgment of the Appellate Court was reversed, and Coyle was permitted to file a belated petition for a writ of certiorari. View "Coyle v. State" on Justia Law

Harry Davis, Jr. was convicted by a jury in the Circuit Court for Baltimore City of second-degree murder, two counts of first-degree assault, two counts of second-degree assault, and one count of openly wearing and carrying a dangerous weapon. He was sentenced to 72 years in prison. After sentencing, the judge informed Davis of his right to appeal and to file a motion for modification of sentence within 90 days but did not advise him of his right to counsel for filing such a motion. Davis filed an appeal, which was affirmed by the Appellate Court of Maryland. No motion for modification of sentence was filed on his behalf.Davis later filed a petition for postconviction relief, claiming ineffective assistance of counsel for his trial counsel’s failure to file a motion for modification of sentence. The Circuit Court denied the petition, stating that there was no evidence Davis had asked his counsel to file the motion. Davis appealed, and the Appellate Court granted his application for leave to appeal and certified questions to the Supreme Court of Maryland.The Supreme Court of Maryland held that a defendant can establish ineffective assistance of counsel based on counsel’s failure to file a motion for modification of sentence by demonstrating that counsel failed to consult with the defendant about filing the motion and that this failure was unreasonable. The Court overruled previous decisions that suggested a per se rule either requiring or not requiring a request from the defendant. The Court concluded that Davis’s trial counsel’s failure to consult with him about filing a motion for modification of sentence constituted deficient performance and that Davis was prejudiced by losing the opportunity to have the motion considered. The Court reversed the Circuit Court’s judgment and remanded the case, allowing Davis to file a belated motion for modification of sentence. View "Davis v. State" on Justia Law

Two former police officers, Mark Zukowski and Joshua Ruggiero, were injured in the line of duty and subsequently awarded both accidental disability retirement (ADR) benefits and workers' compensation benefits under Maryland's Workers' Compensation Act. The ADR benefits exceeded the workers' compensation benefits, resulting in an offset that left the officers with only a small portion of the workers' compensation benefits. The officers' attorney sought fees based on the total workers' compensation award before the offset was applied.The Maryland Workers' Compensation Commission awarded attorney's fees based on the reduced amount of workers' compensation benefits after applying the statutory offset. The Circuit Court for Anne Arundel County affirmed the Commission's decision, holding that attorney's fees should be calculated after the offset.The Supreme Court of Maryland reviewed the case and affirmed the lower courts' decisions. The Court held that the terms "benefits" and "compensation" are interchangeable in this context, meaning that attorney's fees should be calculated based on the amount of compensation actually payable to the claimant after applying the statutory offset. The Court emphasized that the attorney's fees are a lien on the compensation awarded, which is defined as the money payable to the injured employee. Therefore, the offset must be applied before calculating the attorney's fees. The Court also rejected the argument that this interpretation was unconstitutional, stating that the attorney voluntarily agreed to the fee arrangement and was aware of the statutory provisions governing attorney's fees. View "Zukowski v. Anne Arundel Cnty." on Justia Law

Fred Cromartie was convicted of second-degree assault and other offenses following an altercation in a parking lot, which was recorded by surveillance cameras. The State alleged that Cromartie was one of the shooters, and his defense was self-defense. During the trial, the defense invoked Maryland Rule 5-615 to exclude witnesses from the courtroom while others testified. The State designated Detective Courtney Moore, a witness, as its representative, allowing him to remain in the courtroom.The Circuit Court for Anne Arundel County allowed the State's designation over the defense's objection. The jury convicted Cromartie of several charges but acquitted him of others. Cromartie appealed, arguing that the circuit court erred in allowing the State to designate Detective Moore as its representative and that Moore's testimony constituted improper lay opinion identification testimony.The Supreme Court of Maryland reviewed the case. The court did not resolve whether the circuit court erred in permitting the State to designate Detective Moore as its representative because any such error was deemed harmless beyond a reasonable doubt. The court found that Moore's testimony was not improperly influenced by other testimony he heard before testifying and that his presence did not improperly bolster the State's case.Regarding the lay opinion testimony, the court concluded that Cromartie did not preserve his argument that Moore's testimony identifying individuals in the video was improper. The court noted that the identity of the individuals was not in dispute and had already been established, including by the defense. Additionally, the defense did not request a continuing objection or object to subsequent similar questions and answers.The Supreme Court of Maryland affirmed the judgment of the Circuit Court for Anne Arundel County. View "Cromartie v. State" on Justia Law