Justia Maryland Supreme Court Opinion Summaries

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

American Sedan Services, Inc. is a commercial transportation service that has a permit from Maryland Aviation Administration (MAA) to provide ground transportation services at the Baltimore Washington International Thurgood Marshall Airport (BWI). Vadim Roshchin, who was employed as a driver by American Sedan, was picking up passengers at BWI without displaying the permit as required by an MAA regulation when Maryland Transportation Authority (MdTA) police arrested him and impounded the American Sedan. Roshchin and American Sedan sued MAA, MdTA, the MdTA police, and the State, alleging, among other claims, false arrest and false imprisonment. The circuit court granted summary judgment for the State on all counts. The Court of Special Appeals reversed, concluding that there was no legal justification for the arrest of Roshchin. The Court of Appeals reversed, holding (1) the regulation requiring commercial transportation services to display permits was not required to be posted at the airport as a prerequisite to its enforcement; and (2) there was legal justification for the arrest, as nothing in the MAA regulation or the Transportation Article deprives a police officer of the general authority to arrest an individual who commits a misdemeanor in the presence of the officer. View "State v. Roshchin" on Justia Law

Petitioner operated a lake-front recreational campground on her property in Caroline County. The lake was contaminated allegedly by run-off from failed septic systems serving homes and businesses in the Town of Goldsboro. Unable to operate the campground because of the pollution to the lake, Petitioner lost the property through foreclosure. Petitioner filed a complaint for Caroline County against the State and several of its entities, alleging inverse condemnation against all Respondents and trespass against the Town. The circuit court dismissed the complaint as to all Respondents. The court of special appeals affirmed. The Supreme Court remanded, concluding that the court of special appeals erred in affirming the dismissal of Petitioner’s causes of action for negligence, trespass, and inverse condemnation on the grounds of limitations. On remand, the court of special appeals concluded that the circuit court properly dismissed the State and its agencies but erred in dismissing the three claims against the Town. The Court of Appeals reversed in part and affirmed in part, holding that Petitioner adequately alleged a facial claim for inverse condemnation against all Respondents and that a claim for inverse condemnation is not covered by the notice provisions of either the Local Government Tort Claims Act or the Maryland Tort Claims Act. View "Litz v. Dep’t of Env’t" on Justia Law

Respondent was stopped for failure to securely fasten a registration plate and was arrested after a police officer observed signs of impairment. Respondent agreed to take an alcohol concentration test, which he passed, but Respondent refused to take a blood test for drugs or controlled dangerous substances. The officer subsequently confiscated Respondent’s driver’s license and served an order of suspension on Respondent. An administrative law judge determined that Respondent violated Md. Code Ann., Transp. (“TR”) 16-205.1 by refusing to take the drug test and ordered that Respondent’s driver’s license be suspended. The circuit court reversed, holding that, once Respondent passed the alcohol concentration test, he was not required to submit to a blood test to avoid suspension. The Court of Appeals reversed, holding (1) under TR 16-205.1(b)(2) and (3), a law enforcement officer with reasonable grounds to suspect that a driver was driving while impaired by drugs may request that the driver take both an alcohol concentration test and a drug test; and (2) the driver is subject to an automatic license suspension for refusing to take the drug test. View "Motor Vehicle Admin. v. Gonce" on Justia Law

The Capital Crescent Trail, a hiker/biker route, runs between Georgetown in the District of Columbia and Silver Spring, Maryland. Its path was formerly used as a railroad. When the trains stopped running, the property was transferred to Montgomery County, Maryland via a quit-claim deed. The County planned to develop within the former rail line (and current hiker/biker trail) a commuter light rail project. The predecessors in interest to a private landowner adjacent to the rail line had previously erected a fence and installed a shed that encroached for more than twenty years upon the railroad right-of-way. The landowner argued that he owned the encroached-upon land by adverse possession. The circuit court ultimately concluded that the landowner had a creditable claim for adverse possession. The Court of Appeals reversed, holding that the evidence in the record did not establish that the current use of the right-of-way by Montgomery County was unreasonable or that the Railroad or the County abandoned the right-of-way, and therefore, the landowner had no claim for adverse possession. View "Montgomery County v. Bhatt" on Justia Law

Respondent, on her own behalf and as the personal representative of the estate of her deceased son, brought a wrongful death suit against Petitioner, a Baltimore City police officer, alleging negligence and gross negligence, among other causes of action. Petitioner sought both compensatory and punitive damages. The circuit court granted Petitioner’s motion for judgment in part, allowing only the question of whether Respondent was negligent and what amount of compensatory damages should be awarded. The jury returned a verdict for compensatory damages for Respondent, which amount was reduced by the trial judge to comply with the damages cap of the Local Government Tort Claims Act (LGTCA). The court of special appeals reversed and remanded for a new trial, concluding that there was sufficient evidence for each of Petitioner’s claims to have been submitted to the jury, that Petitioner’s claims could qualify as predicates for punitive damages, and that the LGTCA cap applied. The Court of Appeals affirmed in part and reversed in part, holding (1) there was sufficient evidence as to the counts for which the trial court gave judgment in favor of Respondent and on the LGTCA question; but (2) Respondent was not entitled to punitive damages, and therefore, a new trial was not warranted. View "Beall v. Holloway-Johnson" on Justia Law

Mother took her child to health providers on several occasions after complained that her father had hurt her. The child also exhibited vaginal redness. The Department of Human Resources notified Mother that it found her responsible for indicated child abuse mental injury. An Administrative Law Judge (ALJ) affirmed the Department’s finding of indicated child abuse mental injury and found that Mother could be placed on the central registry maintained by the Department. The circuit court affirmed the ALJ’s decision. The Court of Special Appeals affirmed, concluding, in relevant part, that the ALJ did not err by failing to include scienter as an element of indicated child abuse mental injury. The Court of Appeals reversed and remanded, holding that a parent can only be identified on a central registry as responsible for child abuse if the parent intended to injure the child or acted with reckless disregard of the child’s welfare. View "McClanahan v. Washington County Dep’t of Soc. Servs." on Justia Law