Justia Maryland Supreme Court Opinion Summaries

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

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