Justia Maryland Supreme Court Opinion Summaries

The Court of Appeals affirmed the judgment of the court of special appeals reversing Defendant's conviction of second-degree murder, holding that non-mutually admissible evidence was admitted at trial, prejudicing Defendant, and the seizure of a cell phone from Defendant's person exceeded the parameters of the Fourth Amendment and Article 26 of the Maryland Declaration of Rights.Defendant was tried in the circuit court along with a co-defendant for murder. Both defendants were convicted of second-degree murder. On appeal, Defendant argued that his trial should have been severed from that of his co-defendant since a substantial amount of the evidence against the co-defendant was not admissible against him. Defendant further argued that the trial court erred in failing to suppress a cell phone that was seized from his pocket. The Court of Appeals agreed, holding that (1) the trials should have been severed because the joint trial unfairly prejudiced Defendant, and the resulting prejudice could not be cured; and (2) in the absence of a valid search and seizure warrant for the search of Defendant's person or an applicable exception to the warrant requirement, the seizure of the cell phone was unlawful. View "State v. Zadeh" on Justia Law

In this case brought against an insurer in Plaintiff's attempt to collect on a judgment in his favor in a strict liability and negligent failure to warn action, the Court of Appeals held that damages from a continuous bodily injury judgment must be allocated on a pro rata, time-on-the-risk basis across all insured and insurable periods triggered by Plaintiff's injuries.Almost forty years after exposure to asbestos at his place of work, Plaintiff was diagnosed with mesothelioma. Plaintiff won a nearly $2.7 million judgment against the asbestos installer. Plaintiff then initiated garnishment proceedings against Defendant as insurer of the asbestos installer. At issue before the circuit court was how to allocate loss among various trigger insurance policies because the installer was only insured by Defendant from 1974 to 1977 through four comprehensive general liability policies. The circuit court concluded that Plaintiff's damages must be allocated on a pro rata, time-on-the risk basis across all insured and insurable periods triggered by Plaintiff's injuries. The Supreme Court affirmed, holding that the circuit court properly applied the pro rata allocation approach rather than a joint-and-several approach that would have required the insurer to cover the entire judgment. View "Rossello v. Zurich American Insurance Co." on Justia Law

The Court of Appeals affirmed the judgment of the Court of Special Appeals affirming the ruling of the circuit court denying both Appellant's request for post-conviction relief under the Post-Conviction Procedure Act (UPPA) and his petition for writ of error coram nobis, holding that Appellant was not entitled to the relief he sought.The circuit court found Appellant guilty to two counts of second-degree assault and determined that he was "not criminally responsible" (NCR). Appellant later filed a pro se petition for post-conviction relief under the UPPA, arguing that his NCR plea was the functional equivalent of a guilty plea and was invalid because he did not understand the nature of the charges. He also filed a petition for writ of error corm nobis seeking to vacate the NCR judgment. The circuit court denied relief as to both petitions. The Court of Special Appeals affirmed. The Court of Appeals affirmed, holding (1) Appellant was not eligible for relief under the plain language of the UPPA; and (2) Appellant was not entitled to coram nobis relief because he did not suffer significant collateral consequences. View "Peterson v. State" on Justia Law

The Court of Appeals reversed the judgment of the Court of Special Appeals reversing the order of the circuit court declaring that Defendant, who pled guilty to sex trafficking, was not required to register as a Tier II Sex Offender on the ground that the victim's age had not been proven, holding that the circuit court properly granted declaratory judgment in favor of Defendant.At issue was whether a person like Defendant, who was convicted of human trafficking under Md. Code Ann. Crim. Law (CR) 11-303(a), was required to register as a Tier II Sex Offender where the victim's age was not established during the guilty plea proceeding. The Court of Special Appeals reversed and remanded the case for a determination of the victim's age. The Court of Appeals reversed, holding (1) CR 11-303(a) is an offense whose elements do not require proof of the victim's age; (2) where no proof of the victim's age was established at the plea proceeding, Defendant was not required to register as a Tier II Sex Offender; and (3) the Department of Public Safety and Correctional Services lacks the authority to make a factual determination as to the victim's age for purposes of determining whether registration as a Tier II Sex Offender is required. View "Rogers v. State" on Justia Law

In this case concerning the discretion of a court to dismiss a probation violation petition and to terminate probation the Court of Appeals held that the circuit court had discretion to terminate Defendant's probation before it would otherwise expire and remanded the case to the circuit court for any necessary proceedings in which the court may either exercise its discretion, indicate that it had already done so, or take any other appropriate action.Defendant pled guilty to theft and was sentenced to three years supervised probation. Defendant was later charged with violating the conditions of his probation. After noting that Defendant had already been incarcerated for longer than the presumptive sanction of fifteen days' imprisonment the court dismissed the probation violation petition without determining whether Defendant had committed the alleged probation violations. The court never declared that Defendant's probation had "expired" and was "over." Because the record did not indicate that the circuit court in fact exercised its discretion to terminate Defendant's probation before it would otherwise expire, the Court of Appeals remanded the case to the circuit court for any necessary proceedings in which the court may either exercise its discretion, indicate that it had already done so, or take any other appropriate action. View "State v. Alexander" on Justia Law

In this summary ejectment proceeding, the Court of Appeals reversed the judgment of the circuit court affirming the judgment of the district court precluding Tenant from asserting and litigating defenses under the implied warranty of habitability and the rent escrow statutes, holding that Tenant was statutorily entitled to raise such defenses during the proceeding and to have them fully considered.Landlord brought his summary ejectment proceeding alleging that Tenant had failed to pay rent for five months and seeking repossession of the property. Tenant moved to dismiss the complaint on grounds that Landlord did not have use and occupancy permit, which the district court denied. Tenant also attempted to assert defenses to summary ejectment, which the district court denied. The circuit court affirmed. The Supreme Court reversed, holding (1) the district court properly denied the motion to dismiss; but (2) a claim for breach of the warranty of habitability or under the rent escrow statutes may be raised as a defense in a summary ejectment proceeding. View "Pettiford v. Next Generation Trust Service" on Justia Law

The Court of Appeals vacated the judgment of the court of special appeals and remanded with directions to reverse the judgment of the circuit court certifying a settlement class and approving a settlement reached by the parties with respect to that class, holding that the circuit court erred in approving the proposed settlement.The class-action lawsuit was filed on behalf of 100 individuals who had assigned structured settlement annuity benefits they were entitled to receive from certain tortfeasors to Petitioner or its affiliates or designees based on allegations that the assignments were the product of fraud. Ultimately, the circuit court approved the proposed settlement. The court of special appeals reversed. The Court of Appeals vacated the judgment below and concluded that the circuit court erred in approving the proposed settlement under the facts and circumstances of this case. View "Linton v. Consumer Protection Division" on Justia Law

The Court of Appeals affirmed the judgment of the court of special appeals reversing the circuit court's decision determining that it had personal jurisdiction over Defendant and entering a judgment in favor of Plaintiff, holding that the factors weighed against the constitutional reasonableness of causing Defendant to defend this suit in Maryland.This case was filed by Defendant's stepson, who was a North Carolina resident, against Defendant, who was also a North Carolina resident. Plaintiff ultimately obtained a default judgment against Defendant in the amount of $99,856.84. The court of special appeals reversed the circuit court's decision with respect to the finding of personal jurisdiction. The Court of Appeals affirmed, holding that Defendant's act of filing a sole lawsuit through counsel did not rise to the level of a "persistent course of conduct" to justify the assertion of personal jurisdiction over her in this matter. View "Pinner v. Pinner" on Justia Law

The Court of Appeals affirmed the judgment of the court of special appeals affirming Defendant's convictions of volume possession of a controlled dangerous substance under Md. Code Crim. Law (CR) 5-612, holding that CR 5-612 is unambiguous and that Defendant's sentence was not illegal because the maximum term of imprisonment under the statute is twenty years.In connection with his conviction, Defendant was sentenced to a total sentence of fourteen years' imprisonment, the first five years without the possibility of parole. On appeal, Defendant argued that his sentence was illegal because the express language of CR 5-612 failed to state a maximum potential term of imprisonment. The Court of Appeals affirmed, holding that Defendant's sentence was legal because it fell within the permissible range of years for which an individual may be sentenced - five to twenty years' of imprisonment. View "Johnson v. State" on Justia Law

In this appeal concerning whether a school board was liable for a judgment against its employee when the board was dismissed from the case prior to trial the Court of Appeals held that, under Md. Cts. & Jud. Proc. 5-518, even if a board is entitled to substantive dismissal from a case the plaintiffs are required to maintain the board as a party or request that the board be brought back into the case to indemnify an employee.As a matter of trial strategy in a case against the Baltimore City Board of School Commissioners, counsel for Plaintiffs decided to not appeal the dismissal, via summary judgment, of the Board from the case and to avoid joinder of the Board under after the conclusion of the trial. After the trial, Plaintiffs filed motions to enforce the judgments, arguing that the Board was obligated to satisfy the judgments pursuant to section 5-518. The circuit court granted Plaintiffs' motions. The court of special appeals reversed. The Court of Appeals affirmed, holding that, in order to force a county school board to indemnify a judgment against a county board employee, the mandatory joinder requirement under section 5-518 requires that a county board be joined as a party throughout the entire litigation. View "Neal v. Baltimore City Board of School Commissioners" on Justia Law