Justia Maryland Supreme Court Opinion Summaries

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

Almost three years after her involvement in a motor vehicle accident with Petitioner, Respondent brought a personal injury action against Petitioner and his employer (together, Petitioners). Between the time of the accident and the filing of this action, Respondent filed personal bankruptcy and was discharged from her debts. By operation of bankruptcy law, Respondent’s claim became the property of her bankruptcy estate. Issues regarding the claim were litigated in both the circuit court and the bankruptcy court. Eventually, the bankruptcy court granted Respondent’s request to re-open and re-vested her with the claim as of the filing of the bankruptcy petition. Meanwhile, the circuit court awarded summary judgment to Petitioners, ruling that Respondent lacked standing. The court of special appeals reversed, concluding that, because of the bankruptcy court’s ruling, Respondent was an appropriate plaintiff on a timely-filed complaint. The Court of Appeals affirmed, holding (1) summary judgment was inappropriate where the circuit court failed to take into account the legal effect of the bankruptcy court’s decision to re-vest Respondent with her claim against Petitioners; and (2) as a result of the bankruptcy court’s decision, Respondent had standing to prosecute the complaint. View "Morton v. Schlotzhauer" on Justia Law

In the divorce proceeding of Husband and Wife, Husband argued that the marital portion of his Civil Service Retirement System (CSRS) pension should be reduced in order to reflect an offset for the amount of Social Security benefits he would have been entitled to had he not participated in the CSRS. The circuit court rejected Husband’s argument and ordered the retirement plans to be divided so that each party would receive fifty percent of the marital share of the other party’s retirement plan. The Court of Appeals vacated the judgment of the circuit court, holding (1) when dividing marital assets in a divorce proceeding, a trial court is preempted by federal law from dividing hypothetical Social Security benefits by way of an offset; but (2) a court may take into consideration the parties’ anticipated Social Security benefits as a relevant factor under Md. Code Ann. Fam. Law 8-2015(b) in adjusting the equities and rights of the parties in marital property. Remanded. View "Jackson v. Sollie" on Justia Law

Respondents, on behalf of their minor child, Dylan, sued Petitioners after Dylan received severe injuries during his birth. The jury returned a verdict in favor of Dylan. Ultimately the court reduced the judgment to approximately $5 million. Petitioners satisfied the judgment. After Dylan died, Respondents filed a wrongful death action against Petitioners based on the same underlying facts in the personal injury action. The circuit court dismissed Respondents’ wrongful death action, concluding that the action was barred by a judgment in Dylan’s personal injury action. The Court of Special Appeals reversed. The Court of Appeals affirmed, holding (1) Maryland’s wrongful death statute creates a new and independent cause of action for a decedent’s beneficiaries, and therefore, a judgment on the merits in a decedent’s personal injury action during his lifetime does not bar a subsequent wrongful death action by the beneficiaries; and (2) a release by the injured person of one joint tortfeasor, whether before or after the judgment, does not discharge the other tortfeasors unless the release so provides. View "Spangler v. McQuitty" on Justia Law

This case centered around Petitioner’s written request under Maryland Public Information Act (MPIA) for information regarding the value of unclaimed property accounts in the custody of the Comptroller of Maryland. The Comptroller decided that the requested information was prohibited under the MPIA. The circuit court ordered the Comptroller to disclose the requested records in value order. The Court of Appeals affirmed in part and reversed in part, concluding that Petitioner was entitled to a list of claims but not sorted by value. On remand, the circuit court ordered the Comptroller to submit a modified MPIA request limited to certain accounts without sorting any by value. The Court of Special Appeals affirmed. The Court of Appeals affirmed, holding that the MPIA prohibited disclosure of the comparative value of accounts in the Comptroller’s custody. View "Immanuel v. Comptroller" on Justia Law

After a deputy sheriff stopped Petitioner for a traffic violation, the officer inserted his head into the passenger side window of Petitioner’s vehicle. The officer detected the odor of marijuana, and Petitioner was placed under arrest. Petitioner filed a motion to suppress, arguing that an unconstitutional search occurred when the officer inserted his head into the passenger window. The circuit court denied Petitioner’s suppression motion. The court then found Petitioner guilty of possession of marijuana. The Court of Special Appeals affirmed. The Court of Appeals reversed, holding that the circuit court erred in denying Petitioner’s motion to suppress because the evidence was unclear regarding the timing of the officer’s detection of the odor of marijuana, and in the absence of a finding that the officer detected the odor of marijuana before he inserted his head into the window, the State failed to satisfy its burden to show that the search was lawful. View "Grant v. State" on Justia Law

After a jury trial, Petitioner was convicted of sexual abuse of a minor household member and several other sex offenses. Petitioner was sentenced to terms of imprisonment and required to serve supervised probation upon release with the condition that he have no unsupervised contact with minors. Petitioner appealed, arguing that the circuit court erred in prohibiting unsupervised contact with his minor son during probation. The Court of Special Appeals affirmed. The Court of Appeals affirmed, holding that the sentencing court did not abuse its discretion in imposing “a reasonable and narrowly-tailored condition of probation” that prohibited unsupervised contact with all minors, including Petitioner’s son. View "Allen v. State" on Justia Law

Respondent, an instructor at a martial arts school, engaged in sexually explicit communications with his student - a fifteen-year-old girl who regularly attended his class. The communications occurred while Respondent and the student were in separate locations, usually their respective homes. The Department of Social Services concluded that Respondent had engaged in child sexual abuse under the Child abuse and Neglect Law. Under the statute, a department of social services may make a finding of indicated child sexual abuse of an individual commits the abuse while the individual has “temporary care or custody or responsibility for the supervision of the child.” An administrative law judge (ALJ) disagreed with the Department’s conclusion, finding that Respondent did not have “care or custody or responsibility for the supervision of” the student when the inappropriate behavior occurred. The circuit court and Court of Special Appeals affirmed. The Court of Appeals affirmed, holding that there was substantial evidence support the ALJ’s determination that Respondent’s out-of-class behavior did not constitute child sexual abuse under the current statutory definition. View "Dep’t of Social Servs. v. B.A." on Justia Law

Under Md. Code Ann. Lab. & Empl. (LE) 9-632, an award of benefits by the Workers’ Compensation Commission survives the death of an injured employee. Under Md. Code Ann. Lab. & Empl. (LE) 9-640, an award of benefits survives the death of an injured employee only up to $45,000. Appellant, an injured worker’s daughter, sought to collect benefits under the Maryland Workers’ Compensation Act that would have been due to her father had he not died of causes unrelated to his accidental work injury. At dispute between Appellant and Appellees, the worker’s former employer and employer’s insurer, was whether LE 9-632 or 9-640 applied. The Commission determined that Appellees were not obligated to make further payments under an award of compensation to Appellant because LE 9-640 capped the survival of benefits at $45,000, and Appellees had already paid more than this amount to the decedent at the time of his death. The circuit court affirmed the Commission’s ruling. The Court of Appeals affirmed, holding that LE 9-640, rather than LE 9-632, applied in this case. View "Hollingsworth v. Severstal Sparrows Point, LLC" on Justia Law