Justia Maryland Supreme Court Opinion Summaries

The trial court properly admitted into evidence a bank statement record and a compact disk (CD) containing video surveillance footage because the evidence was properly authenticated under the Maryland Rules of Evidence.Defendant was convicted of first-degree assault and theft of at least $1,000 but less than $10,000. The court of special appeals affirmed, holding that the disk segment containing the surveillance footage was properly authenticated by a bank employee and that the bank statements satisfied the four requirements of the business record hearsay exception and thus were properly authenticated. The Court of Appeals affirmed, holding that the court of special appeals did not err when it concluded that the CD was properly authenticated and that the bank statements were admissible under the business records exception to the hearsay rule. View "Jackson v. State" on Justia Law

At issue was whether a teacher in the Montgomery County Public School (MCPS) system is protected by the Maryland State Whistleblower Protection Law (WBL), Md. Code State Pers. & Pens. 5-301-314.Petitioner filed a WBL complaint against MCPS, arguing (1) teachers employed by the county school board are embraced within the WBL because the county school board is a unit of the executive branch of State government, and (2) MCPS should be estopped from asserting that it is not a State agency because it had asserted in other contexts State agency status. The court of appeals concluded (1) the WBL does not apply to public school teachers employed by county boards of education because they are not employees of the executive branch, and (2) an entity may qualify as a State agency for some purposes while being classified as a local agency for other purposes. The Supreme Judicial Court held (1) the county board of education is not a State agency for purposes of the WBL, and WBL protection does not otherwise extend to public school teachers; and (2) judicial estoppel has no role in this case because the appropriate designation of a county school board as either a State or local agency depends on the context of the board’s particular authority or function. View "Donlon v. Montgomery County Public Schools" on Justia Law

The trial court abused its discretion by choosing to wait until Defendant testified before ruling on the admissibility of Defendant’s prior conviction for purposes of impeachment.Defendant was convicted for possession with intent to distribute a controlled dangerous substance. During trial, defense counsel advised Defendant of his Fifth Amendment right against self-incrimination and informed him that because he had a prior conviction for possession with intent to distribute a controlled dangerous substance, counsel would ask the court to conduct a balancing test under Maryland Rule 5-609 to determine whether the State would be allowed to use that prior conviction against him. The trial court declined to conduct the balancing test prior to Defendant’s election not to testify. On appeal, Defendant argued that the trial court failed to exercise its discretion when it chose not to give an advance ruling on the admissibility of his prior conviction. The Court of Special Appeals affirmed, concluding that it would have been “premature” for the trial court to engage in a balancing test without observing Defendant’s testimony first. The Court of Appeals reversed, holding that the trial judge did not need to wait to hear Defendant’s testimony before ruling on the Rule 5-609 motion, and the court’s failure to exercise its discretion constituted an abuse of discretion. View "Burnside v. State" on Justia Law

Under the totality of the circumstances of this case, Petitioner knowingly and voluntarily pleaded guilty to first-degree murder.Petitioner pleaded guilty to first-degree murder. After unsuccessfully seeking leave to appeal his conviction following guilty plea and failing to obtain requested postconviction relief, Petitioner requested that his postconviction matter be reopened pursuant to Md. Code Ann. Crim. Proc. 7-104. As grounds for his petition, Petitioner claimed that the Supreme Court’s decision in State v. Daughtry, 18 A.3d 60 (Md. 2011), required reopening his case in the interests of justice. The postconviction hearing judge agreed, reopened the case, and vacated Petitioner’s guilty plea. The Court of Special Appeals reversed. The Court of Appeals affirmed, holding (1) the record of the plea hearing demonstrated that Petitioner entered his guilty plea knowingly and voluntarily; and (2) procedural distinctions precluded Daughtry’s application to the present case. View "Tate v. State" on Justia Law

At issue was whether the possession and control exception to Maryland’s statute of repose, codified at Md. Code Cts. & Jud. Proc. (CJP) 5-108, which bars certain claims relating to injuries caused by improvements to real property, opens defendants to liability in cases that do not involve asbestos.CJP 5-108(d)(2)(i) provides that the protections of the statute of repose shall not apply if the “defendant was in actual possession and control of the property as owner, tenant, or otherwise when the injury occurred….” The subsections (d)(2)(ii)-(iv) eliminate the statute’s protection for certain defendants where a claimed injury was caused by exposure to asbestos. Here, Plaintiffs filed a wrongful death action against Defendants, the owner and property manager of a shopping center, alleging that the defendants failed to warn the decedent, an HVAC repairman, that the wall he climbed and fell from had no roof access. Defendants moved for summary judgment arguing that Plaintiffs’ claims were barred by the statute of repose and that the possession and control exception applied only to asbestos cases. The circuit court greed and granted summary judgment for Defendants. The Court of Special Appeals reversed. The Court of Appeals affirmed, holding that the possession and control exception to the statute of repose applies in non-asbestos cases. View "SVF Riva Annapolis LLC v. Gilroy" on Justia Law

At issue was whether the circuit court erred in admitting controlled dangerous substances into evidence at trial in the absence of strict compliance with Md. Code Ann. Cts. & Jud. Proc. 10-1001, 10-1002, and 10-1003.Prior to his criminal trial, Defendant made a timely demand pursuant to Cts. & Jud. Proc. 10-1003 for the presence of all the members in the chain of custody at trial. The State was unable to call the “packaging” officer as a witness, but the court admitted the suspected controlled dangerous substances, concluding that the State properly established the chain of custody. The Court of Special Appeals affirmed. The Court of Appeals affirmed, holding (1) where there has been an invocation of the right to have all witnesses produced pursuant to section 10–1003, the State may not proceed under the streamlined procedure for establishing the chain of custody pursuant to Cts. & Jud. Proc. 10-1001 to -1003 and instead must establish a proper chain of custody that negates a reasonable probability of alteration or tampering; and (2) because the State produced the officer who originally recovered the drugs and the chemist who tested them, the trial court did not abuse its discretion in admitting the evidence. View "Wheeler v. State" on Justia Law

In this dispute over constitutional limits on the governor’s power to make recess appointments, the Court of Appeals held that a provision in the state budget bill passed by the general assembly that precluded two gubernatorial appointees from being paid a salary exceeded the authority of the legislature was was invalid and unenforceable.In 2016, the governor appointed the two appointees as secretaries for two departments. The governor withdrew his nomination of the appointees during the 2017 legislation session but later reappointed the two secretaries. Anticipating that prospect, the general assembly passed a provision in the state budget bill forbidding payments to administration appointees who were nominated but not confirmed by the Maryland Senate. The cabinet secretaries filed suit demanding pay for their work. The circuit judge ruled that the governor had the authority to make the two recess appointments and ordered the treasurer to pay the cabinet secretaries. The Court of Appeals vacated the circuit court’s judgment and remanded for entry of a declaratory judgment declaring that the appointees were entitled to be paid the salaries set forth in the fiscal year 2018 budget for the times they served as secretaries of their respective departments and for entry of an order enjoining the state from interfering with the payment of those salaries. View "Kopp v. Schrader" on Justia Law

The Court of Appeals affirmed the judgment of the Court of Special Appeals affirming the trial court, which convicted Petitioner of rape and sentenced him to a term of seven years incarceration and five years of supervised probation.Before the Court of Appeals, Petitioner argued that the trial court erred in allowing the State to admit redacted portions of telephone calls Petitioner made to his mother while in pre-trial detention. The Court disagreed, holding that the trial court’s exclusion of the entire jail call transcript did not violate the common law doctrine of verbal completeness. View "Otto v. State" on Justia Law

Jurisdiction under the Maryland Uniform Postconviction Procedure Act (UPPA), Md. Code Ann., Crim. Proc. 7-101 to -109, is determined upon the filing of a petition for postconviction relief and, barring a procedural default, is not defeated upon the petitioner’s release from custody prior to completion of full review of the case, including any appellate review.After Petitioner filed an application for leave to appeal the denial of his petition for postconviction relief, Petitioner completed his sentence, including a three-year probationary period. The Court of Appeals dismissed the appeal, concluding that it lost jurisdiction to entertain the appeal once Petitioner was no longer in custody. The Court of Appeals vacated the Court of Appeals’ judgment and remanded to that court to consider the merits of Petitioner’s appeal, holding that whenever a timely petition for postconviction relief is filed, absent the petitioner’s procedural default, Maryland courts retain jurisdiction throughout consideration of the petition, including appellate review, despite any intervening release from custody. View "Kranz v. State" on Justia Law

The award of summary judgment in favor of the general contractor against the subcontractor in this case based on a pay-if-paid clause was improper because the pay-if-paid clause did not apply to the issues in this case.Pay-if-paid clauses make the project owner’s payment of the general contractor a condition precedent of the general contractor’s obligation to pay the subcontractor. Thus, the pay-if-paid clause can relieve the general contractor of liability to the subcontractor even where the subcontractor has fully performed its part of the subcontract. Here, Subcontractor sued General Contractor for breach of contract relating to a construction project. The circuit court granted summary judgment to General Contractor, concluding that, under Virginia law, a pay-if-paid provision in the subcontract applied to the damages sought. The Supreme Court reversed and remanded the case, holding (1) the pay-if-paid clause did not necessarily apply to the costs at issue in this case; and (2) the other provision relied upon by the circuit court did not create a condition precedent for payment of subcontractors. View "Young Electrical Contractors, Inc. v. Dustin Construction, Inc." on Justia Law