Justia Maryland Supreme Court Opinion Summaries
Norman v. State
At issue in this case was whether a law enforcement officer who detects an odor of marijuana emanating from a vehicle with multiple occupants has reasonable articulable suspicion that the vehicle’s occupants are armed and dangerous and thus may frisk the vehicle’s occupants for weapons. The circuit court denied Defendant’s motion to suppress in this case, concluding that the police officer that searched the vehicle in which Defendant was a passenger had reasonable articulable suspicion that Defendant was armed and dangerous. The Court of Special Appeals affirmed. The Court of Appeals reversed, holding (1) an odor of marijuana alone emanating from a vehicle with multiple occupants does not give rise to a reasonable articulable suspicion that the vehicle’s occupants are armed and dangerous and subject to frisk; and (2) at the time of the frisk in this case, there were insufficient circumstances giving rise to reasonable articulable suspicion that Defendant was armed and dangerous to justify the frisk. View "Norman v. State" on Justia Law
Brown v. State
Defendant was charged with two counts of first-degree murder and related charges. Defendant filed a motion to suppress statements he made to police during an interrogation at the police department. The circuit court granted Defendant’s motion to suppress statements Defendant made to a police officer before the officer advised Defendant of his Miranda rights. The Court of Special Appeals reversed, concluding that the suppression court had incorrectly determined that, from the outset of the interrogation, Defendant was in custody for purposes of Miranda. The Court of Appeals reversed, holding that Defendant was in custody for purposes of Miranda for the entirety of the interrogation that preceded Miranda warnings, and therefore, the circuit court properly suppressed Defendant’s statements made to the police. View "Brown v. State" on Justia Law
Cain v. Midland Funding, LLC
Lender’s assignee (Assignee), while operating as an unlicensed debt collector, obtained a judgment against a credit card debtor (Debtor) in district court. Debtor’s contract with Lender included an arbitration provision. Debtor then filed a class action suit collaterally attacking the judgment based on violations of Maryland consumer protection laws. Assignee filed a motion to arbitrate the class action suit pursuant to an arbitration clause between Lender and Debtor. Assignee moved to compel arbitration. The circuit court granted the motion to compel, thus rejecting Debtor’s argument that Assignee waived its right to arbitrate when it brought its collection action against Debtor. The Court of Special Appeals affirmed. The Court of Appeals reversed, holding that because Assignee’s collection action was related to Debtor’s claims, Assignee waived its contractual right to arbitrate Debtor’s claims when it chose to litigate the collection action. View "Cain v. Midland Funding, LLC" on Justia Law
Gupta v. State
After a jury trial, Petitioner was convicted of first-degree murder and sentenced to life imprisonment. The Court of Special Appeals affirmed. Petitioner appealed, inter alia, the denial of his motion to suppress the statements he made to police officers during his interrogation, arguing that they were obtained in violation of his Miranda right to counsel. The Court of Appeals affirmed, holding (1) the trial judge violated Maryland Rule 4-326(D)(2) by communicating an ex parte answer to a juror’s question without disclosing it to the defendant or any lawyer, but the error was harmless beyond a reasonable doubt; and (2) Petitioner did not invoke his Miranda right to counsel by demanding to see a lawyer from his holding cell before being interrogated, and therefore, the circuit court did not err in denying Petitioner’s motion to suppress the statements he made to detectives during his interrogation. View "Gupta v. State" on Justia Law
In re Cody H.
A family magistrate of the circuit court for Baltimore County found that Cody H. had committed the delinquent act of assault by punching a sixteen-year-old victim in the face and breaking his jaw. The magistrate judgment made a recommendation for a restitution award of $1,489 to the victim for medical expenses but did not award restitution for lost earnings. The State filed exceptions to the recommendation. A juvenile court judge sustained the State’s exception and imposed an additional restitution amount of $5,000 for loss of earnings. The Court of Appeals affirmed, holding that the loss of earnings restitution award in this case was proper under the restitution statute, Md. Code Ann., Crim. Proc. 11-603. View "In re Cody H." on Justia Law
Posted in:
Criminal Law, Juvenile Law
Hughes v. Moyer
The Department of Public Safety and Correctional Services (DPSCS) sent Laura Hughes a notice of termination from her position with the agency. Hughes followed the directions for invoking the first tier of the administrative appeal process. The Secretary of DPSCS did not respond within the statutory time limit, thus denying Hughes first-tier appeal. Hughes was unaware that this silent denial triggered the limited time for her to invoke a second-tier appeal, and therefore she did nothing before the deadline passed. Hughes belatedly attempted to pursue her administrative appeal, but DPSCS did not respond. Hughes then commenced this mandamus action in the circuit court. The circuit court dismissed the mandamus action. The Court of Special Appeals affirmed. The Court of Appeals reversed, holding that, in order to discharge its responsibility to provide a disciplined employee with notice of the employee’s administrative appeal rights, an agency must advise the employee of the possibility of a second-tier appeal and alert the employee as to the significance of silence in response to a first-tier appeal. Remanded for consideration whether Hughes should be afforded the opportunity to pursue a second-tier appeal. View "Hughes v. Moyer" on Justia Law
URS Corp. v. Fort Myer Construction Corp.
Maryland-National Capital Park and Planning Commission (the Commission) contracted with Fort Myer Construction Corporation to build a pedestrian bridge. After disputes arose, Fort Myer sued the Commission. The Commission impleaded URS Corporation (URS), the engineering firm that created the design documents. The circuit court eventually dismissed Fort Myer’s original complaint, but the claims between URS and the Commission went to trial. Both parties asked the court to award monetary sanctions against Fort Myer on the basis that Fort Myer had litigated its original complaint “without substantial justification.” The circuit court did so. All three parties appealed. The Court of Special Appeals reversed the circuit court’s sanctions awards. The Court of Appeals affirmed, holding (1) the intermediate appellate court properly exercised its jurisdiction to decide Fort Myer’s appeal; and (2) as for the sanctions awards against Fort Myer, the circuit court’s explanation of its reasoning did not support a finding that Fort Myer’s pursuit of its claim was “without substantial justification.” View "URS Corp. v. Fort Myer Construction Corp." on Justia Law
Posted in:
Civil Procedure, Contracts
State v. Jones
Respondent was acquitted in a jury trial of first-degree murder premeditated murder, second-degree specific intent murder, and other charges. Thereafter, the State sought to prosecute Respondent for second-degree felony murder predicated on first-degree assault. Respondent interposed a plea of double jeopardy, which was denied. The Court of Special Appeals reversed, concluding that a subsequent trial for felony murder based upon first-degree assault was barred by the Double Jeopardy Clause. The Court of Appeals affirmed but on different grounds, holding that first-degree assault may not serve as a predicate for second-degree felony murder when that assault is not collateral to the lethal act. In so holding, the Court overruled Roary v. State, which was the foundation and predicate for the State’s charge for second-degree felony murder based on first-degree assault. View "State v. Jones" on Justia Law
Posted in:
Criminal Law
In re Judge Pamela J. White
After an investigation, the Commission on Judicial Disabilities found by clear and convincing evidence that Judge Pamela J. White had committed sanctionable conduct and that a public reprimand was the appropriate disposition under the circumstances. Judge white filed with the Court of Appeals an appeal and, in the alternative, a petition for writ of certiorari, seeking to have the Court review whether the Commission had denied her procedural due process and whether the Commission had erred in finding sanctionable conduct and reprimanding her. The Commission filed a motion to dismiss. The Court ordered that the matter be set for a show cause hearing for the limited purpose of addressing whether the Court of Appeals had jurisdiction to decide whether Judge White was denied procedural due process during the Commission proceedings. The Court of Appeals entered an order holding (1) this Court has authority to consider Judge White’s arguments as to whether the Commission proceeding accorded her with the due process required by the State Constitution and the Maryland Rules; but (2) the Court was not able at this time to conduct that review. View "In re Judge Pamela J. White" on Justia Law
Posted in:
Legal Ethics
Balfour Beatty Infrastructure, Inc. v. Rummel Klepper & Kahl, LLP
The City of Baltimore contracted with Engineer to design upgrades to a wastewater treatment plant. Contractor successfully bid for work on the construction project. During construction, Contractor encountered leaking and other problems, resulting in delays and cost overruns. Contractor subsequently filed a complaint against Engineer, arguing that Engineer owed it a tort duty of care because Engineer knew that Contractor would rely on its designs in bidding and constructing the project. The circuit court granted Engineer’s motion to dismiss due to lack of privity between Contractor and Engineer. The court of special appeals affirmed. The Court of Appeals affirmed, holding (1) the economic loss doctrine barred Contractor’s negligence and negligent misrepresentation claims; and (2) privity equivalent concepts of extra-contractual duty did not apply in Contractor’s case. View "Balfour Beatty Infrastructure, Inc. v. Rummel Klepper & Kahl, LLP" on Justia Law
Posted in:
Government Contracts, Personal Injury