Justia Maryland Supreme Court Opinion Summaries
Yuan v. Johns Hopkins University
Petitioner, a former researcher employed by Johns Hopkins University School of Medicine (JHU), filed suit against JHU alleging (1) he was wrongfully terminated in retaliation for his repeated protests of research misconduct in violation of 42 U.S.C. 289b and 42 C.F.R. 93; and (2) conversion because after the termination of his employment, he was denied access to stored research materials he had collected. The circuit court granted JHU’s motion to dismiss because Petitioner failed to identify a public policy exception to the at-will employment doctrine and because JHU “could not have converted what it in fact had ownership of.” The Court of Special Appeals affirmed. The Court of Appeals affirmed, holding (1) Plaintiff was not wrongfully terminated, and his at-will employment came to an end due to the expiration of his employment contract; and (2) Plaintiff’s claim of conversion must fail because JHU owned the research materials pursuant to its stated policies. View "Yuan v. Johns Hopkins University" on Justia Law
Breck v. Maryland State Police
Under Md. Code Ann. Pub. Safety, 3-103(b), Maryland law enforcement agencies may not prohibit law enforcement officers from working secondary employment. Petitioner, a former employee of the Maryland State Police Department (MSP), began working overtime in a law enforcement capacity securing National Security Agency (NSA) facilities pursuant to an agreement between MSP and NSA. The next year, MSP informed Petitioner that she could no longer work overtime at NSA. Petitioner brought a show cause action, alleging a violation of section 3-103(b)(1). MSP argued, in response, that troopers who work overtime at NSA are not engaged in “secondary employment” as that term is used in the statute but, rather, “on duty overtime.” The circuit court dismissed the action. The Court of Special Appeals affirmed. The Court of Appeals affirmed, holding that the Court of Special Appeals did not err in ruling (1) that Petitioner’s work at NSA was on-duty overtime work rather than secondary employment protected by section 3-103(b); and (2) that MSP did not take punitive action in prohibiting Petitioner from working at NSA. View "Breck v. Maryland State Police" on Justia Law
Posted in:
Labor & Employment Law
Spaw, LLC v. City of Annapolis
Petitioner, a Delaware limited liability company, owned and managed an apartment building in the City of Annapolis, Maryland that was within the designated historic district under the City’s zoning ordinance. The Annapolis Historic Preservation Commission issued two historic preservation municipal infraction citations to Petitioner. Petitioner requested a trial, and the district court found in favor of the City. In a de novo appeal, the circuit court entered summary judgment in favor the City after Petitioner admitted to replacing historic wood windows with vinyl windows without the Commission’s approval. Thereafter, Petitioner filed a petition for a writ of certiorari, alleging several claims of error. The Court of Appeals affirmed, holding (1) historic preservation municipal citations are civil and, in this case, were not barred by laches or the relevant statute of limitations; (2) the citations in this case were sufficient to give Petitioner adequate notice of its violations, and the circuit court’s judgment was not clearly erroneous; and (3) the circuit court did not abuse its discretion by denying Petitioner’s motion for a new trial or, in the alternative, to amend the judgment. View "Spaw, LLC v. City of Annapolis" on Justia Law
Hartman v. State
Petitioner pled guilty to theft in exchange for the State’s recommendation that she receive no executed jail time. The district court did not follow the State’s recommendation and instead imposed a sentence of thirty days’ incarceration. Petitioner filed a de novo appeal to the circuit court and entered a plea of not guilty. The State subsequently offered a new plea agreement whereby, in exchange for Petitioner’s guilty plea, the State would recommend Petitioner receive thirty days’ incarceration. Petitioner filed a motion to enforce the plea agreement in the circuit court, contending that the state violated the terms of the district court plea agreement by altering its sentencing recommendation. The circuit court denied the motion, concluding that on de novo appeal, the district court plea agreement was no longer enforceable. The Court of Appeals affirmed, holding that the district court plea agreement did not extend to the de novo circuit court proceeding. View "Hartman v. State" on Justia Law
Posted in:
Contracts, Criminal Law
State v. Bey
After a jury trial, Defendant was convicted on seventeen various counts, resulting in a cumulative sentence of 390 years imprisonment. The Court of Special Appeals affirmed Defendant’s convictions but vacated his sentences, determining that Md. Code Ann., Crim. Law 3-315 prohibits multiple convictions and sentences per victim, regardless of the duration of the abuse or the type of sexual acts committed. The Court of Appeals affirmed, holding (1) the plain language of the statute prohibits a defendant from being convicted and sentenced for each type of prohibited sexual act as a separate unit of prosecution; and (2) the statute is ambiguous regarding whether a defendant may be convicted and sentenced for multiple uninterrupted ninety-day minimum intervals of a continuing course of conduct, and therefore, the rule of lenity applies to bar multiple punishments. View "State v. Bey" on Justia Law
Posted in:
Criminal Law
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