Justia Maryland Supreme Court Opinion Summaries

At issue was whether the revised and consolidated assault statute, contained in Md. Code Ann. Crim. Law 3-201(b), contemplates different crimes or whether the acts constitute second degree assault.Petitioner was convicted of two counts of first degree assault. The trial court instructed the jury on two different variations of second degree assault, but the jury was not instructed to reach a unanimous decision about which version occurred. The Court of Special Appeals upheld Petitioner’s convictions. The Court of Appeals affirmed, holding that the assault statute contemplates different modalities of committing the singular crime of second degree assault, as opposed to different crimes. Therefore, Petitioner was not entitled to have the trial judge instruct the jury to unanimously agree to which modality of assault Petitioner had committed. View "Watts v. State" on Justia Law

At issue was the manner in which Md. Const. art. IV, 22, which provides for an in banc appeal from a “decision of determination of any point or question” by a circuit court judge, is intended to operate.The State in this criminal case filed a request for an in banc review of an order of the circuit court judge granting Defendant’s motion in limine to exclude certain documents and testimony under Reed v. State, 283 Md. 374 (1978). The State sought in banc review, but the request was untimely filed. After a hearing, an in banc court reversed the trial judge’s ruling. The Court of Special Appeals reversed, concluding that “a litigant may not appeal to an in banc panel when the litigant could not note an appeal to [the Court of Special Appeals] successfully.” The Court of Appeals affirmed after analyzing relevant case law and the current version of section 22 in conjunction with Maryland Rule 2-551. The court further outlined the proper procedures a party must follow to reserve the point, question, or judgment for review and held that a decision by the in banc court constitutes a final judgment of that court. View "State v. Phillips" on Justia Law

At issue in this negligence case was the admission, under Maryland Rule 5-703(b), of Plaintiff’s medical records that a defense expert relied upon in forming his opinions. The circuit court granted a motion for judgment in favor of Plaintiff. Plaintiff sought damages in an amount from $50,000 to $150,000 but the circuit court entered judgment in the amount of $10,576.05. The court of special appeals affirmed. The Supreme Court affirmed, holding that the circuit court did not err or abuse its discretion in admitting Plaintiff’s post-accident medical treatment records into evidence under Maryland Rule 5-703. View "Lamalfa v. Hearn" on Justia Law

The Court of Appeals affirmed the judgment of the circuit court finding that the Dormant Mineral Interests Act (the Act), Md. Code Ann. Envir. 15-1201 through 15-1206, is constitutional and terminating Petitioners’ mineral interests.The Act authorizes a circuit court, under certain circumstances, to terminate a dormant severed mineral interest, thus effecting a merger of that mineral interest with the estate overlying it. Owners of surface estates (Respondents), invoked the Act, seeking termination of dormant mineral interests held by Petitioners. The circuit court entered a final order merging the terminated mineral interests of Petitioners into the surface estates of Respondents. The Supreme Court affirmed, holding that the Act does not violate Article 24 of the Maryland Declaration of Rights or Article III, section 40 of the Maryland Constitution because the Act is not retrospective and vested rights are not subject to Maryland’s enhanced protection rule. View "Ellis v. McKenzie" on Justia Law

The Court of Appeals reversed the judgment of the Court of Special Appeals and remanded this criminal case with instructions to vacate the judgment of the circuit court convicting Defendant of second-degree murder and related charges and to remand the case to that court for a new trial. The court held that the trial court committed reversible error by refusing to permit Defendant to cross-examine a State’s witness, pursuant to Maryland Rule 5-616(a)(4), as to whether, in return for his testimony, he expected or hoped for a benefit from the State in connection with pending criminal charges he was facing. View "Manchame-Guerra v. State" on Justia Law

The Court of Appeals affirmed the judgment of the Court of Special Appeals affirming Defendant’s conviction of second-degree assault. On appeal, Defendant argued that the trial court improperly admitted evidence of his 1990 battery conviction. The Court of Special Appeals held that the trial court did not abuse its discretion in allowing the State to impeach character witnesses with evidence of Defendant’s twenty-five-year-old battery conviction. The Supreme Court affirmed, holding that the trial court did not err in admitting evidence of Defendant’s 1990 battery conviction because (1) the 1990 conviction was not irrelevant as a matter of law because the conviction had some bearing on Defendant’s character for peacefulness; and (2) Maryland Rule 5-404 unambiguously does not provide a fifteen-year limitation for rebuttal evidence. View "Williams v. State" on Justia Law

The trial court properly dismissed two of Petitioners’ counts against Respondent seeking damages for injuries one of the petitioners allegedly sustained while staying at one of Respondent’s facilities because these two counts alleged medical injuries within the Health Claims Act (HCA). Therefore, Petitioners were required to file those claims in the Health Care Alternative Dispute Resolute Office (ADR Office) as a condition precedent to their circuit court action. Petitioners’ remaining negligence count should survive because it did not allege a breach of professional standard of care such that it must be filed in the ADR Office. Petitioners’ counts sounding in contract, consumer protection, and loss of consortium also survived dismissal. View "Davis v. Frostburg Facility Operations, LLC" on Justia Law

When a landlord sues a tenant for breach of contract based on a residential lease and the trial court enters judgment in the landlord’s favor and the judgment includes damages for unpaid rent and other expenses, a post-judgment interest rate of six percent applies pursuant to Md. Code Ann., Cts. & Jud. Proc. (“CJ”) 11-107(b) rather than the post-judgment interest rate of ten percent under CJ 11-107(a).Landlords initiated actions for breach of contract against Tenants. The district court entered judgments in Landlords' favor, but the judgments did not delineate the portions thereof that were comprised of unpaid rent, as opposed to other expenses. Thereafter, Debt Collector engaged in collections activity on Landlords’ behalf. Debt Collector sought to apply the post-judgment interest rate of ten percent under CJ 11-107(a). Tenants filed complaints against Debt Collector, arguing that CJ 11-107(b) applied. The federal district court certified the question of which legal rate of post-judgment interest on the judgment awarded applied. The Supreme Court answered as set forth above. View "Ben-Davies & Moore v. Blibaum & Associates, P.A." on Justia Law

Petitioners, thirteen operators of charter schools in Baltimore County, filed breach of contract complaints against the Baltimore City Board of School Commissioners directly in the circuit court without first seeking review before the State Board of Education. Petitioners argued that the City Board breached contractual requirements by not providing information as to its commensurate funding calculations and by failing to provide the correct amount of commensurate funding for the 2015-16 school year. The circuit judge stayed proceedings in the circuit court pending the State Board’s administrative review of the parties’ dispute. The court of special appeals dismissed Petitioners' appeal, concluding that the stay order was not an appealable order. The Court of Appeals reversed, holding (1) under the unique circumstances of this case, the stay order was a final and appealable judgment; (2) the circuit court abused its discretion in staying the proceeding in order for the parties to seek administrative review before first allowing for discovery; and (3) the State Board retained primary jurisdiction as to the underlying commensurate funding issues in dispute, and after discovery before the circuit court is concluded, it will be appropriate for the circuit court to enter a more definite order staying proceedings for review of those issues before the State Board. View "Monarch Academy Baltimore Campus, Inc. v. Baltimore City Board of School Commissioners" on Justia Law

The application of Georgia law concerning a pollution exclusion contained in an insurance policy as excluding coverage for bodily injuries resulting from the ingestion of lead-based paint under the principle of lex loci contractus does not violate Maryland public policy.Appellants were exposed to lead-based paint at a property owned by the Salvation Army. Appellants sued Defendants, alleging lead-based paint related tort claims. Liberty Mutual Insurance Company issued comprehensive general liability insurance policies to the Salvation Army. The policies, which were purchased in Georgia, did not include lead-based paint exclusion provisions but did include pollution exclusion provisions. Appellants sought affirmation that Liberty Mutual was obligated to indemnify the Salvation Army and defend against Appellants’ claims. Liberty Mutual moved to dismiss the complaint, arguing that Maryland courts follow the doctrine of lex loci contracts in choosing the applicable law and that, under Georgia law, the insurance policy did not cover claims for lead-based paint poisoning. The Supreme Court held that application of Georgia law concerning the policy’s pollution exclusion under the principle of lex loci contracts does not violate Maryland public policy. View "Brownlee v. Liberty Mutual Fire Insurance Co." on Justia Law