Justia Maryland Supreme Court Opinion Summaries
State v. Thomas
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
Posted in:
Criminal Law
Adventist Healthcare v. Behram
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
Posted in:
Civil Procedure, Contracts
In the Matter of McCloy
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
Posted in:
Criminal Law, Government & Administrative Law
Cook v. State
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
Posted in:
Criminal Law
Turenne v. State
A collection of Dutch and Luxembourgish energy companies invested in solar power projects in Spain, relying on promised economic subsidies. Following the 2008 financial crisis, Spain withdrew these subsidies, prompting the companies to challenge Spain's actions through arbitration under the Energy Charter Treaty (ECT). The companies prevailed in arbitration, securing multi-million-euro awards. However, the European Union (EU) argued that the ECT's arbitration provision does not apply to disputes between EU Member States, rendering the awards invalid under EU law.The United States District Court for the District of Columbia reviewed the cases. In NextEra Energy Global Holdings B.V. v. Kingdom of Spain and 9REN Holding S.A.R.L. v. Kingdom of Spain, the court held it had jurisdiction under the Foreign Sovereign Immunities Act (FSIA) arbitration exception and denied Spain's motion to dismiss. The court also granted anti-anti-suit injunctions to prevent Spain from seeking anti-suit relief in foreign courts. Conversely, in Blasket Renewable Investments LLC v. Kingdom of Spain, the district court deemed Spain immune under the FSIA and denied the companies' requested injunction.The United States Court of Appeals for the District of Columbia Circuit reviewed the cases. The court held that the district courts have jurisdiction under the FSIA’s arbitration exception to confirm the arbitration awards against Spain. However, it found that the district court in NextEra and 9REN abused its discretion by enjoining Spain from pursuing anti-suit relief in Dutch and Luxembourgish courts. The court emphasized that anti-suit injunctions against a foreign sovereign raise significant comity concerns and that the domestic interests identified were insufficient to justify such extraordinary relief. Consequently, the court affirmed in part and reversed in part in NextEra, reversed in 9REN and Blasket, and remanded for further proceedings. View "Turenne v. State" on Justia Law
Rovin v. State
The petitioner was arrested under a warrant for allegedly violating Maryland's juror intimidation statute. After a bench trial, the circuit court acquitted her based on its interpretation of the statute. Subsequently, the petitioner filed a civil suit against a sheriff’s deputy, claiming false arrest, false imprisonment, malicious prosecution, and violations of her rights under the Maryland Declaration of Rights. The deputy had filed the application for charges after consulting with the State’s Attorney’s Office, which determined that the petitioner’s conduct violated the statute.The Circuit Court for Wicomico County granted summary judgment in favor of the State, ruling that the deputy could not be held civilly liable for the petitioner’s arrest pursuant to a warrant issued by a judicial officer. The Appellate Court of Maryland affirmed this decision, concluding that the warrant provided legal justification for the arrest and that the officers’ interpretation of the statute was objectively reasonable.The Supreme Court of Maryland reviewed the case and upheld the lower courts' decisions. The Court held that the circuit court did not err in granting summary judgment in favor of the State on the common law claims of malicious prosecution, false arrest, and false imprisonment, as well as on the constitutional claims under Articles 24 and 26 of the Maryland Declaration of Rights. The Court emphasized that when an arrest is made pursuant to a warrant, probable cause is predetermined by a judicial officer, creating a strong presumption of objective reasonableness. The petitioner failed to overcome this presumption.Additionally, the Court held that the circuit court did not err in granting summary judgment on the petitioner’s claim that her arrest and imprisonment violated her free speech rights under Article 40. The Court found that the judicial officer had probable cause to believe that the petitioner’s speech constituted a “true threat” and thus fell outside the protections of Article 40. Finally, the Court upheld the circuit court’s ruling that the juror intimidation statute was not unconstitutionally vague. View "Rovin v. State" on Justia Law
Mitchell v. State
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
Posted in:
Criminal Law
State v. Smith
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
Posted in:
Criminal Law
Mooney v. State
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
Posted in:
Criminal Law
Bennett v. Gentile
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
Posted in:
Professional Malpractice & Ethics, Trusts & Estates