Justia Maryland Supreme Court Opinion Summaries

The Court of Appeals reversed the judgment of the Court of Special Appeals reversing Defendant's conviction for robbery on the ground that the guilty verdict on the robbery charge was legally inconsistent with Defendant's acquittal on a second-degree assault charge, holding that the guilty verdict on the robbery count should be affirmed.A jury found Defendant guilty of robbery and theft but acquitted him of second-degree assault. The Court of Special Appeals reversed the conviction on the robbery count, concluding that the trial court erred in accepting inconsistent verdicts because the second-degree assault charge of which Defendant was acquitted was a lesser-included offense of the robbery. A majority of the Court of Appeals reversed, but the members who agreed with this disposition did so for different reasons. Two judges would apply a two-step analysis to hold that that the verdicts were not legally inconsistent and that the evidence satisfied the elements of robbery. Two other judges would analyze whether the verdict demonstrated that the jury disregarded the trial court's instructions on the law to conclude that the guilty verdict on the robbery count should not be reversed on the ground of inconsistency. View "State v. Stewart" on Justia Law

The Court of Appeals affirmed Defendant's conviction for involuntary manslaughter, holding that there was sufficient evidence to convict Defendant of gross negligence involuntary manslaughter for selling heroin to the victim, who fatally overdosed.Specifically, the Court of Appeals held that there was sufficient evidence in the record to conclude that Defendant's conduct was both the actual and legal cause of the victim's death. Therefore, the Court held that Defendant could be held to the most minimal level of criminal homicide culpability and that the trial court did not err in convicting Defendant of gross negligence involuntary manslaughter. View "State v. Thomas" on Justia Law

The Supreme Court reversed the decision of the Court of Special Appeals reversing the decision of the circuit court affirming the decision of the Workers' Compensation Commission modifying an order that provided Officer Peter Gang, who was injured working as a correctional officer for Montgomery County, a compensation award for a permanent partial disability resulting from his injury, holding that the Commission was authorized to retroactively modify the compensation award.Specifically, the Commission retroactively adjusted the rate of compensation because, as a public safety employee, Officer Gang had been entitled to a higher rate of compensation than that which he initially received. The Court of Appeals concluded that the Commission was not statutorily authorized to retroactively modify Officer Gang's rate of compensation. The Supreme Court affirmed, holding (1) under section 9-736(b) of the Workers' Compensation Act, the Commission may modify the compensation award within five years from the date of the last compensation payment; and (2) because Officer Gang applied for the correction before the statutory five-year period expired the Commission properly exercised its continuing jurisdiction to retroactively correct the rate of compensation in Officer Gang's award for permanent partial disability based on an error of law. View "Gang v. Montgomery County" on Justia Law

In this case involving the correct interpretation of Maryland Rule 4-345(c), the Court of Appeals held that, for a "mistake in the announcement of a sentence" to be "evident" under the statute, the mistake must be clear or obvious and that, under Maryland Rule 4-345(c), the circuit court did not make an evident mistake in the announcement of Defendant's sentence for conspiracy to rob Demaris Glover with a dangerous weapon.A jury found Defendant guilty of attempted robbery with a dangerous weapon, conspiracy to rob both Glover and William Rich with a dangerous weapon, and use of a handgun in the commission of a crime of violence. The Court of Special Appeals affirmed the convictions but remanded with instructions to amend the sentence to reflect that the circuit court sentenced Defendant to twenty years of imprisonment, with all but time serve suspended, for conspiracy to rob Glover with a dangerous weapon. The State appealed, arguing that, in the announcement of the sentence, the circuit court intended to say "ten years" instead of "time served" and that the court later corrected the mistake. The Supreme Court affirmed, holding that the record of the sentencing proceeding did not demonstrate that the circuit court made an "evident" mistake in the announcement of Defendant's sentence. View "State v. Brown" on Justia Law

The Court of Appeals affirmed the judgment of the Court of Special Appeals upholding the suppression hearing court's denial of Defendant's motion to suppress, holding that evidence of an out-of-court identification procedure, through which the victim of an alleged assault identified Defendant as the perpetrator of the crime, contained sufficient indicia of reliability to withstand a motion to suppress.At the conclusion of a suppression hearing, the presiding judge concluded that the second photo array identification procedure at issue in this case was admissible because she found it reliable by clear and convincing evidence. Ultimately, the jury found Defendant guilty of attempted robbery, second-degree assault, and reckless endangerment. The Court of Special Appeals affirmed, holding that the identification had sufficient indicia of reliability to overcome the procedure's suggestiveness. The Court of Appeals affirmed, holding that the identification contained sufficient indicia of reliability to overcome the suggestive nature of the pretrial identification procedures. View "Small v. State" on Justia Law

In this lead-based paint case the Court of Appeals held that the trial court did not abuse its discretion in admitting expert testimony from two of Plaintiff's experts - a vocational rehabilitation expert and an economic expert.The vocational expert provided testimony that, with the cognitive deficits caused by Plaintiff's exposure to lead, Plaintiff would have the earning capacity of someone with less than a twelfth-grade education. Relying on the vocation rehabilitation expert's conclusions, the economic expert opined that Plaintiff's loss of earning capacity over his lifetime was $1,073.042. The Supreme Court affirmed, holding (1) there was a sufficient factual basis to support the vocational rehabilitation expert's opinion as to Plaintiff's vocation and education attainment absent impairment; and (2) Lewin Realty III, Inc. v. Brooks, 771 A.2d 446 (Md. 2001), and Sugarman v. Liles, 190 A.3d 344 (Md. 2018), do not require an expert in a lead-based paint case to utilize statistical data or studies to support an opinion as to a plaintiff's vocational and education attainment absent deficits; and (3) the trial court did not abuse its discretion in denying a motion in limine to exclude the economic expert's testimony and report as untimely. View "Dackman v. Robinson" on Justia Law

The Court of Appeals vacated the judgment of the juvenile court declining to terminate the legal relationship between Mother, Father, and Child and ordering Child into the guardianship and custody of a relative, holding that the juvenile court abused its discretion by declining to terminate the parental rights of Father when it found that neither parent could never safely care for Child.In deciding this case, the Court of Appeals reaffirmed that, when considering the termination of parental rights, the pursuit of the best interest of the child remains the overall goal. As to the instant case, the Court of Appeals held (1) there was ample evidence to find that Father was unfit or that exceptional circumstances existed by clear and convincing evidence to terminate his parental rights; and (2) the trial court abused its discretion in declining to terminate Father's parental rights. View "In re Adoption/Guardianship of C.E." on Justia Law

The Court of Appeals affirmed the judgment of the Court of Special Appeals affirming the judgment of the circuit court denying Petitioner coram nobis relief, holding that Petitioner waived the grounds underlying both claims supporting his petition.Petitioner pleaded guilty to third degree sexual offense and was required to register as a sex offender. In his second petition for a writ of coram nobis Petitioner argued that he was deprived of the effective assistance of counsel and that his guilty plea was involuntary. The circuit court denied relief. The Court of Special Appeals affirmed after reaching the merits of Petitioner's claims. The Supreme Court affirmed, albeit on a different ground, holding that Petitioner's claims were waived. View "Hyman v. State" on Justia Law

The Court of Appeals vacated the judgment of the Court of Special Appeals affirming the postconviction court's grant of Defendant's petition for postconviction relief and remanded with instructions to remand the case to the postconviction court for further fact finding, holding that the record lacked the factual determinations necessary to rule on the state's motion to correct the record.Defendant was convicted of first degree murder and other crimes. In his motion for postconviction relief, Defendant raised several claims of ineffectiveness of trial counsel. The postconviction court granted Defendant's petition, finding that trial counsel provided deficient assistance by not objecting to an improper jury instruction. The Court of Special Appeals affirmed. The State appealed and, prior to oral argument, filed a motion to correct the record pursuant to Maryland Rule 8-414. The State's motion, if granted, would resolve the merits of the State's appeal by eliminating the sole ground for Defendant's postconviction relief. The Supreme Court held that a remand to the postconviction court was required because, given the nature of the parties' dispute and the facts available, the Court was not in the position to rule upon the State's motion to correct the record. View "State v. Christian" on Justia Law

The Court of Appeals affirmed the judgment of the Court of Special Appeals affirming Defendant's convictions, holding that this Court had jurisdiction to reach the merits of this appeal and that the trial court erred in excluding a witness' prior convictions for committing a violent crime in aid of racketeering (VICAR offense) for impeachment purposes but that the exclusion of those convictions was harmless.Defendant was found guilty of retaliation against a witness and participation in a criminal gang. The Court of Appeals affirmed the judgment of the trial court, holding that the trial court properly excluded a witness' prior VICAR offenses for impeachment purposes because those convictions involved violent crimes that were not relevant to credibility and were non-impeachable crimes. The Court of Appeals affirmed, holding (1) a witness' prior convictions for VICAR offenses are admissible for witness impeachment; and (2) although the trial court erred in excluding the witness' prior convictions for impeachment purposes, the court's error was harmless beyond a reasonable doubt. View "Rosales v. State" on Justia Law