Justia Maryland Supreme Court Opinion Summaries

At issue in this case were the Dabbs Class’s claims demanding refunds of impact fees collected by Anne Arundel County between fiscal years 1997-2003.Anne Arundel County imposed road and school impact fees according to County districts beginning in 1987. Those who paid impact fees might become eligible for refunds of those fees under certain circumstances. The Dabbs Class sought refunds on the ground that the impact fees at issue were not expended or encumbered in a timely manner under section 17-11-210(b) of the Anne Arundel County Code and that the amendments to the Impact Fee Ordinance in Bill No. 27-07 and Bill No. 71-08, which codified the County’s procedures for calculating capital expenditures and encumbrances and removed prospectively the refund provision provided in section 17-11-210, unconstitutionally interfered with their vested rights in refunds. The circuit court entered a declaratory judgment for the County. The intermediate appellate court affirmed. The Court of Appeals affirmed, holding that the lower courts did not err in (1) concluding that the rough proportionality test/rational nexus test of Nollan v. California Coastal Comm’n, 483 U.S. 825 (1987), and Dolan v. City of Tigard, 512 U.S. 374 (1994), did not apply; and (2) permitting the retroactive application of the legislation and not finding an unconstitutional taking. View "Dabbs v. Anne Arundel County" on Justia Law

At issue was whether victim impact evidence in the form of a video displaying more than one hundred photographs of Defendant’s victims, with accompanying music, is permissible at a sentencing hearing.Defendant entered an Alford plea to two counts of first-degree murder, one count of robbery, and one count of child kidnapping. During sentencing, Defendant moved to exclude a video with approximately 115 photographs of the two victims set to background music. The sentencing judge allowed the video to be played. The Court of Appeals held that showing the video at the sentencing hearing did not violate Defendant’s constitutional rights. Specifically, the Court held (1) a sentencing judge has discretion to permit any additional form of victim impact evidence outside the constraints of Md. Code Ann. Crim. Proc. (“CP”) 11-402 and CP 11-403; (2) all prepared victim impact evidence, not including victim impact testimony, must be limited to the content prescribed under CP 11-402(e); (3) the Eighth Amendment does not prohibit a sentencing judge from considering victim impact evidence at a defendant’s noncapital sentencing proceeding; and (4) Defendant’s Fourteenth Amendment due process rights were not violated because the disputed victim impact evidence did not inflame the passions of the sentencing judge more than the facts of the crime. View "Lopez v. State" on Justia Law

At issue was when injuries from asbestos exposure “arise” for purposes of the statute of repose, Md. Code Cts. & Jud. Proc. 5-108.James Piper filed a complaint alleging that at the time he worked in connecting a new steam turbine generator to another turbine he was unknowingly exposed to asbestos as a result of installation of insulating material that contained asbestos. The insulation was installed in 1970. Piper was diagnosed with mesothelioma in 2013. In 2014, Piper filed suit against several defendants, including Respondent, which built the major components of the turbine and constructed the turbine. The circuit court granted summary judgment for Respondent. The court of special appeals affirmed, concluding that Piper’s cause of action did not “arise” or “accrue” until 2013, and therefore, the diagnosis of mesothelioma was outside of the twenty-year limitations period set forth in the statute of repose beginning with the operation of the turbine. The Supreme Court reversed, holding (1) for purposes of asbestos-related causes of action, an injury arises at the time of last exposure to the asbestos-laden product; and (2) because the statute of repose was enacted after the date of Piper’s injuries, as a matter of law, the statute did not bar Piper’s causes of action. View "Duffy v. CBS Corp." on Justia Law

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