Justia Maryland Supreme Court Opinion Summaries

Scott was convicted of attempted robbery with a dangerous weapon, use of a handgun in the commission of a crime of violence, and conspiracy to commit robbery with a dangerous weapon. Md. Code, Crim. Law 14-101(d) provides for an enhanced sentence for a defendant who was convicted of a third crime of violence. The prosecutor offered cited Scott's first-degree assault conviction in Maryland and an aggravated assault conviction in the District of Columbia. The court imposed an enhanced sentence of 25 years for attempted robbery; a consecutive sentence of 10 years for use of a handgun; and a consecutive sentence of 10 years for conspiracy. The Court of Special Appeals vacated the 25-year sentence, concluding that the evidence was insufficient to establish that the D.C. conviction constituted a crime of violence. On remand, Scott argued that the imposition of an enhanced sentence would constitute double jeopardy. The court reimposed the enhanced sentence, with the other sentences to be served consecutively. The Maryland Court of Appeals affirmed. An appellate court's determination that the evidence was insufficient to establish a requisite prior conviction as a basis for an enhanced sentence does not preclude a trial court from determining at resentencing that the prior conviction satisfies the requirement for an enhanced sentence. Where an appellate court vacates a sentence and remands without vacating a consecutive sentence, the trial court may not make the new sentence concurrent with the non-vacated consecutive sentence. View "Scott v. State" on Justia Law

The circuit court’s order denying Appellant’s petition to compel arbitration was not a final, appealable judgment under Md. Code Ann. Cts. & Jud. Proc. 12-301.Appellees were individuals who each purchased vehicles from the automobile dealership operated by Appellant. Appellees filed a class action lawsuit against Appellant, challenging Appellant’s practice of providing customers with an alleged free lifetime limited warranty for their vehicles conditioned on the consumer’s continued use of and payment for other services provided by Appellant. Appellant filed an independent action seeking to compel arbitration in the class action case. The circuit court concluded that Appellees’ claims were not subject to binding arbitration. Appellant appealed. Appellees filed a motion to dismiss on the basis that the order denying arbitration was not an appealable final judgment. The court of special appeals denied the motion. The Court of Appeals vacated the judgment of the court of special appeals and remanded to that court with instructions to dismiss the appeal, holding that the circuit court’s order denying Appellant’s petition to compel arbitration was not a final, appealable judgment, depriving the court of special appeals of jurisdiction to hear an appeal of that order. View "Deer Automotive Group, LLC v. Brown" on Justia Law

While Md. Code. Ann. Crim. Law 10-615 does not provide for seizure of an animal that is already in state custody in connection with a criminal proceeding, an officer of a humane society may notify the animal’s owner or custodian of an intent to take possession of the animal upon the animal’s release from state custody in the criminal case, and the seizure of an animal under the statute need not occur contemporaneously with the alleged mistreatment of the animal.In this case, the humane society exercised its authority under section 10-615 to take possession of Petitioner’s animals based on allegations of animal cruelty. Petitioner unsuccessfully petitioned the district court for their return. Ultimately, the vast majority of the animal cruelty charges against Petitioner were disposed of by dismissal or acquittal, but the humane society retained possession of the animals. The Court of Appeals remanded the case in light of the change of circumstances since the district court’s initial decision, holding (1) Petitioner was not entitled to return of the animals based on the humane society’s alleged failure to comply with section 10-615; but (2) the denial of Petitioner’s petition for return of the animals did not eliminate Petitioner’s ownership interest in the animals. View "Rohrer v. Humane Society of Washington County" on Justia Law

The Maryland Condominium Act allows access to communally-held property to be restricted as a means to enforce payment of condominium fees, but such restrictions must first be authorized by the unit owners through agreement in the condominium’s declaration.In this case, a condominium association and its management firm (collectively, Elvaton) claimed that unit owners William and Dawn Rose were delinquent in paying their condominium fees. The association thus prohibited the Roses from parking in the parking lot overnight or using the pool until they paid their allegedly delinquent fees. The circuit court ruled that Elvaton did not have the authority to restrict the Roses’ use of the parkings lots and the pool as a means of collecting on the debt. The Court of Appeals affirmed. The Supreme Court affirmed, holding that because Elvaton did not include a restriction to the general common elements of the condominium as a means to enforce payment of condominium fees in the condominium’s declaration, the restriction was invalid. View "Elvaton Towne Condominium Regime II, Inc. v. Rose" on Justia Law

Between 2011 and 2013, a labor union held demonstrations at Walmart stores throughout Maryland, protesting Walmart’s employment conditions. Consequently, Walmart sued the union for trespass and nuisance and sought an injunction against the union. The circuit court granted summary judgment in favor of Walmart and issued a permanent injunction against UFCW. The court of special appeals affirmed. The Court of Appeals affirmed, holding (1) Walmart’s claims for trespass and nuisance were not preempted by the National Labor Relations Act, and therefore, the circuit court properly denied the union’s motion to dismiss; and (2) the circuit court properly ruled that this case did not involve a labor dispute within the meaning of Maryland’s Anti-Injunction Act. View "United Food & Commercial Workers International Union v. Wal-Mart Stores, Inc." on Justia Law

The Court of Special Appeals did not err in concluding that Defendant’s sentence was imposed in violation of Maryland Rule 4-243(c) because, pursuant to a plea agreement, the State did not receive what it bargained for when the judge imposed a sentence below the terms of the plea agreement. Defendant pleaded guilty to theft scheme greater than $10,000 but less than $100,000. The plea agreement provided that Defendant would be found guilty of a crime and serve jail time, but, instead, the sentence imposed did not include a finding of guilt or incarceration. The Court of Special Appeals reversed, concluding that the sentence was illegal because it was below the floor of the terms. The Court of Appeals affirmed, holding that the Court of Special Appeals did not err in holding that Defendant’s sentence was imposed in violation of Rule 4-243(c). View "Smith v. State" on Justia Law

The circuit court and Court of Special Appeals affirmed the decision of the Howard County Board of Appeals approving a conditional use application for a funeral home in Howard County’s Rural Residential-Density Exchange Option zone. The Howard County Board of Appeals hearing examiner initially denied the proposed conditional use plan, but after public hearings and two revisions, the Board approved the conditional use application subject to several conditions. The Court of Appeals affirmed, holding (1) the Board properly analyzed the revised plan pursuant to the relevant statutory requirements; (2) the Board did not err in concluding that the revised plan would not create an adverse cultural impact on vicinal properties or that such impact will be beyond those ordinarily associated with funeral home and mortuary uses; and (3) substantial evidence supported the Board’s conclusion that the revised plan contemplated a 100-foot stream buffer in compliance with state requirements. View "Clarksville Residents Against Mortuary Defense Fund, Inc. v. Donaldson Properties" on Justia Law

Appellant, who was convicted of four counts of first-degree murder and sentenced to four consecutive terms of life without the possibility of parole, appealed the circuit court’s denial of his pro se petition for DNA testing of scientific evidence, arguing that in reaching its conclusion, the circuit court applied the incorrect standard of law. The Court of Appeals affirmed, holding that Appellant was not entitled to testing under Md. Code Ann. Crim. Proc. 8-201, as (1) the hearing court erred in applying the incorrect standard of law when denying the petition; but (2) analyzed under the correct standard of law, the arguments presented by Appellant in his petition utterly failed to satisfy the requirements of section 8-201. View "Beaman v. State" on Justia Law

In 1993, the Anne Arundel county board of appeals (Board) granted Petitioner special exceptions and variances to construct and landfill and sand and gravel operations. Three extensions of time were necessary to obtain that permit. In 2011, the permit and a county building permit to construct the landfill were granted. That same year, the Board, by a vote of 2-2, denied Petitioner’s request for a further two-year extension. The circuit court vacated the Board’s decision and remanded. The court of special appeals modified the decision of the circuit court, disagreeing on the standard the Board was to apply. The Court of Appeals vacated the rulings of the lower courts with instructions to remand to the Board for further proceedings, holding that the ultimate conclusions of the denying members were arbitrary and capricious, but that did not require an outright reversal of the Board’s rejection. View "National Waste Managers, Inc. v. Forks of the Patuxent Improvement Ass’n" on Justia Law

In order to recover attorney’s fees against a negligent title searcher using the collateral litigation doctrine, the plaintiff must show that the title searcher’s negligence proximately caused the plaintiff to file a necessary collateral action, resulting in the plaintiff incurring reasonable litigation costs necessarily and in good faith, and that the plaintiff has not otherwise received compensation for those costs.The Ochses purchased property from the Henrys. The Ochses later learned that a encumbrance bisecting their lot was part of a strip of land that had been granted to Dorchester County. Prior to this discovery, the Ochses filed a lawsuit against the Henrys to quiet title. The Ochses later filed a lawsuit against Chicago Title Insurance Company and Eastern Shore Title Company (ESTC), the title examiner, alleging breach of contract and negligence. The trial court found in favor of the Ochses and awarded a $215,710 against ESTC and Chicago Title, which was the amount of the attorney’s fees awarded to the Ochses in the Henry litigation. The trial court subsequently reduced its judgment against ESTC and Chicago Title by $215,710. The Court of Appeals affirmed, holding that the trial court did not err by reducing the damages awarded to the Ochses by the amount previously satisfied by the Henrys. View "Eastern Shore Title Co. v. Ochse" on Justia Law