Justia Maryland Supreme Court Opinion Summaries

The trial court in this criminal case did not err in admitting the testimony from the State’s cellular communication expert, Allen Hagy, and did not err in admitting evidence of Defendant’s silence during an investigation by his automobile insurer that was related to and concurrent with the police investigation in this case.After a third trial, Defendant was convicted of crimes associated with the murder of LaToya Taylor. The Court of Appeals affirmed the convictions, holding (1) the trial court properly exercised its discretion when it found that a sufficient factual basis existed in admitting Hagy’s expert opinion testimony, and the trial court’s decision to admit the testimony was not made in an arbitrary or capricious manner; and (2) there was no clear abuse of discretion in the trial court’s ruling to admit evidence of Defendant’s silence during the investigation by Defendant’s automobile insurer. View "Santiago v. State" on Justia Law

Although the Maryland Commission on Judicial Disabilities violated applicable Maryland Rules in proceedings against Judge Pamela J. White, the violations did not ultimately deprive Judge White of a fundamentally fair proceeding.In 2015, the Commission concluded that probable cause existed to believe that Judge White had committee sanctionable conduct and filed public charges against Judge White. The Commission later publicly reprimanded Judge White by unanimous vote, concluding that Judge White violated the Maryland Code of Judicial Conduct. On appeal, Judge White alleged that the Commission denied her procedural due process. The Court of Appeals disagreed, holding that although the proceeding before the Commission contained several mistakes, Judge White received the fundamental due process protections under the Maryland Constitution and the Maryland Rules. View "In re Honorable Pamela J. White" on Justia Law

At issue was to which of the decedent’s wives applied the provision of a trust agreement providing that a charitable foundation would be created unless the decedent was survived by his wife, in which case the foundation would not come into existence. After the decedent created the trust, his first wife died. The decedent remarried before he died. The Court of Appeals held (1) the decedent expressed a reasonably clear intention that the phrase “my wife,” as used in the contested provision, referred to his first wife rather than his second wife; and (2) therefore, the distribution to the foundation did not lapse, and the circuit court correctly accepted the trustees’ proposed restatement of the trust with respect to that issue. View "In re Albert G. Aaron Living Trust" on Justia Law

Md. Code Ann., Real Prop. 8-402.1(a)(1)(i) requires that before a landlord may file a breach of lease action, the tenant must breach the lease, the notice requirement must expire, and the tenant must refuse to comply with the notice to vacate.Here, the circuit court determined that Landlord did not need to wait for the fourteen-day notice period to expire before it filed a complaint for breach of lease. The Court of Appeals reversed, holding (1) the circuit court erred in its construction of section 8;402.1(a)(1)(i)(2)(b) when it concluded that Landlord was not required to exhaust the notice requirement prior to filing a complaint for possession; and (2) Landlord’s notice to vacate was not issued in accordance with the terms of the lease with Tenant, and this deficiency could not be cured by the subsequently filed complaint. View "Hunter v. Broadway Overlook" on Justia Law

In this election contest, the circuit court properly granted Defendants’ motion to dismiss on the grounds that Appellant's petition was untimely filed under Md. Code Ann., Elec. Law (EL) 12-202(b) and barred by the doctrine of laches.More than six months after the 2016 general election, Appellant filed a petition seeking to have the candidacy of the successful candidate for the position of judge of the Circuit Court for Prince George’s County decertified. Appellants filed a motion to dismiss, arguing that the election claims were untimely under EL 12-202(b) and barred by the doctrine of laches. The circuit court granted the motion to dismiss. The Court of Appeals affirmed, holding (1) the petition was untimely filed under EL 12-202(b) because Appellant did not file the petition until more than six months after the election and more than one year after Appellant became aware of the facts that served as the basis for the election claims and several months after the election results were certified; and (2) independent of the statutory limitations period set forth in EL 12-202(b), the petition was barred by the doctrine of laches because Appellant unreasonably delayed in asserting her rights, and that delay prejudiced Appellees. View "Ademiluyi v. State Board of Elections" on Justia Law

A conviction that is more than fifteen years old is not irrelevant as a matter of law to a character witness’ opinion about a defendant.After he was convicted for second-degree assault, Defendant appealed, arguing that the trial court improperly admitted evidence of his 1990 battery conviction. The Court of Special Appeals held that the trial court was permitted to allow the State to impeach character witnesses with evidence of Defendant’s twenty-five-year-old battery conviction where each character witness testified regarding Defendant’s reputation for peacefulness. The Court of Appeals affirmed, holding (1) the trial court did not err in deciding that the 1990 battery conviction bore some legal relevance to the character witnesses’ testimony; and (2) the probative value of the 1990 battery conviction was not substantially outweighed by the danger of unfair prejudice. View "Williams v. State" on Justia Law

Data from a business record indicating locations and durations of time determined by a GPS device carried by Defendant was admissible without the need for the State to present expert testimony to explain the operation of, and science underlying, GPS devices.Defendant, an officer with the Maryland Transit Administration (MTA) police, was convicted of assaulting and raping a woman after driving her home following her involvement in a traffic accident with an MTA bus. During trial, the State introduced GPS data from the mobile GPS device Defendant carried as part of his job that matched the itinerary given by the woman in her testimony. On appeal, Defendant argued that the State should have presented expert foundation testimony concerning GPS devices as a prerequisite to the admission of such evidence. The Court of Special Appeals affirmed the convictions. The Court of Appeals affirmed, holding that the jury did not require expert testimony to understand the operation of a GPS device and the data it generated. View "Johnson v. State" on Justia Law

At issue was under what circumstances a defendant has properly invoked his right to request a discharge of counsel pursuant to Maryland Rule 4-215(e).The Court of Special Appeals vacated Defendant’s convictions because the circuit court failed to hold a Rule 4-215(e) hearing prior to Defendant’s trials. Before trial, Defendant sent two pieces of correspondence to the circuit court in which he expressed dissatisfaction with his counsel. The circuit court did not take action on either correspondence until after Defendant’s trials. After the trials had concluded, the circuit court denied Defendant’s request. The Court of Appeals affirmed the judgment of the Court of Special Appeals, holding (1) Defendant’s two letters to the circuit court sufficiently triggered Rule 4-215(e); (2) Defendant did not waive his request to discharge his counsel when he did not repeat his request prior to or during his trials; and (3) the circuit court committed reversible error when it failed to inquire into the reasons for Defendant’s request in a timely manner. View "State v. Weddington" on Justia Law

The memorandum of understanding (MOU) between Prince George’s County and the City of College Park, a municipality within the County, did not alter the City’s authority to enforce zoning violations within the limits of its municipality and permitted the City to require additional permits under the City building code.Petitioners, a tenant to certain property and the property’s owners, challenged citations issued by the City after Petitioners failed to obtain required City permits. Petitioners sought a declaration that the terms of the MOU restricted the City from requiring City non-residential occupancy or building permits where occupants previously obtained building permits from the County. The circuit court concluded that the MOU restricted the City from requiring additional permits under the City building code where use and occupancy permits had previously been granted by the County. The Court of Special Appeals reversed. The Court of Appeals affirmed, holding that the MOU only controlled power that the County delegated to the City and did not limit the City’s power to enact additional ordinances. View "Precision Small Engines, Inc. v. City College Park" on Justia Law

At issue was whether the Attorney General has authority to request injunctive relief against a nursing facility pursuant to two different provisions of the Patient’s Bill of Rights, a comprehensive statutory scheme enacted to identify and protect individuals’ rights in Maryland nursing facilities.The State sought an injunction against Defendant, a nursing facility. The trial court concluded that the allegations in the State’s complaint, if true, would be in violation of the Patient’s Bill of Rights but that the Injunction Clause did not authorize the kind of broad injunctive relief the State sought and that the State lacked authority to sue for an injunction under the Enforcement Clause. The Court of Appeals reversed, holding (1) under Md. Code Ann. Health-Gen. 19-345.3(c), the Attorney General may bring suit on behalf of individual residents who have been subjected to, or away, imminent, unlawful involuntary discharges if at least one individual’s statutory rights have been violated, and a court may issue injunctive relief for violations of Md. Code Ann. Health-Gen. 19-345, 19-345.1 and 19-345.2; and (2) the Attorney General’s authority to prosecute violations of Md. Code Ann. Health-Gen. 19-344(c)(4)-(5) permits the Attorney General to seek an injunctive to enforce certain provisions related to the Medicaid application process. View "State v. Neiswanger Management Services, LLC" on Justia Law