Justia Maryland Supreme Court Opinion Summaries

Plaintiffs, individuals with lung cancer, attempted to join in one action claims against Defendants, asbestos and tobacco companies, alleging that their cancers were caused by their exposure to asbestos and smoking cigarettes. Specifically, Plaintiffs claimed claimed that “the combination of asbestos exposure and cigarette smoking acted in ‘synergy’ and multiplied the risk of developing lung cancer[.]” The trial court refused to permit joinder of the two sets of defendants on the special asbestos docket maintained by the court. The appellate issues dealt with how the trial implemented its decision to deny joinder, and the issues before the Supreme Court were largely procedural. The Court held (1) there was a final judgment in the case; (2) Plaintiff’s appeal, in any event, was moot and should be dismissed on that ground; and (3) the Court of Special Appeals did not err addressing the joinder argument made by Plaintiff for guidance of the lower court in other pending cases. View "R.J. Reynolds Tobacco Co. v. Stidham" on Justia Law

These two cases involved the common facts of underage people drinking alcohol on an adult’s property and then leaving that property in a motor vehicle. The alcohol was consumed with the knowledge and consent of the adult property owner. Plaintiffs in both cases filed negligence actions against the property owners, alleging that one defendant caused the death of an individual and that the other defendant caused another individual’s life-threatening injuries. In the first case, the trial court dismissed the complaint for failure to state a claim. In the second case, the trial court granted summary judgment for Defendant. The Supreme Court reversed the judgments of the trial courts, holding (1) adults who allow underage drinking on their property may owe a civil duty to persons injured as a result of such drinking, including the underage persons consuming the alcohol; and (2) Defendants in both cases owed the victims in these cases such a duty. View "Kiriakos v. Phillips" on Justia Law

The Commissioner of Financial Regulation of the Department of Labor, Licensing, and Regulation brought an administrative enforcement action against CashCall, Inc., a California corporation that marketed high-interest loans to consumers through television and internet advertisements, and John Paul Reddam (together, Petitioners), the corporation’s president and owner, alleging that Petitioners violated the Maryland Credit Services Business Act (MCSBA). The Commissioner concluded that CashCall was subject to the MCSBA, ordered Petitioners to cease and desist from engaging in the credit services business, and ordered that Petitioners pay a civil penalty. The circuit court reversed, concluding that CashCall was not a “credit services” business under the MCSBA. The Court of Special Appeals affirmed. The Court of Appeals affirmed, holding that the MCSBA’s definition of a “credit services business” requires there to be a direct payment from a consumer to an entity whose primary business is to assist consumers in obtaining loans that would be usurious under Maryland law. View "CashCall, Inc. v. Comm'r of Fin. Regulation" on Justia Law

After a jury trial, Petitioner was convicted of neglect of a minor. Petitioner was sentenced to twenty days’ incarceration. The Court of Special Appeals affirmed. The Court of Appeals granted certiorari to address the questions of whether Md. Code Ann. Crim. Law 3-602.1, the criminal neglect of a minor statute, was unconstitutionally vague and whether the evidence was sufficient to support Petitioner’s conviction. The Court of Appeals reversed, holding that the evidence presented at trial was insufficient to support Petitioner’s conviction for criminal child neglect. Remanded with directions to reverse the judgment of the circuit court. View "Hall v. State" on Justia Law

In 2003, Petitioner entered an Alford plea to second degree rape. Thereafter, Petitioner filed several motions for DNA testing. In 2005, the petition was granted, but the results of the testing yielded inconclusive results. In 2015, Petitioner filed a petition for DNA testing alleging that that testing a piece of underwear and additional material collected on laboratory microscope slides would produce exculpatory or mitigating evidence. The circuit court denied the petition pursuant to Md. Code Ann. Crim. Proc. 8-201. The Court of Appeals affirmed, holding that none of Petitioner’s assertions in his 2015 petition would have produced evidence which would have exculpated him of second degree rape under the standard of section 8-201(c), and therefore, the circuit court did not err in denying the petition. View "Jackson v. State" on Justia Law

Petitioner, the assignee of an entity that paid certain sewer connection charges, sought a refund of the charges, asserting that they were improperly charged by the Town of Bel Air. The Town’s Director of Finance denied Petitioner’s refund application. On appeal, the Tax Court granted the Town’s motion to dismiss, concluding (1) it lacked jurisdiction to consider Petitioner’s refund claim because it did not come within the purview of the refund statute, and (2) even if the sewer connection charges were miscalculated or illegally imposed the common law voluntary payment doctrine precluded Petitioner from obtaining a refund. The Supreme Court reversed, holding (1) Petitioner may pursue its refund claim under the refund statute; (2) Petitioner’s claim is not barred by the voluntary payment doctrine; and (3) the Tax Court has jurisdiction to consider the appeal. View "Brutus 630, LLC v. Town of Bel Air" on Justia Law

Under the Workers’ Compensation Act (Act), the amount of compensation due to a “covered employee” - which may include a sole proprietor - who has a “permanent total disability resulting from an accidental personal injury” is based on the employee’s “average weekly wage” (AWW). At issue in this case was how to calculate the AWW of a sole proprietor who elects coverage for an accident personal injury under the Act. Petitioner, a self-employed sole proprietor who elected to obtain workers’ compensation coverage as a covered employee, was injured while working as a subcontractor. The Workers’ Compensation Commission issued an award of compensation, but the parties disputed the amount of compensation due. The Commission ultimately calculated Petitioner’s AWW based on his net profit rather than his gross receipts. The circuit court and Court of Special Appeals affirmed. The Court of Appeals affirmed, holding that the AWW of a sole proprietor who elects coverage under the Act is calculated based on the sole proprietorship’s net profit, not on the sole proprietorship’s gross receipts or gross income. View "Long v. Injured Workers' Ins. Fund" on Justia Law

Petitioner filed a complaint against the State of Maryland alleging negligence and malfeasance of an unspecified clerk of the district court. Specifically, Petitioner alleged that she was injured as the direct and proximate result of the issuance of a body attachment. The State filed a motion to dismiss the complaint on the ground of absolute judicial immunity. The circuit court denied the motion, questioning whether the clerk was acting at the direction or under the supervision of a judge in generating the body attachment. The Court of Special Appeals reversed, concluding that the issuance of arrest warrants is a judicial act. The Court of Appeals affirmed, holding that Petitioner’s claims were barred by absolute judicial immunity because the clerk’s role in transmitting the application for a body attachment to the judge for signature was not the proximate cause of Petitioner’s wrongful arrest, but, rather, the judge’s act of signing the body attachment caused Petitioner’s injury. View "Keller-Bee v. State" on Justia Law

Adkins started working at PRMC in 2005, delivering and organizing supplies. In April 2011, Adkins went to PRMC’s emergency room after experiencing pain. Adkins was diagnosed with a tear in the joint of her hip and a deformation in her hip socket. She scheduled surgery and completed paperwork under the Family and Medical Leave Act, 29 U.S.C. 2612, stating that she would return to work in October 2011. PRMC approved Adkins’s leave, explaining that her 12-week FMLA leave would expire on November 17, 2011, After surgery, Adkins’s pain intensified. Doctors advised that recovery could take up to a year. On November 7, 2011, Adkins returned to work, stating that she was still in pain and would be unable to fulfill her job responsibilities that day. An “Employee Charting Note” states that “[a]ll parties” agreed that Adkins could not return to work; that Adkins had “been educated on FMLA and to start looking at job postings,” and that Adkins reported having applied for a position. PRMC granted a 14-week extension, after which Adkins was terminated. Adkins unsuccessfully applied to positions. The trial court rejected her suit under the Maryland Fair Employment Practices Act, Code 20-601 on summary judgment. The Court of Appeals reversed, finding disputes of material fact with respect to whether: Adkins was qualified to perform the essential functions of a specific job with or without a reasonable accommodation, and whether Adkins was terminated because of her disability. View "Peninsula Regional Med. Ctr. v. Adkins" on Justia Law

In cases consolidated for this appeal, defendants were found guilty but not criminally responsible at the time of the commission of the offense and were committed to the Department of Health and Mental Hygiene. The court granted conditional releases on various occasions but each conditional release was subsequently revoked, resulting in recommitment to DHMH for treatment. The Maryland Court of Appeal held that the Circuit Court erred in determining that the statutory scheme, Criminal Procedure Article 3-114, for granting or revocation of the conditional release of a committed person violated the separation of powers provision found in Article 8 of the Maryland Declaration of Rights. The court also erred in revoking defendant’s conditional release and ordering his continued commitment for institutional inpatient care and treatment after the ALJ had found that defendant was eligible for conditional release and had recommended the same. The court held that under CP 3-114 the substantial evidence standard applies to a circuit court’s review of an ALJ’s findings of facts and recommendations. View "Stoddard v. State" on Justia Law