Justia Maryland Supreme Court Opinion Summaries

The Supreme Court affirmed the judgment of the post-conviction court denying Petitioner's pro se petition for post-conviction relief, holding that the post-conviction court did not err in denying the petition.Petitioner was convicted of distribution of heroin and sentencing him to eight years in prison. In his post-conviction motion, Petitioner argued that his trial counsel rendered ineffective assistance during trial and that the State had violated its Brady obligations. The post-conviction court denied relief. The appellate court certified questions of law to the Supreme Court. The Supreme Court answered (1) Defendant failed to establish that trial counsel rendered ineffective assistance by failing to move to compel production of Internal Affairs Division files; and (2) assuming, without deciding, that the State was required to disclose impeachment evidence prior to the suppression hearing, Petitioner failed to establish the Brady materiality standard. View "Blake v. State" on Justia Law

The Supreme Court held that Jacob Bennett was not barred from serving on the Harford County Council because of his employment as a schoolteacher by the Harford County Board of Education, thus reversing the contrary order and declaratory judgment of the circuit court.After Bennett was elected to the Council in the November 2022 general election a dispute arose between Bennett and Harford County concerning whether he was precluded from serving simultaneously as a member of the Council and as an employee of the Board by either section 207 of the Harford County Charter or the common law doctrine of incompatible positions. The circuit court ruled in favor of the County on the basis that the Board should be treated as a County for purposes of Charter 207. The Supreme Court reversed, holding that neither Charter 207 nor the doctrine of incompatible positions barred Bennett from simultaneously serving as a member of the Council and an employee of the Board. View "Bennett v. Harford County" on Justia Law

The Supreme Court affirmed the decision of the post-conviction court denying Defendant's petition for post-conviction relief, holding that the post-conviction court did not err in ruling that trial counsel had not rendered ineffective assistance and that the State had not violated its Brady obligations during the underlying proceedings, holding that there was no error.After a jury trial, Defendant was convicted of distribution of heroin and sentenced to eight years' imprisonment. The appellate court affirmed. Defendant later filed a pro se petition for post-conviction relief, which the post-conviction court denied. On appeal, the appellate court certified questions of law to the Supreme Court. The Supreme Court answered (1) the post-conviction court did not err in ruling that trial counsel had not rendered ineffective assistance by failing to move production of certain evidence; and (2) assuming, without deciding, that the State was required to disclose challenged impeachment evidence prior to the hearing on Defendant's motion to suppress, Defendant failed to establish the Brady materiality standard. View "Blake v. State" on Justia Law

The Supreme Court reversed the judgment of the appellate court reversing the judgment of the circuit court denying Constituents' challenge to the amendment to a zoning ordinance limiting development of housing at a private airport in Prince George's County, which allowed the airport to develop higher-density housing, holding that the ordinance survived the challenge.While the County's zoning ordinance had historically limited development of housing at the airport to low-density, single-family detached housing, the County Council amended the text of the ordinance to allow the development of higher-density housing in order to incentivize redevelopment of the airport. Constituents brought the underlying challenge, arguing that the ordinance violated Maryland's uniformity requirement, Md. Code Ann., Land Use 22-201(b)(2)(i). The circuit court denied relief, but the appellate court reversed. The Supreme Court reversed, holding (1) the ordinance did not discriminate against similarly situated parties and was adopted to further a valid public purpose; and (2) therefore, the ordinance should have survived the uniformity challenge. View "Prince George's County Council v. Concerned Citizens of Prince George's County" on Justia Law

The Supreme Court affirmed the judgment of the circuit court granting Defendant's motion to dismiss Petitioner's petition for judicial review of a decision of a hearing examiner with the Fire and Police Employees' Retirement System for the City of Baltimore denying Petitioner's request for line-of-duty disability retirement, holding that the petition was untimely.Petitioner, a police officer, sustained an injury during a car accident that occurred while he was responding to an emergency call. A copy of the hearing examiner's decision denying line-of-duty disability retirement but granting him non-line-of-duty disability retirement. At issue was whether former Chief Judge Mary Ellen Barbera's administrative tolling order issued in response to the COVID-19 pandemic applied to Defendant's case. The circuit court concluded that the extension applied only to deadlines that were tolled during the closure of the clerks' offices between March 16, 2020 and July 20, 2020. The appellate court certified the question of whether the fifteen-day extension applied to all cases whose statute of limitations and deadlines related to initiation expired between those dates. The Supreme Court answered the question in the negative, holding that the fifteen-day extension under the administrative tolling orders applied only to cases with deadlines that were suspended during the closure of the clerks' offices between the relevant dates. View "In re Hosein" on Justia Law

The Supreme Court answered three questions certified by the United States District Court for the District of Maryland in this suit brought against Catholic Relief Services-United States Conference of Catholic Bishops (CRS), which follows the teaching that marriage is between one man and one woman.The district court ruled (1) CRS violated Title VII of the Civil Rights Act of 1964 by revoking Plaintiff's dependent health insurance because he was a man married to another man; and (2) Plaintiff was entitled to summary judgment on his federal Equal Pay Act claim. The court then ordered the parties to confer and file proposed questions of law with respect to the Maryland Fair Employment Practices Act (MFEPA), Md. Code Ann., State Gov't 20-606, and the Maryland Equal Pay for Equal Work Act (MEPEWA), Md. Code Ann., Lab. & Empl. 3-304. The Supreme Court answered (1) the prohibition against discrimination on the basis of sex in MFEPA does not itself also prohibit sexual orientation discrimination, which is separately covered under MFEPA; (2) MEPEWA does not prohibit sexual orientation discrimination; and (3) MFEPA's religious entity exemption applies with respect to claims by employees who perform duties that directly future the core mission of the religious entity. View "Doe v. Catholic Relief Services" on Justia Law

In this case involving the criminal trial of two co-defendants whose cases had been consolidated and was initially scheduled for a date beyond the appropriate date under the "Hicks rule" and the trial court made no finding of "good cause," the Supreme Court held that the dismissal of Defendants' indictments as a remedy for the Hicks violation was inappropriate.The circuit court granted Defendants' motions to dismiss their respective indictments because of the Hicks rule violations. The appellate court affirmed in the case of Garrick Powell on the grounds that Powell's attorney did not expressly consent to a trial date beyond the Hicks date but reversed in the case of Lateekqua Jackson, determining that Jackson expressly consented a trial date beyond the Hicks date. The Supreme Court reversed in part and reversed in part, holding (1) through his conduct, Powell's counsel sought a trial date that exceeded the Hicks date, thus precluding dismissal of the indictment against him due to the Hicks violation; and (2) through her conduct, Jackson's attorney sought a trial date that exceeded the Hicks date, thereby precluding dismissal of the indictment as a remedy for the Hicks violation. View "Jackson v. State" on Justia Law

The Supreme Court held that the Maryland Tort Claims Act's (MTCA), Md. Code Ann. State Gov't (SG) 12-104(a)(1), waiver of sovereign immunity as to a "tort action" does not extend to federal statutory claims.Plaintiff brought this action against Defendants, her former employer and supervisor, regarding her termination from Morgan State University (MSU). Because Plaintiff included claims of retaliation in violation of the National Defense Authorization Act (NDAA), 41 U.S.C. 4712, and the American Recovery and Reinvestment (ARRA), Pub. L. No. 11-5, 1553 Defendants removed the suit to federal district court. The district court dismissed the action with prejudice. The United States Court of Appeals for the Fourth Circuit vacated the district court's order and remanded the matter with directions to address whether Maryland has waived state sovereign immunity against federal whistleblower claims by enacting the MTCA. The district court answered the question in the negative. The Supreme Court answered an ensuing certified question by holding that "a tort action" under the MTCA does not include federal statutory claims. View "Williams v. Morgan State University" on Justia Law

The Supreme Court upheld the final determination of the Maryland Department of the Environment to reissue with revisions a general discharge permit to Animal Feeding Operations (AFOs), holding that the Department's final determination was reasonable and complied with applicable water quality standards.The most recent iteration of the general discharge permit the Department issued to AFOs was finalized by the Department pursuant to certain statutory requirements requiring the Department to review and issue or reissue water pollution control permits once every five years. The circuit court vacated the permit and remanded the matter with instructions to incorporate certain water quality standards into the permit. The Supreme Court reversed the judgment of the circuit court, holding (1) the Department's AFO general discharge permit framework was reasonable and consistent with federal and state law; and (2) the Department's decision to evaluate each AFO individually and to require appropriately-tailored best-management practices to control the emissions where they presented a risk of discharge was reasonable and not an abuse of discretion. View "Dep't of Environment v. Assateague Coastal Trust" on Justia Law

The Court of Appeals reversed the judgment of the circuit court convicting Defendant of first-degree murder and related handgun offenses, holding that the circuit court abused its discretion in permitting a firearms examiner to testify, without qualification, that bullets left at a murder scene were filed from a gun Defendant had acknowledged was his, and the error was not harmless.On appeal, Defendant argued that the circuit court abused its discretion in admitting the firearms identification testimony based on testimony, reports, and studies that called into question the reliability of firearms identification analysis. The Court of Appeals agreed and reversed the case for a new trial, holding that the circuit court (1) did not abuse its discretion in ruling that the firearms examiner could testify about firearms identification generally and other information; but (2) erred in permitting the examiner to opine without qualification that the crime scene bullets were fired from Defendant's firearm. View "Abruquah v. State" on Justia Law