Justia Maryland Supreme Court Opinion Summaries

The Court of Appeals reversed the decision of the circuit court affirming the decision of the administrative law judge (ALJ) concluding that an officer did not have reasonable grounds to believe that Respondent was driving or attempting to drive a motor vehicle while impaired, holding that the ALJ erred in imposing his credibility determinations and inferences to make the legal determination at issue.Following a traffic infraction, the officer in this case approached the vehicle, observed Respondent sitting in the driver's seat, and smelled alcohol on her breath and person. The officer requested that Respondent take an alcohol concentration test. Respondent refused to submit to the breath test, and the officers confiscated her driver's license. The ALJ took "no action" on the order of suspension, and Respondent's driving privileges were reinstated. The circuit court affirmed. The Court of Appeals reversed, holding that the detaining officer had reasonable grounds to suspect Respondent was driving or attempting to drive while impaired or under the influence of alcohol. View "Motor Vehicle Administration v. Medvedeff" on Justia Law

The Court of Appeals reversed the judgment of the court of special appeals affirming the judgment of the circuit court granting Defendant's petition for postconviction relief and ordering a new trial on the ground that Defendant's trial counsel provided ineffective assistance of counsel by not requesting an alibi jury instruction, holding that the circumstance that Defendant's trial counsel did not request an alibi jury instruction did not prejudice Defendant.At issue was whether Defendant satisfied, under Strickland v. Washington, 466 U.S. 668 (1984), his burden of proving that he was prejudiced when his trial counsel did not request, and the trial court did not give, an alibi jury instruction where purported alibi witnesses testified at trial. The Court of Appeals concluded that Defendant was not prejudiced because none of the purported alibi witnesses' testimony indicated that Defendant could not have been at the murder scene, and the circumstance that the circuit court gave other instructions regarding the State's burden to prove guilt beyond a reasonable doubt diminished the claim of prejudice. View "State v. Mann" on Justia Law

In this case involving the appropriate standard of review in an appeal on the record from the district court to the circuit court and the interpretation of a promissory note the Court of Appeals reversed the circuit court's judgment after applying the clearly erroneous standard to the district court's interpretation of the promissory note, holding that the circuit court applied the incorrect standard of review and erred in its interpretation of the promissory note.Petitioner offered a tuition loan program to its employee, and Respondent, a former employee of Petitioner, participated in this program until he was fired. Petitioner brought this action against Respondent seeking repayment of his debt. The district court entered judgment for Respondent. The circuit court affirmed, finding that the district court was not clearly erroneous in its interpretation of the promissory note. The Court of Appeals reversed, holding (1) a circuit court, in hearing an appeal on the record from the district court, reviews the district court's factual determinations for clear error and its legal conclusions de novo; and (2) the circuit court erred in construing the promissory note to require repayment only in situations where an employee quits. View "Credible Behavioral Health v. Johnson" on Justia Law

The Court of Appeals affirmed the judgment of the Court of Special Appeals determining that, to be entitled to habeas corpus relief under Md. Code Ann. Cts. & Jud. Proc. (CJ) 3-702(a), a person must be physically restrained within Maryland and that Petitioner was not entitled to habeas corpus relief in this case because he was not physically restrained within the State, holding that because Petitioner filed his habeas corpus when he was not significantly restrained in Maryland he was not eligible to seek habeas corpus relief pursuant to CJ 3-702(a).Petitioner was found guilty of fourth-degree sex offense and placed on probation. The district court later found that Petitioner had violated his probation and modified the conditions of probation to be "unsupervised" so that Petitioner could move from Maryland to Michigan. Thereafter, Petitioner filed his habeas corpus petition. The circuit court denied the petition. The Court of Special Appeals dismissed Petitioner's appeal because Petitioner was neither physically restrained nor within the State when he filed his petition. The Court of Appeals affirmed, holding that, under CJ 3-702(a), to be eligible to seek habeas corpus relief, a person must be committed detained, confined, or restrained in the State. View "Sabisch v. Moyer" on Justia Law

The Court of Appeals affirmed the decision of the Court of Special Appeals affirming the judgment of the circuit court finding that the Taneytown City Council violated some provisions of the Open Meetings Act (OMA), Md. Code, Title 3 of the General Provisions Article, but declining to impose sanctions, holding that the circuit court did not abuse its discretion in not imposing sanctions.Plaintiff alleged that the Council held a meeting that was closed to the public in violation of the OMA and asked the court to impose sanctions. The circuit court entered judgment for Defendant, concluding that the Council had violated certain provisions of the OMA but that those violations were technical, harmless, and not willful. The Court of Special Appeals affirmed. The Court of Appeals affirmed, holding (1) the use of "technicality" and harmless error as reasons to excuse violations of the OMA is rejected; (2) all sanctions under the OMA are discretionary with the trial court, and the court cannot impose such sanctions unless the violations were willful; and (3) although the trial court imposed used the wrong terms, the court did not abuse its discretion in determining that imposing civil penalties on the Council was not appropriate under the circumstances. View "Frazier v. McCarron" on Justia Law

The Court of Appeals affirmed the judgment of the court of special appeals affirming the judgment of the circuit court convicting Defendant of second-degree assault and misconduct in office, holding that the court did not abuse its discretion in excusing for cause four prospective jurors who indicated that they would be unable to use the stairs to the jury room.In this case, the courthouse in the circuit court contained a staircase with twenty-five steps that was the only way to reach the jury room that accompanied the courtroom used for the trial. The four prospective jurors said that they would have difficulty using or would be unable to use the stairs the trial court excused them. Defendant, a correctional officer, was convicted of second-degree assault and misconduct in office. The Court of Appeals affirmed, holding that, under the circumstances, the circuit court did not clearly err in finding that no other courtroom was available and excusing the prospective jurors for cause. View "Trotman v. State" on Justia Law

The Court of Appeals affirmed the circuit court's grant of preliminary injunctive relief enjoining the State Board of Elections from certifying the 2018 general election ballot with April Ademiluyi's name listed as a candidate for circuit court judge, holding that the Libertarian Party's nomination of Ademiluyi did not comport with the requirements of Md. Code Ann. Elec. Law (EL) 5-701 and that the circuit court's grant of preliminary injunction was sufficiently supported by the appropriate factors.Ademiluyi was a registered Democrat. Upon learning of Ademiluyi's party affiliation, Appellees challenged her qualifications for nomination as a circuit court judge. The circuit court ordered that Ademiluyi's be removed from the ballot. The Court of Appeals affirmed the circuit court's grant of preliminary injunctive relief, holding that Ademiluyi's candidacy was impermissible under the relevant provisions that regulate judicial elections in Maryland because (1) Ademiluyi's candidacy was at odds with the Libertarian Party's Constitution, which requires that its candidates for office be registered Libertarians; and (2) a judicial candidate's route to access the ballot is dependent upon her party affiliation, and candidates registered with a principal party may only achieve this end through participation in primary elections. View "Ademiluyi v. Egbuono" on Justia Law

The Court of Appeals affirmed the holding of the court of special appeals affirming the judgment of the juvenile court finding that sixteen-year-old S.K. was involved in distributing child pornography, holding that a minor may be adjudicated delinquent under Maryland's child pornography and obscenity statutes as the "person" who is a distributor of child pornography and a displayer of obscene matter when she is also the minor participant in the sex act.S.K. sent a video to her two best friends that showed herself performing fellatio in a male. When the video was later distributed to other students S.K. was charged under Md. Code Crim. Law (CR) 11-207(a)(4) and 11-203(b)(1)(ii). After an adjuratory hearing, the juvenile court found S.K. involved as to distributing child pornography and displaying an obscene item to a minor. The court of special appeals reversed in part, holding (1) a minor legally engaged in consensual sexual activity is not exempted from CR 11-207(a)(4); and (2) the cellphone video was not an "item" covered within CR 11-203(b)(1)(ii). The Court of Appeals reversed in part, holding (1) the plain language of CR 11-207(a)(4) subsumes situations where a minor produces and distributes pornographic material of himself or herself; and (2) S.K.'s conduct fell within that contemplated by CR 11-203. View "In re S.K." on Justia Law

The Court of Appeals affirmed the judgment of the court of special appeals overturning Defendant's conviction based on a lack of independent evidence that would corroborate accomplice testimony, holding that Maryland's common law accomplice corroboration rule is hereby abrogated and that the jury, after proper instruction about the possible unreliability of accomplice testimony, is entitled to weigh the sufficiency of the evidence without the need for independent corroboration.Defendant was convicted of conspiracy to commit armed carjacking. The court of special appeals reversed, holding that the accomplices' testimony was not independently corroborated by other evidence, which left the remaining evidence legally insufficient to sustain Defendant's conviction. The Court of Appeals held (1) the common law accomplice corroboration rule, which requires that accomplice testimony be independently verified to sustain a conviction, is hereby abrogated and replaced with a modified common law rule; and (2) the new rule should not apply to Defendant. View "State v. Jones" on Justia Law

In this case involving the claim of Petitioner, a veteran paramedic/firefighter regarding degenerative meniscal tears in his right knee the Court of Appeals affirmed the judgment of the trial court denying Baltimore County's motion for summary judgment and concluding that Petitioner's degenerative meniscal tears could be classified as an occupational disease, holding that there was ample evidence that Petitioner's employment actually caused the degenerative tears.The trial court determined that Petitioner met the statutory requirements set forth in Md. Code Ann. Lab. & Empl. (LE) 9-502(d)(1) that his alleged occupational disease was "due to the nature of an employment in which hazards of the occupational disease exist...." The County appealed. The Court of Appeals affirmed, holding that there was sufficient evidence for the jury reasonably to conclude that Petitioner's degenerative knee tears were "due to the nature of an employment in which hazards of the occupational disease exist." View "Baltimore County v. Quinlan" on Justia Law