Justia Maryland Supreme Court Opinion Summaries

The Maryland Supreme Court granted the State’s petition for a writ of certiorari in this case to decide whether the Uniform Postconviction Procedure Act (“UPPA”) granted the Court of Special Appeals the authority to reopen a postconviction proceeding if doing so was “in the interests of justice.” The Supreme Court "easily" concluded that the UPPA did not. However, the Court of Special Appeals was statutorily authorized to review a circuit court's denial of a motion to reopen for abuse of discretion, and could remand the matter back to the circuit court with instruction to award appropriate relief if the circuit court abused that discretion. In 1978, Respondent James Leslie Adams-Bey, Jr., was convicted by a jury of first degree rape and related offenses, for which he was sentenced to life plus ten years of incarceration. Respondent petitioned unsuccessfully for postconviction relief in 2010. In 2012, Respondent moved pro se to reopen his postconviction proceedings on the ground that jurors at his criminal trial were given advisory-only instructions in violation of his constitutional rights to due process. Respondent argued that those instructions were unconstitutional because the jury was not instructed to follow the court’s explanation of the law and the court did not inform the jury of the binding nature of its instructions on the State’s burden of proof or the presumption of innocence. The circuit court denied Respondent’s motion without a hearing. On appeal of that denial, Respondent argued the circuit court abused its discretion by denying his motion to reopen. The Court of Special Appeals granted Respondent's application, and addressed the merits of his appeal, and reversed the circuit court's denial. The Supreme Court affirmed the Court of Special Appeals, finding it correctly concluded that the circuit court abused its discretion by denying Respondent's motion to reopen. View "Maryland v. Adams-Bey" on Justia Law

Petitioner was convicted of murder and related offenses arising from a failed armed robbery in 1994. Petitioner was sentenced to life imprisonment. In 2013, Petitioner filed a petition for writ of actual innocence under Md. Code Ann. Crim. Proc. 8-301, claiming newly discovered evidence in that the State’s ballistics expert falsely testified about his academic credentials at Petitioner’s trial. The circuit court concluded that Petitioner was not entitled to relief under section 8-301. The Court of Special Appeals affirmed. The Court of Appeals affirmed, holding that the hearing judge did not abuse his discretion in ruling that, under the circumstances of this case, Petitioner was unable to prove that the expert's lies about his academic credentials created a substantial or significant possibility that the outcome at trial may have been different. View "McGhie v. State" on Justia Law

The well-known author Thomas Clancy (Decedent) died in 2013. Decedent was survived by his second wife (Mrs. Clancy), a minor child by that marriage, and four adult children from Decedent’s first marriage. Decedent left a will and various amendments. At issue in this case was which beneficiaries, if any, were obligated to pay a portion or all of federal estate taxes. Mrs. Clancy petitioned in the Orphans’ Court for a declaratory judgment in which she sought a determination that a Family Trust was not obligated to pay any estate taxes. The Orphans Court concluded that Decedent’s predominant intent was that the Family Trust be free of any federal estate tax liability. The Court of Appeals affirmed, holding that the property conveyed in the Family Trust as identified in Decedent’s will and second codicil could not be burdened by the payment of federal estate taxes. View "Bandy v. Clancy" on Justia Law

After a trial, Defendant was found guilty of possession of cocaine with intent to distribute and possession of a firearm during a drug trafficking crime. Defendant appealed, arguing that the trial court erred in denying his motion to suppress evidence obtained after a Terry frisk because the law enforcement officers did not have reasonable suspicion to justify the frisk. The Court of Special Appeals affirmed the denial of the motion to suppress, concluding that the facts created reasonable suspicion that Defendant was armed and dangerous and that he had committed or was planning to commit a crime. The Court of Appeals reversed, holding that, under the totality of the circumstances, the officers did not have reasonable articulable suspicion to frisk Defendant, and therefore, the Court of Special Appeals erred in concluding that the evidence was correctly suppressed. View "Sellman v. State" on Justia Law

After a jury trial, Defendant was found guilty of, among other crimes, first-degree murder. As relevant to this appeal, the jury found Defendant not guilty of attempted robbery with a dangerous weapon and attempted robbery. Defendant filed a motion to strike, arguing that the felony murder guilty verdict was inconsistent with the acquittals of robbery and attempted robbery. The circuit court denied the motion to strike. The Court of Appeals affirmed, concluding that, by failing to object before the jury was discharged and the verdicts became final, Defendant waived any issue as to the allegedly inconsistent verdicts. The Court of Appeals affirmed, holding that, to preserve the issue of legally inconsistent verdicts for appellate review, a defendant in a criminal trial by jury must object or make known opposition to the allegedly inconsistent verdicts before the verdicts become final and the trial court discharges the jury. View "Givens v. State" on Justia Law

Defendant was indicted for several drug offenses. Defendant filed a motion to suppress evidence seized by police officers from his person, alleging that his detention in handcuffs while in a car that he had been driving was searched constituted an unlawful arrest and that the evidence obtained by the officers were the fruits of that arrest. The motion to suppress was denied. Defendant entered a conditional guilty plea to one count of possession of cocaine with intent to distribute. The Court of Appeals affirmed, holding (1) the police officers possessed reasonable suspicion to stop Defendant and ask him to leave the vehicle based upon their belief that Defendant may have been armed and dangerous; and (2) the use of handcuffs per se does not ordinarily transform a Terry stop into an arrest, and the continued use of handcuffs by the police officers in this case constituted a Terry stop because of an ongoing concern for officer safety. View "Chase v. State" on Justia Law

Baltimore County zoning regulations provide for a planned unit development (PUD) approval process that is partly legislative and partly quasi-judicial or adjudicative. Whalen Properties, LLC, the developer of a proposed PUD, submitted a PUD application to First District Councilman Thomas Quirk of Baltimore County. Thereafter, Stephen Whalen, the owner and principal of Whalen Properties, distributed $8,500 of the company’s money to several individuals with instructions that they deposit the sums into their own accounts and to donate those amounts to Councilman Quirk’s campaign committee. An adjacent landowner challenged the subsequent approval of the PUD, alleging that the appearance of impropriety generated by the donations invalidated the approval process. The circuit court and Court of Special Appeals affirmed the decision. The Court of Appeals affirmed, holding (1) because the introduction and passage of a resolution is a legislative action, the legislative intent is subject to limited judicial review; and (2) an alleged appearance of impropriety generated by illegal campaign contributions does not negate the presumption of validity of the legislative act. View "Kenwood Gardens Condos., Inc. v. Whalen Props., LLC" on Justia Law

Brenda Smith slipped on the floor in the course of her employment and landed on her left knee when she fell. Smith filed a workers’ compensation claim seeking benefits from Delaware North Companies and its insurer (together, Delaware North) for a full knee replacement. The Workers’ Compensation Commission denied her claim. Smith filed a petition for judicial review and requested a jury trial. During trial, Smith presented the expert testimony of Dr. Kevin McGovern. Delaware North, in turn, sought to admit a consent order that Dr. McGovern entered into with the Maryland Board of Physicians in order to impeach Dr. McGovern’s testimony. The trial court admitted into evidence a portion of the consent order. Based on the jury verdict, the trial judge affirmed the decision of the Commission. The Court of Appeals reversed, holding (1) Md. Code Ann. Health Occ. 14-410 generally prohibits the admission of a Board of Physicians’ consent order into evidence in a civil or criminal proceeding; and (2) the trial court erred as a matter of law in admitting a redacted version of the consent order in this case, causing prejudice to Smith’s case. View "Smith v. Delaware North Cos." on Justia Law

Defendant was indicted on several drug-related counts, which resulted in a two-day jury trial. During jury deliberations, the trial court received a jury note stating that the jury was deadlocked on a particular count (Count 1). Arrangements were made to bring Defendant to the courtroom, but Defendant had been transported to a hospital due to a medical emergency. The court summoned the jury foreperson to discuss the deadlock, and in Defendant’s absence, the judge accepted a partial verdict from the jury. Defendant was found guilty on three counts, and the trial court declared a mistrial on Count 1 on the ground of “manifest necessity.” The trial court subsequently ordered a new trial, concluding that it erred in receiving the partial verdict in Defendant’s absence. The judge, however, denied defense counsel’s motion to dismiss Count 1. The Court of Special Appeals reversed as to Count 1, concluding that, due to Defendant’s involuntary absence, manifest necessity did not exist to declare a mistrial as to Count 1, and therefore, retrial was barred by double jeopardy principles. The Court of Appeals affirmed, holding (1) the trial judge erred in declaring a mistrial in Defendant’s involuntary absence without first continuing the case; and (2) double jeopardy barred a retrial of Count 1. View "State v. Hart" on Justia Law

Brown, Brown & Brown, P.C. (BB&B), a Virginia law firm, entered into more than fifty agreements over a nine-month period with Maryland homeowners facing foreclosure. Under the agreements, in return for an advance payment of money, BB&B promised to attempt to renegotiate the mortgage loan so that the homeowner could avoid foreclosure. Ultimately, BB&B did not obtain loan modifications for any of the homeowners. The Commissioner of Financial Regulation (Commissioner) concluded that BB&B had violated the Maryland Credit Services Businesses Act (MCSBA) and directed BB&B to pay treble damages to the Maryland homeowners with whom they had agreements. The circuit court reversed, concluding that the MCSBA did not apply to BB&B because the agreements at issue were for legal services rather than credit services. The Court of Appeals reversed, holding (1) BB&B’s activities fell within the definition of “credit services business” under the MCSBA; and (2) BB&B did not qualify for the attorney exemption in the MCSBA. View "Comm'r of Fin. Regulation v. Brown, Brown & Brown, P.C." on Justia Law