Justia Maryland Supreme Court Opinion Summaries

The Supreme Court affirmed in part and reversed in part the decision of the appellate court reversing the judgment of the circuit court granting Defendants' motion to dismiss this case for failure to state a claim upon which relief may be granted, holding that the appellate court erred in finding that Plaintiff's complaint alleged sufficient facts to state a cause of each for counts two and three.Plaintiff, a minority stockholder in a family-owned corporation, brought this action alleging one count of stockholder oppression seeking equitable relief short of dissolution (count one) and compensatory damages for claims of breach of fiduciary duty (count two) and unjust enrichment (count three). The circuit court granted Defendants' motion to dismiss, thereby denying Plaintiff's request for leave to amend the complaint. The appellate court reversed the judgment in its entirety. The Supreme Court affirmed as to count one and reversed as to the remaining counts, holding that Plaintiff's proposed amended complaint set forth sufficient facts to state a claim for stockholder oppression but did not allege sufficient facts to support Plaintiff's direct causes of action for breach of fiduciary duty and unjust enrichment. View "Eastland Food Corp. v. Mekhaya" on Justia Law

The Supreme Court held that Maryland law allows spouse to allocate martial assets in a postnuptial agreement based on whether a spouse engaged in adultery, thereby causing the breakdown of the marriage, thus affirming the judgment of the lower courts.Plaintiff filed a complaint for absolute divorce on the grounds of adultery, requesting that the circuit court incorporate the parties' postnuptial agreement into the decree. The agreement included a $7 million lump sum provision that triggered if Defendant engaged in adultery. The circuit court determined that the lump sum provision was an enforceable penalty and issued a judgment of divorce that incorporated, but did not merge, the agreement. The appellate court affirmed. The Supreme Court affirmed, holding (1) the public policy in Maryland supports intefspousal distributions of marital assets based on adultery in postnuptial agreements; and (2) Plaintiff was entitled to no more than Defendant's "50% share of the Column B Assets." View "Lloyd v. Niceta" on Justia Law

The Supreme Court affirmed the decision of the appellate court affirming the circuit court's grant of summary judgment in favor of Defendant in this action brought under the Maryland Health Care Worker Whistleblower Protection Act (the Act), Md. Code Ann., Health Occ. (HO) 1-501 through 1-506, holding that Plaintiff was not entitled to relief on her allegations of error.Specifically, the Supreme Court held (1) the lower court did not err by requiring Plaintiff to show that the protected conduct was the but-for cause of the challenged personnel action; (2) a plaintiff may avail herself of the burden-shifting framework established by McDonnell Douglas to prove but-for causation; (3) Plaintiff failed to genuinely dispute Defendant's evidence that she was terminated for reasons unrelated to her alleged protected disclosure; and (4) the circuit court did not err by granting judgment to Defendant as a matter of law. View "Romeka v. RadAmerica II, LLC" on Justia Law

In this professional malpractice action, the Supreme Court vacated the judgment of the appellate court reversing the summary judgment of the trial court in favor of Defendant because Plaintiff could not prove damages and remanded this case to the circuit court for further proceedings consistent with this opinion, holding that remand was required.Plaintiff, a medical and surgical practice, retained Defendant, an accounting firm, in 2013 and terminated Defendant's services in 2015. In 2018, Plaintiff sued Defendant to recover damages for lost profits. Plaintiff designated a certificated public accountant (CPA) as an expert witness, who used the "before-and-after" method to calculate Plaintiff's lost profits. In 2021, the CPA issued updated calculations reflecting "normalizing adjustments" that she had made. The trial court excluded the CPA's expert testimony based on its application of the Daubert-Rochkind factors. The appellate court reversed the trial court's exclusion of the CPA's testimony and remanded the case for further proceedings. The Supreme Court remanded the cause, holding that the trial court erred in its consideration of the normalizing adjustments as reflecting on the reliability of the CPA's methodology, as opposed to the credibility of the CPA herself. View "Katz, Abosch, Windesheim, Gersham & Freedman, P.A. v. Parkway Neuroscience & Spine Institute, LLC" on Justia Law

The Supreme Court affirmed the judgment of the post-conviction court denying Petitioner's pro se petition for post-conviction relief, holding that the post-conviction court did not err in denying the petition.Petitioner was convicted of distribution of heroin and sentencing him to eight years in prison. In his post-conviction motion, Petitioner argued that his trial counsel rendered ineffective assistance during trial and that the State had violated its Brady obligations. The post-conviction court denied relief. The appellate court certified questions of law to the Supreme Court. The Supreme Court answered (1) Defendant failed to establish that trial counsel rendered ineffective assistance by failing to move to compel production of Internal Affairs Division files; and (2) assuming, without deciding, that the State was required to disclose impeachment evidence prior to the suppression hearing, Petitioner failed to establish the Brady materiality standard. View "Blake v. State" on Justia Law

The Supreme Court held that Jacob Bennett was not barred from serving on the Harford County Council because of his employment as a schoolteacher by the Harford County Board of Education, thus reversing the contrary order and declaratory judgment of the circuit court.After Bennett was elected to the Council in the November 2022 general election a dispute arose between Bennett and Harford County concerning whether he was precluded from serving simultaneously as a member of the Council and as an employee of the Board by either section 207 of the Harford County Charter or the common law doctrine of incompatible positions. The circuit court ruled in favor of the County on the basis that the Board should be treated as a County for purposes of Charter 207. The Supreme Court reversed, holding that neither Charter 207 nor the doctrine of incompatible positions barred Bennett from simultaneously serving as a member of the Council and an employee of the Board. View "Bennett v. Harford County" on Justia Law

The Supreme Court affirmed the decision of the post-conviction court denying Defendant's petition for post-conviction relief, holding that the post-conviction court did not err in ruling that trial counsel had not rendered ineffective assistance and that the State had not violated its Brady obligations during the underlying proceedings, holding that there was no error.After a jury trial, Defendant was convicted of distribution of heroin and sentenced to eight years' imprisonment. The appellate court affirmed. Defendant later filed a pro se petition for post-conviction relief, which the post-conviction court denied. On appeal, the appellate court certified questions of law to the Supreme Court. The Supreme Court answered (1) the post-conviction court did not err in ruling that trial counsel had not rendered ineffective assistance by failing to move production of certain evidence; and (2) assuming, without deciding, that the State was required to disclose challenged impeachment evidence prior to the hearing on Defendant's motion to suppress, Defendant failed to establish the Brady materiality standard. View "Blake v. State" on Justia Law

The Supreme Court reversed the judgment of the appellate court reversing the judgment of the circuit court denying Constituents' challenge to the amendment to a zoning ordinance limiting development of housing at a private airport in Prince George's County, which allowed the airport to develop higher-density housing, holding that the ordinance survived the challenge.While the County's zoning ordinance had historically limited development of housing at the airport to low-density, single-family detached housing, the County Council amended the text of the ordinance to allow the development of higher-density housing in order to incentivize redevelopment of the airport. Constituents brought the underlying challenge, arguing that the ordinance violated Maryland's uniformity requirement, Md. Code Ann., Land Use 22-201(b)(2)(i). The circuit court denied relief, but the appellate court reversed. The Supreme Court reversed, holding (1) the ordinance did not discriminate against similarly situated parties and was adopted to further a valid public purpose; and (2) therefore, the ordinance should have survived the uniformity challenge. View "Prince George's County Council v. Concerned Citizens of Prince George's County" on Justia Law

The Supreme Court affirmed the judgment of the circuit court granting Defendant's motion to dismiss Petitioner's petition for judicial review of a decision of a hearing examiner with the Fire and Police Employees' Retirement System for the City of Baltimore denying Petitioner's request for line-of-duty disability retirement, holding that the petition was untimely.Petitioner, a police officer, sustained an injury during a car accident that occurred while he was responding to an emergency call. A copy of the hearing examiner's decision denying line-of-duty disability retirement but granting him non-line-of-duty disability retirement. At issue was whether former Chief Judge Mary Ellen Barbera's administrative tolling order issued in response to the COVID-19 pandemic applied to Defendant's case. The circuit court concluded that the extension applied only to deadlines that were tolled during the closure of the clerks' offices between March 16, 2020 and July 20, 2020. The appellate court certified the question of whether the fifteen-day extension applied to all cases whose statute of limitations and deadlines related to initiation expired between those dates. The Supreme Court answered the question in the negative, holding that the fifteen-day extension under the administrative tolling orders applied only to cases with deadlines that were suspended during the closure of the clerks' offices between the relevant dates. View "In re Hosein" on Justia Law

The Supreme Court answered three questions certified by the United States District Court for the District of Maryland in this suit brought against Catholic Relief Services-United States Conference of Catholic Bishops (CRS), which follows the teaching that marriage is between one man and one woman.The district court ruled (1) CRS violated Title VII of the Civil Rights Act of 1964 by revoking Plaintiff's dependent health insurance because he was a man married to another man; and (2) Plaintiff was entitled to summary judgment on his federal Equal Pay Act claim. The court then ordered the parties to confer and file proposed questions of law with respect to the Maryland Fair Employment Practices Act (MFEPA), Md. Code Ann., State Gov't 20-606, and the Maryland Equal Pay for Equal Work Act (MEPEWA), Md. Code Ann., Lab. & Empl. 3-304. The Supreme Court answered (1) the prohibition against discrimination on the basis of sex in MFEPA does not itself also prohibit sexual orientation discrimination, which is separately covered under MFEPA; (2) MEPEWA does not prohibit sexual orientation discrimination; and (3) MFEPA's religious entity exemption applies with respect to claims by employees who perform duties that directly future the core mission of the religious entity. View "Doe v. Catholic Relief Services" on Justia Law