Justia Maryland Supreme Court Opinion Summaries

At issue before the Court of Appeals was whether - without ruling out other possible causes of exposure - the fact that property tested positive for lead-based paint throughout its interior in 1976, combined with other circumstantial evidence, was sufficient for Plaintiff to establish that the subject property was a “reasonably probable source” of his lead poisoning. Plaintiff claimed that he was poisoned by lead-based paint as a toddler when he lived in a row house owned by Respondent during 1996 and 1997. The trial court granted Respondent’s motion for summary judgment on source and source causation. The Court of Special Appeals affirmed. The Court of Appeals reversed, holding that Plaintiff presented sufficient circumstantial evidence to demonstrate that the subject property was a reasonably probable source of his elevated blood lead levels, and therefore, the trial court erred in granting summary judgment on the issues of source and source causation. View "Rogers v. Home Equity USA, Inc." on Justia Law

Petitioner made several public records requests under the Maryland Public Information Act (PIA) to the police department of Anne Arundel County, ultimately seeking “any and all” records related to one of the County’s police officers. Dissatisfied with the handling of his requests, Petitioner filed at least two lawsuits under the PIA against the County that resulted in numerous rulings in the circuit court. As a result of the circuit court’s rulings, Petitioner obtained several records that the County had not found in its initial searches in response to Petitioner’s request or had initially withheld as privileged. The circuit court concluded that the circuit court had committed “knowing and willful” violations of the PIA but declined to grant Petitioner the injunctive relief or damages he sought. The Court of Special Appeals affirmed. The Court of Appeals affirmed, holding that there was not clear and convincing evidence of any knowing and willful violations of the PIA, and therefore, Petitioner was not entitled to the relief he sought. View "Glass v. Anne Arundel County" on Justia Law

Appellant was convicted of attempted first-degree rape, third-degree sexual offense, and second-degree sexual offense. Appellant was sentenced to life imprisonment for the rape offense. Appellant later filed a petition for post-conviction DNA testing, asserting that there was a reasonable probability that DNA testing of the requested items had the scientific potential to produce exculpatory evidence relevant to his claim of wrongful conviction. The post-conviction court denied Appellant’s petition for DNA testing after conducting a hearing. The Court of Appeals reversed, holding (1) the hearing judge erred in applying a more stringent standard that would require Appellant to show that the DNA testing he sought would exonerate him; and (2) Appellant established that DNA testing was warranted in light of the proper standard. View "Edwards v. State" on Justia Law

Evidence of non-party negligence was properly admitted in this case.Petitioners alleged that John S. Park, M.D. was negligent when he interpreted radiological images, leading to Lance Copsey’s fatal stroke. Petitioners originally sued Dr. Park and three subsequent treating physicians but partially settled their claims and dismissed the subsequent treating physicians. The jury returned a verdict in favor of Dr. Park. On appeal, Petitioners argued that the trial court abused its discretion in denying their motions in limine opposing the admission of evidence regarding the non-parties’ statuses as former defendants and Dr. Park’s defense that the negligence of the subsequent treating physicians was an intervening and superseding cause of Copsey’s death. The Court of Special Appeals affirmed, concluding that the motions in limine were properly denied because Martinez ex rel. Fielding v. Johns Hopkins Hops, 70 A.3d 397 (2013) permits the introduction into evidence of non-party negligence and causation. The Court of Appeals affirmed, holding (1) evidence of non-party negligence was relevant and necessary in providing Dr. Park a fair trial; and (2) causation was an issue for the trier of fact, and the evidence tended to show that Dr. Park was not negligent and that other independent causes contributed to Copsey’s death. View "Copsey v. Park" on Justia Law

Jayson Master sought access to a lease between Calvert Tract, LLC and Whole Foods. Calvert Tract had earlier voluntarily provided a redacted version of the lease to Prince George’s County while its zoning application was pending. The County denied Master’s request seeking access to the lease, explaining that the lease was not subject to disclosure under the Maryland Public Information Act (MPIA). Master then filed a complaint seeking access to the lease. The trial court granted summary judgment to Calvert Tract and the County, concluding that the lease was confidential commercial information and therefore was exempt under the MPIA. The Court of Special Appeals affirmed. The Court of Appeals vacated the judgment of the Court of Special Appeals, holding that the trial court erred in granting summary judgment on the grounds that the lease was protected from disclosure under the MPIA’s confidential commercial information exemption. View "Amster v. Baker" on Justia Law

Darrell Ellis filed criminal charges against Andrew Baker for an incident involving a shoot-out. Baker then filed criminal charges against Ellis for an alleged assault that occurred two days later. At Baker’s trial for allegedy assaulting Ellis, it was discovered that Ellis’ defense counsel for the charges related to the second incident was related to the assistant state’s attorney who was prosecuting Baker for the charges stemming from the first incident. Upon learning this information, the trial court declared a mistrial over Baker’s objection. Baker filed a motion to dismiss his indictments on grounds of double jeopardy. The trial court denied the motion. The Court of Special Appeals reversed and ordered the indictments be dismissed. The Court of Appeals affirmed, holding that retrial of Baker was barred by double jeopardy principles because the trial court’s declaration of a mistrial over Baker’s objection was not supported by manifest necessity. View "State v. Baker" on Justia Law

The circuit court erred in dismissing the minor Appellant’s wrongful death claims as untimely and erred in failing to consider that the time limitation to file a wrongful death action is tolled when the defendant engages in fraudulent conduct that prevents the plaintiffs from bringing a wrongful death action within three years from the date of death, pursuant to Md. Code Cts. & Jud. Proc. 5-203.Cassandra Parker, Craig Parker’s mother, and Craig’s five-year-old child filed a complaint against William Hamilton alleging that Hamilton killed Craig and buried Craig’s remains in order to conceal his wrongdoing. The circuit court granted Hamilton’s motion to dismiss as to the wrongful death claims, concluding that they were time-barred under Md. Code Cts. & Jud. Proc. 3-904. The Court of Appeals reversed, holding that both Md. Code Cts. & Jud. Proc. 5-201, which operates to toll a minor plaintiff’s wrongful death claims during the period of his or her minority, and section 5-203. View "Parker v. Hamilton" on Justia Law

Three of four siblings who were beneficiaries under an irrevocable trust attempted to remove the fourth sibling as a beneficiary by relying on a provision of the irrevocable trust that permitted seventy-five percent of the beneficiaries to amend the terms of the trust. The Court of Appeals held (1) the plain language of the modification provision granting the modification authority to the beneficiaries of the irrevocable trust does not grant authority for three beneficiaries of the trust to remove the fourth beneficiary; (2) the trust clearly manifests the settlor’s intent for the trust to benefit the four beneficiaries equally; and (3) therefore, the amendment in which the three beneficiaries purported to divest the fourth beneficiary was impermissible under the terms of the trust. View "Vito v. Grueff" on Justia Law

After a jury trial, Petitioner was acquitted of murder in the first degree but convicted of murder in the second degree. The circuit court granted Petitioner’s motion for a new trial. After the State rested its case during the second trial, the trial judge declared a mistrial and discharged the jury. The case was rescheduled. Petitioner then filed a motion to dismiss the indictment on grounds of double jeopardy. After hearing arguments, the judge struck his previous grant of a mistrial and granted Petitioner’s previously-filed motion for judgment of acquittal, thus dismissing the second-degree murder charge against Petitioner based on insufficiency of the evidence. The State subsequently reindicted Petitioner for second-degree murder. Upon Petitioner’s motion, the trial judge dismissed the indictment. The Court of Appeals reversed, concluding that principles of double jeopardy did not bar Petitioner’s retrial because the trial court could not acquit Petitioner after declaring a mistrial and discharging the jury. The Court of Appeals affirmed, holding that the trial judge acted without authority in acquitting Petitioner weeks after he had declared a mistrial and discharged the jury. View "Johnson v. State" on Justia Law

In 1993, Respondent was convicted of two counts of felony murder and other crimes. Respondent was sentenced to life without parole for the murders. Twenty-one years later, a trial witness alleged that he “lied” during Respondent’s trial when he identified Respondent as the individual who shot the victims. Thereafter, Respondent filed a pro se petition for writ of actual innocence under Md. Code Ann. Crim. Proc. 8-301, alleging that the recantation constituted “newly discovered evidence.” The circuit court denied the petition. The Court of Special Appeals reversed. The Court of Appeals vacated the judgment of the Court of Special Appeals and remanded the case to the circuit court for further proceedings, holding (1) a petition that fails to include an averment of innocence but otherwise complies with the pleading requirements contained in Maryland Rule 4-332(d) may be amended if the circuit court determines that allowing an amendment would do substantial justice; and (2) Petitioner alleged sufficient “newly discovered evidence” that could create a “substantial of significant possibility” that his original trial may have been different and was therefore entitled to a hearing under Md. Code Ann. Crim. Proc. 8-301(e)(1). View "State v. Ebb" on Justia Law