Justia Maryland Supreme Court Opinion Summaries

Appellants brought this action just weeks before the 2016 general election seeking to compel the State Board of Elections and the Baltimore City Board of Elections (collectively, Appellees) to establish a special system for “inmate voting” in the City for the general election. The circuit court denied the request for a broadly worded temporary restraining order (TRO), concluding that the complaint had been untimely filed. One day before the 2016 general election, the expedited appeal was argued before the Court of Appeals. The Court of Appeals dismissed the appeal as moot, holding that even if the Court were to find that Appellants were entitled to a TRO with respect to the 2016 general election, there was no way such an order could have been implemented as a practical matter. View "Voters Organized for the Integrity of City Elections v. Baltimore City Board of Elections" on Justia Law

At issue in this case was whether an insured may receive personal injury protection (PIP) coverage under a personal motor vehicle liability insurance policy for injuries sustained while driving a taxicab owned by the insured but not covered by the personal motor vehicle liability insurance policy where the policy contains an exclusion for motor vehicles owned but not insured under the policy. The Maryland Insurance Commissioner concluded that the insurer’s denial of coverage was unlawful in this case. The circuit court reversed. The Court of Special Appeals affirmed the judgment of the circuit court. The Court of Appeals affirmed, holding that an insurer of a personal motor vehicle liability insurance policy, which includes PIP coverage, is not responsible, as a result of the application of the personal motor vehicle liability insurance policy’s owned but not insured exclusion, for PIP coverage for injuries the insured sustained while driving a taxicab owned by the insured but not covered by the personal motor vehicle liability insurance policy. View "Maryland Insurance Administration v. State Farm Mutual Automobile Insurance Co." on Justia Law

This suit arose from the actions of iStar’s Board of Directors in modifying performance-based executive compensation awards, which were granted in the form of stock. Petitioners filed suit against current and former members of iStar’s Board and senior management, alleging breach of fiduciary duty, unjust enrichment, waste of corporate assets, breach of contract, and promissory estoppel. The circuit court dismissed all of Petitioners’ claims for failure to state a claim upon which relief can be granted. The Court of Special Appeals affirmed. The Court of Appeals affirmed, holding (1) Petitioners’ claims were properly dismissed by the circuit court for failure to overcome the business judgment rule presumption; and (2) furthermore, Petitioners’ claims for breach of contract and promissory estoppel are derivative claims that are subject to the business judgment rule. View "Oliveira v. Sugarman" on Justia Law

Defendant was charged with two counts of first-degree murder. The police obtained DNA samples from the crime scene. The DNA analysis was conducted in accordance with the FBI’s Quality Assurance Standards. Prior to trial, Defendant filed a motion in limine to exclude the State’s DNA evidence and related expert testimony, arguing that the evidence was not admissible because the analysis was not performed in accordance with standards established by one of the two entities named in Md. Code Ann. Cts. & Jud. Proc. (CJP) 10-915 and because the methods of analysis that were used are not generally accepted as reliable under Frye-Reed. The trial court and Court of Special Appeals held (1) the DNA evidence did not qualify for automatic admissibility under section 10-915; but (2) the evidence was nonetheless admissible under Frye-Reed. The Court of Appeals affirmed, holding (1) the DNA evidence was automatically admissible under CJP 10-915; and (2) therefore, the trial court should not have conducted a Frye-Reed hearing to determine its admissibility, but the error was harmless because the trial court ultimately reached the correct conclusion that the DNA evidence was admissible. View "Phillips v. State" on Justia Law

Before October 1, 2014, under Maryland law, possession of less than ten grams of marijuana was a misdemeanor that carried a maximum penalty of ninety days of incarceration and a fine of $500. As of that date, possession of less than ten grams of marijuana became a civil offense punishable by participation in a drug education program, an assessment for substance abuse disorder, possible substance abuse treatment, and a fine. In separate cases, each of three petitioners moved to suppress evidence that had been found in a vehicle that he had been driving or had possession of, arguing that, due to decriminalization of possession of less than ten grams of marijuana, a law enforcement officer no longer has probable cause to search a vehicle when the officer detects an order of marijuana emanating from the vehicle. The circuit court denied the motion to suppress in each case. The Court of Special Appeals affirmed. The Court of Appeals affirmed, holding (1) notwithstanding the decriminalization of less than ten grams of marijuana, marijuana remains contraband, and the order of marijuana gives rise to probable cause to believe that the vehicle contains contraband or evidence of a crime; and (2) there was probable cause to search the vehicles in question in this case. View "Robinson, Williams & Spriggs v. State" on Justia Law

Through Chapter 35 of the 2016 Laws of Maryland, the General Assembly amended Md. Code Ann., Educ. 3-110(b), which governs the School Board Nominating Commission of Anne Arundel County, to eliminate the ability of the Governor to appoint members to the Nominating Commission. The amendment changed the Nominating Commission to a body that is comprised of members who are appointed by various specific entities other than the Governor. Four of the five gubernatorial appointees filed suit contending that the General Assembly unconstitutionally removed them from their positions as members of the Nominating Commission. The circuit court agreed and issued a preliminary injunction against implementation and enforcement of Chapter 35, concluding that Chapter 35 violates Article II, Section 15 of the Maryland Constitution and Article 8 of the Declaration of Rights. The Court of Appeals reversed, holding that the circuit court erred in issuing the preliminary injunction because Chapter 35 is not unconstitutional but, rather, restructures or reconstitutes the Nominating Commission. View "State v. Falcon" on Justia Law

Dominion Cove Point LNG, LP, the owner and operator of a liquefied natural gas (LNG) terminal, applied to FERC and the Maryland Public Service Commission (PSC) for authorization to expand the terminal into a facility that could both import and export LNG. Because the expansion project included the proposed construction of a 130-megawatt electric generating station, PSC approval, through the grant of a Certificate of Public Convenience and Necessity (CPCN), was required. Petitioner, a consortium dedicated to protecting local waterways, was allowed to intervene in the proceeding to oppose Dominion’s application. PSC granted the CPCN subject to approximately 200 conditions. The circuit court and court of special appeals affirmed. The Court of Appeals affirmed, holding (1) two of the conditions imposed by PSC in its grant of the CPCN did not constitute taxes or mandatory payments; (2) Petitioner’s argument that PCS’s alleged failure to identify the value it assigned to positive economic value in favor of the CPCN prevented Petitioner from effectively challenging the PSC decision was without merit; and (3) PSC’s valuation of the economic benefit created by the generating station was supported by substantial evidence in the record. View "Accokeek, Mattawoman, Piscataway Creeks Community Council, Inc. v. Public Service Commission" on Justia Law

After a jury trial, Roderick Colvin was convicted of felony murder and other crimes. Colvin later filed a motion to correct an illegal sentence pursuant to Maryland Rule 4-345(a). In this motion Colvin argued, for the first time, that the verdicts supporting his convictions were not unanimous, in violation of Maryland Rule 4-327(a), because the jury foreperson was not polled individually after she announced the jury’s verdicts. The circuit court denied the motion, determining, as a preliminary matter, that the alleged defect in the polling process was not a cognizable claim under Maryland Rule 4-345(a). The court of special appeals affirmed, ruling that the claim was cognizable but failed on its merits. The Court of Appeals vacated the judgment of the court of special appeals, holding that the procedural error alleged in this case did not come within the narrow meaning of Rule 4-345(a) and, therefore, was not a cognizable claim under the rule. View "Colvin v. State" on Justia Law

After a jury trial, Defendant was convicted of attempted second-degree murder and other offenses. Defendant appealed his conviction of attempted second-degree murder, challenging the trial judge’s finding that defense counsel’s explanations for striking jurors were a pretext for racial discrimination. The Court of Special Appeals affirmed. The Court of Appeals reversed, holding (1) the trial judge’s finding that defense counsel’s peremptory challenges were a pretext for racial discrimination was clearly erroneous; and (2) the evidence was insufficient for a rational trier of fact to find beyond a reasonable doubt specific intent for the crime of attempted second-degree murder. Remanded for a new trial as to all remaining counts except for the count charging attempted second-degree murder. View "Spencer v. State" on Justia Law

Under the rent escrow statute, if a tenant is successful in showing that a landlord was aware of certain conditions or defects in the rental property and failed to correct them, the tenant may be entitled to an abatement or reduction of the rent or other relief. Landlord in this case filed a summary ejectment action against Tenant to collect unpaid rent and to regain possession of the unit. During trial, Tenant attempted to submit evidence of alleged defects in the rental property. The circuit court declined to accept the proffered evidence, concluding that it would be relevant only in an affirmative rent escrow action, which, according to the court, must be filed as a separate action. The circuit court proceeded to enter judgment in favor of Landlord. The Court of Appeals vacated the judgment, holding that Tenant could present her evidence and contentions under the rent escrow statute in defense of the summary ejectment action brought by Landlord and was not required to present them in a separate action. Remanded. View "Cane v. EZ Rentals" on Justia Law