Justia Maryland Supreme Court Opinion Summaries

While living in Maryland, Petitioner opened a personal line of credit and a credit card account with Respondent. Respondent later filed two complaints against Petitioner in a Maryland district court, one for the outstanding balance on the credit card account and the other for the amount owed on the line of credit. At the time of the filings, Petitioner was living and working in Texas. Respondent was awarded default judgments. Respondent subsequently secured two writs of garnishment in the same actions from the district court. The writs were served on the resident agent of Petitioner’s employer. Petitioner moved to quash the writs, arguing that his wages earned solely for work he performed in Texas were not subject to garnishment in Maryland. The district court denied the motions to quash. The Court of Appeals affirmed, holding that the district court in its continuing and ancillary jurisdiction properly ordered Petitioner’s wages earned in Texas to be subject to garnishment served upon Petitioner’s employer because of the employer’s continuous and systematic business in Maryland. View "Mensah v. MCT Fed. Credit Union" on Justia Law

The complaint in this case was brought both individually and as a class action. Plaintiffs, a police union and others, asserted that Montgomery County, a charter county, was not authorized to use its fiscal and human resources to urge approval of a law enacted by the County Council that limited bargaining rights and that had been petitioned to referendum. The circuit court concluded that the government speech doctrine does not constitute an affirmative authority for government to advocate and spend money on political campaigns. The Court of Special Appeals, however, concluded that the County had inherent power to use properly appropriated funds for a governmental purpose and that advocacy on the non-partisan ballot measure was a governmental purpose. The Court of Appeals agreed, holding that a charter county is authorized to use its resources to encourage the electorate of the County to support or opposed a measure that may have a significant impact on the operations of the County government. View "Fraternal Order of Police v. Montgomery County" on Justia Law

Defendant was charged with first degree murder and attempted first degree murder. While there was no dispute that Defendant shot the victim, his defense was that he acted in self-defense and did not intend to hit anyone. During jury deliberations, the trial judge gave a supplemental jury instruction on transferred intent after the jury asked, “We are confused on the term ‘intent.’ Does it mean to kill a person or the specific person. Can you please clarify? Thank you.” The jury convicted Defendant of the charges. Defendant appealed, arguing that the supplemental instruction on transferred intent was not generated by the evidence and introduced an entirely new theory of the case that was prejudicial to him. The Court of Appeals affirmed the judgment of the circuit court, holding that the trial judge did not abuse his discretion in giving the supplemental instruction because the evidence generated the instruction, and the instruction did not prejudice Defendant. View "State v. Bircher" on Justia Law

After a joint jury trial, Petitioner was found guilty of second degree murder, conspiracy to commit murder, and use of a handgun in the commission of a crime of violence. The court of special appeals affirmed. Petitioners filed a petition for writ of certiorari, arguing that the prosecutor’s response to an allegation of racial and gender discrimination in the exercise of a peremptory challenge did not satisfy the requirement of Batson v. Kentucky that the State provide a specific explanation for each challenged strike which is racially, and with respect to gender, neutral. The Court of Appeals reversed, holding that the prosecutor’s explanation for striking the juror at issue, in addition to lacking the requisite specificity, violated Batson because the explanation was neither race- nor gender-neutral. Remanded for a new trial. View "Ray-Simmons v. State" on Justia Law

In 2012, the Maryland Department of Health and Mental Hygiene (DHMH) adopted new procedures regarding the application process for surgical abortion facilities, including the requirement that individuals and other entities obtain a license from the Secretary of DHMH before establishing or operating such a facility. In 2013, Petitioner, pursuant to the Public Information Act, requested the records of all applications submitted for a license under these regulations. DHMH responded by providing copies of the applications but with certain information redacted. DMHM filed a petition seeking judicial confirmation for its continued denial of the information. The circuit court granted the petition, indicating that DHMH’s decision to redact was made on the basis of public safety concerns for those individuals who proposed to operate the facilities. The court of special appeals affirmed. The Court of Appeals affirmed, holding that redaction and denial of the relevant information in this case was necessary to protect the public interest from a substantial injury. View "Glenn v. Dep’t of Health & Mental Hygiene" on Justia Law

Respondent decided not to renew the lease of Petitioner, a tenant in an apartment building, and filed a tenant holding over action. Petitioner argued that the non-renewal and tenant holding over action were in retaliation for her advocation on behalf of the apartment building’s tenants association. The circuit court ruled in Petitioner’s favor on the question of retaliation but awarded damages for only one of the two alleged acts of retaliation. Specifically, the court found that Petitioner failed to prove that she was current on the rent at the time that she filed her tenant holding over action. The circuit court also declined to award attorneys’ fees to Petitioner. The Court of Appeals affirmed in part and reversed in part, holding (1) Petitioner was not ineligible for relief as to the second alleged act of retaliation, as Petitioner’s debts to Respondent other than her fixed monthly amount specified as “rent” in her lease did not factor into whether she was current on the rent for purposes of the anti-retaliation statute; and (2) the circuit court erred in refusing to grant attorney fees without permitting Petitioner an opportunity to submit evidence concerning her entitlement to attorneys’ fees and without explaining how it chose to exercise its discretion. View "Lockett v. Blue Ocean Bristol, LLC" on Justia Law

Defendants were indicted for possession of a controlled dangerous substance, intent to distribute a controlled dangerous substance, and possession of a firearm with a nexus to drug trafficking. Defendants moved for judgment of acquittal, arguing that the evidence did not sufficiently connect them to the drugs and firearm because there were multiple people in the apartment where the incriminating evidence was discovered. The trial court denied the motions, and the jury returned a verdict of guilty on all four counts with respect to both Defendants. The Court of Special Appeals reversed, concluding that the State failed to prove that Defendants had possession of the cocaine and handgun. The Court of Appeals reversed, holding that the evidence adduced at trial was sufficient to establish that Defendants had joint constructive possession of the drugs and handgun found in the apartment. View "State v. Gutierrez" on Justia Law

At issue in this case was whether an order granting a petition for writ of actual innocence constitutes a final judgment such that the State can appeal it directly. Petitioner here filed a petition for writ of actual innocence in the circuit court. The circuit court granted Petitioner a new trial on the basis of newly discovered evidence. The State filed a notice of appeal. Petitioner moved to dismiss, citing the State’s limited statutory authority to appeal. The Court of Special Appeals denied Petitioner’s motion to dismiss, ruling that the State can appeal an order granting a petition for writ of actual innocence. The Supreme Court reversed, holding that the State does not have the right to appeal a circuit court decision granting a writ of actual innocence under Md. Code Ann. Crim. Proc. 8-301. View "Seward v. State" on Justia Law

Defendant pleaded guilty to a third degree sexual offense. Defendant was sentenced to one year incarceration and was required to register as a sex offender. Six years later, Defendant petitioned for a writ of actual innocence, alleging newly discovered evidence. The circuit court denied the petition on the merits. The intermediate appellate court affirmed, holding that a writ of actual innocence does not apply to a guilty plea. The Court of Appeals affirmed, holding that a person who has pled guilty may not later avail himself or herself of the relief afforded by a petition for a writ of actual innocence. View "Yonga v. State" on Justia Law

At issue in this case were two parcels of land in the Emerald Hills Subdivision called the Triangular Parcel and Parcel 765. In 2009, the owners of Parcel 765 began construction of a paved driveway on the Triangular Parcel to access a public street. The Emerald Hills Homeowners’ Association filed suit, seeking compensatory damages, injunctive relief, and a declaratory judgment that the Triangular Parcel was not subject to an easement for the benefit of Parcel 765. The circuit court granted summary judgment in favor of the Association. The Court of Special Appeals reversed, ruling that the Subdivision Plat established an express easement over the Triangular Parcel in favor of Parcel 765 and that a Cross Easement Agreement executed in 2001 by the developer of the Emerald Hills Subdivision had no effect on this easement. The Court of Appeals affirmed, holding (1) the Subdivision Plat for Emerald Hills established an express easement; and (2) the Cross Easement Agreement did not extinguish any easement attached to Parcel 765. View "Emerald Hills Homeowners’ Ass’n, Inc. v. Peters" on Justia Law