Justia Maryland Supreme Court Opinion Summaries

The trial court in a second lawsuit against Defendants seeking reformation of a refinance deed of trust properly determined that the elements of res judicata and collateral estoppel were satisfied and thus barred Plaintiffs from bringing the claims.Financial Institution, the former owner of a note for a refinance mortgage loan, sued Defendants, a married couple, for reformation of the refinance deed of trust because the wife had not signed the refinance deed of trust, leaving Financial Institution unable to institute foreclose proceedings against Defendants’ property. The trial court ruled in favor of Defendants. Three years later, the current owner of the note and the title insurer of the refinance mortgage loan (collectively, Plaintiffs) sued Defendants for reformation of the refinance deed of trust. The trial court again in favor of Defendants, concluding that Plaintiffs were barred by res judicata and collateral estoppel from bringing and relitigating the claims in the second lawsuit. The Court of Appeals affirmed, holding that the trial court in the second lawsuit (1) properly declined to apply judicial estoppel to bar Defendants’ argument that Plaintiffs were in privity with Financial Institution; and (2) correctly determined that res judicata and collateral estoppel barred Plaintiffs from relitigating their claims in the second lawsuit. View "Bank of New York Mellon v. Georg" on Justia Law

Because the State’s authority to nol pros applies only to charges, the State may not use its nol pros authority to alter a final judgment such as a conviction and sentence.At issue before the Supreme Court was whether the State had the authority to enter a nol pros of a charge that resulted in a conviction and sentence. Defendant was convicted and sentenced for conspiracy to violate the controlled dangerous substance laws. Defendant appealed. Before the court of special appeals heard oral arguments, the State nol prossed the charge underlying Defendant’s conviction and sentence. The court of appeals ruled that the State lacked the authority to nol pros a charge underlying a conviction and sentence and ultimately reversed the judgment based on insufficient evidence. The Supreme Court affirmed, holding (1) after a defendant has received a final judgment in the form of a conviction and sentence, the State may not enter a nolle prosequi to alter the final judgment; and (2) the State lacked the authority in this case to nol pros in order to alter the final judgment or to eliminate the appellate process initiated by Defendant. View "State v. Simms" on Justia Law

At issue in this appeal was the Circuit Court for Baltimore City’s grant of Defendant’s motion to transfer this case to Talbot County and the proper application of the standard of appellate review to the trial court’s order pursuant to Maryland Rule 2-327(c). The hearing judge granted the motion to transfer. The court of special appeals reversed, concluding that the moving party failed to meet its burden of demonstrating that the convenience of the parties and the interests of justice supported transfer of the case. The Court of Appeals reversed, holding (1) the facts of each case will dictate whether the plaintiff’s choice of venue will control the choice of forum; and (2) the hearing judge did not abuse his discretion in balancing the convenience of the parties and interests of justice and finding that the weight of the evidence favored transfer. View "University of Maryland Medical System Corp. v. Kerrigan" on Justia Law

The law enforcement officers that stopped Defendant in this case had reasonable suspicion to conduct an investigatory stop when they witnessed what appeared to be criminal activity immediately before the stop. Alternatively, even assuming the stop was unlawful, the evidence recovered from Defendant would be admissible because the attenuation doctrine would apply.The Court of Appeals affirmed the judgment of the Court of Special Appeals to the extent that it held that the officers had reasonable suspicion to stop Defendant. Alternatively, the court affirmed the judgment of the intermediate appellate court and adopted the reasoning of the concurring opinion with respect to the application of the attenuation doctrine. Accordingly, Defendant’s motion to suppress should have been denied. View "Sizer v. State" on Justia Law

At issue was the admissibility at a child in need of assistance (CINA) proceeding of the out-of-court statement of J.J., the nine-year-old daughter of Petitioner, alleging that Petitioner had sexually abused her. The circuit court, sitting as a juvenile court, determined that J.J.’s statement should be admissible to prove the truth of the matter asserted because it possessed the requisite particularized guarantees of trustworthiness. The court of special appeals affirmed. The Court of Appeals affirmed, holding (1) Md. Code Ann. Crim. Proc. (CP) 11-304 does not require a juvenile court to determine a child’s truth competency when ruling on the admissibility of the child’s out-of-court statement; and (2) the juvenile court did not err in finding that J.J.’s out-of-court statement possessed the requisite particularized guarantees of trustworthiness required for admissibility under CP 11-304. View "In re J.J. and T.S." on Justia Law

A county may rescind its approval of a municipality’s rezoning of annexed land.The Town Commissioners of Queenstown annexed farm land adjacent to Queenstown in Queen Anne’s County and rezoned the annexed land for purposes of a planned development. The Town sought the County’s approval of the new zoning classification. The outgoing Board of County Commissioners approved the Town’s rezoning. After the November 2014 election, the newly installed Board of County Commissioners rescinded that approval. Waterman and the Town then brought this action against the County. The circuit court issued a declaratory judgment that the resolution rescinding approval had “no legal force and effect.” The Court of Special Appeals reversed. The Court of Appeals affirmed, holding that the County had authority to rescind the initial resolution approving the rezoning. View "Waterman Family Ltd. Partnership v. Boomer" on Justia Law

To be valid, a Development Rights and Responsibilities Agreement (DRRA) is not required to confer an enhanced public benefit on a county.After a DRRA was approved and recorded, Cleanwater Linganore, Inc. and other individuals and entities (collectively, Cleanwater) filed a petition for judicial review, challenging the validity of the DRRA, arguing that the DRRA was void for lack of consideration because Petitioners had failed to prove any “enhanced public benefits” as consideration. The circuit court affirmed the Frederick County Board of County Commissioner’s approval of the DRRA. The court of special appeals reversed, concluding that the DRRA was void for lack of consideration because it lacked any enhanced public benefits to Frederick County. The Court of Appeals reversed, holding that the DRRA was not required to confer any enhanced public benefit to the County and was supported by sufficient consideration. View "Lillian C. Blentlinger, LLC v. Cleanwater Linganore, Inc." on Justia Law

In this child in need of assistance (CINA) case, the Court of Appeals settled conflicting decisions from the Court of Special Appeals on the appealability of a juvenile court’s order waiving the government’s obligation to provide reasonable reunification efforts to families. The Court of Appeals issued a writ of certiorari to answer two questions. The court did not reach the second question and answered the first question by holding that the Court of Special Appeals did not err in holding that the juvenile court’s order waiving reasonable reunification efforts was not a final order and not appealable, and therefore, Petitioner had no right to an interlocutory appeal. View "In re C.E." on Justia Law

In this criminal case concerning the State’s obligation to disclose to a defendant’s counsel information regarding a State’s witness’s pretrial identification of a co-defendant and whether the State was required to make such a disclosure under the circumstances of this case, the Court of Appeals held (1) Maryland Rule 4-263(d)(7)(B), by its plain language and history, does not require disclosure of pretrial identifications of co-defendants; and (2) a pretrial identification of a co-defendant is relevant information regarding pretrial identification of the defendant under Maryland Rule 4-263(d)(7)(B) where the pretrial identification of the co-defendant is the equivalent of a pretrial identification of the defendant as the person responsible for the crime. Accordingly, in this case, the State was obligated to disclose during discovery a witness’s pretrial identification of Defendant’s co-defendant as the person who was not the shooter. View "Green v. State" on Justia Law

The suppression court did not err in denying Petitioner’s motion to suppress the images of his fifteen-year-old girlfriend that the police found while executing the warrant to search Petitioner’s cell phone because the warrant-issuing judge had a substantial basis for issuing the warrant to search Petitioner’s cell phone.Petitioner was convicted of possession of child pornography based in large part on photographs and a video of Petitioner’s girlfriend that the police found on his cell phone while executing a warrant to search it. The Court of Special Appeals affirmed the circuit court’s denial of Petitioner’s motion to suppress the photographs and video, concluding that the affidavit in support of the warrant provided a substantial basis who issued the warrant to find probable cause to search the cell phone. The Court of Appeals affirmed, holding that there was a substantial basis for the judge who issued the warrant to find probable cause that Petitioner’s cell phone contained evidence of suspected criminal behavior. View "Moats v. State" on Justia Law