Justia Maryland Supreme Court Opinion Summaries

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

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