Justia Maryland Supreme Court Opinion Summaries

At issue in these two consolidated civil cases was the circumstances under which an insurer providing uninsured (UM) motorist coverage may disclaim any such liability owed to its insured. In these cases, Petitioners sued their UM carriers for breach of contract. The Court of Special Appeals affirmed the judgments in favor of the UM carriers in both cases, concluding that Petitioners’ failure to comply with the statutory UM coverage settlement procedures were fatal to their claims. The Court of Appeals affirmed, holding that the Court of Special Appeals did not err in concluding that (1) the UM carrier did not waive its right to receive written notice of a pending settlement with the tortfeasor’s insurance carrier even where there was unequivocal testimony from Petitioner’s counsel that he received oral consent to settle from a UM carrier claims representative; and (2) the UM carrier did not bear the burden of proving prejudice arising from Petitioners’ failure to give written notice of the pending settlement with the tortfeasors’ insurance carrier. View "Woznicki v. GEICO Gen. Ins. Co." on Justia Law

Pursuant to a binding plea agreement, Defendant pleaded guilty to two counts of first degree murder. Two decades after he was sentenced, Defendant filed a motion to correct illegal sentence and motion for credit against time spent in custody, arguing that his sentence on Count I was illegal because it exceeded the sentence agreed upon by the parties under the terms of the plea agreement. The State responded by moving to correct the entire sentence, contending that the sentences on both Count I and Count III were illegal. The circuit court concluded that the sentences on both counts were illegal and ordered a resentencing in accordance with the original plea agreement. The Court of Special Appeals affirmed, agreeing that Defendant’s original sentence on Count III was illegal because it was below the binding plea agreement. The Court of Appeals affirmed, holding that a sentence below a binding plea agreement constitutes an illegal sentence within the meaning of Maryland Rule 4-345(a). View "Bonilla v. State" on Justia Law

Respondent filed in the circuit court a “complaint for title by adverse possession and bill to quiet title” against Petitioners concerning the ownership of a piece of land known as the Landing on Watts Creek (the Landing). Respondents answered and filed a countercomplaint alleging that they held title to the Landing and that Respondent’s use of the Landing constituted trespass. The circuit court ruled that Respondent had established a claim to the Landing by adverse possession. The Court of Special Appeals affirmed. The Court of Appeals affirmed, holding (1) the “woodlands exception,” previously applied only to prescriptive easements, also applies to adverse possession where the land at issue is unimproved or otherwise in a general state of nature; (2) the “woodlands exception” does not apply under the circumstances of this case, and therefore, no presumption of permissive use arose; and (3) because Petitioners failed to meet the burden of demonstrating permissive use, both the Court of Special Appeals and the circuit court were correct in holding that Respondent obtained title to the Landing by adverse possession. View "Breeding v. Koste" on Justia Law

Here the Court of Appeals decided whether to overrule Allied Inv. Corp. v. Jasen, in which the Court held that a defendant does not convert a plaintiff’s intangible property where the defendant does not convert a document that embodies the plaintiff’s right to the plaintiff’s intangible property. In this case involving a life insurance policy a jury found Defendant, an insurance broker, liable for negligence, negligent misrepresentation, deceit, conversion, and constructive fraud. The Court of Special Appeals reversed and remanded, holding that Plaintiffs failed to establish claims for conversion and constructive fraud. Plaintiffs appealed, urging the Court of Appeals to overrule Jasen and arguing that a defendant converts a plaintiff’s intangible property by interfering with the plaintiff’s right to the the intangible property, even if the defendant does not convert a document that embodies the plaintiff’s right to the plaintiff’s intangible property. The Court of Appeals affirmed, holding that the circuit court erred in denying Defendant’s motion for judgment notwithstanding the verdict as to conversion, as Defendant did not convert the life insurance policy, and as to constructive fraud, as Plaintiffs failed to establish that the parties were in a confidential relationship. View "Thompson v. UBS Fin. Servs." on Justia Law

These three cases, consolidated for the purposes of this opinion, involved the same legal issues arising out of the Court of Appeals’ opinion in Griffin v. State, in which the Court addressed the admissibility of a screenshot of a MySpace page. This appeal addressed Griffin’s application to the authentication of screenshots of messages allegedly sent through social networking websites. In the three cases, the messages were sent via a Facebook timeline, on Twitter through direct messages and public tweets, and through Facebook messages. The Court of Appeals held that, “in order to authenticate evidence derived from a social networking website, the trial judge must determine that there is proof from which a reasonable juror could find that the evidence is what the proponent claims it to be.” Accordingly, the Court held that, in each of the cases, the trial court did not err in (1) excluding the admission of the four pages of the Facebook conversation; (2) admitting the “direct messages” and “tweets” in evidence; and (3) admitting the Facebook messages authored by the defendant. View "Sublet v. State" on Justia Law

Plaintiff, a towing company, filed a complaint and requested a declaratory judgment, a temporary restraining order, and both a preliminary and permanent injunction against the State and other governmental entities, alleging that two towing statutes enacted by the General Assembly in 2012 - Md. Code Ann., Transp. 21-10A-04(a)(3) and (a)(7) - are arbitrary, oppressive, and unreasonable, as well as unconstitutional. The trial judge granted Plaintiff’s requests for declaratory and injunctive relief. The State appealed, and the Court of Special Appeals certified to the Supreme Court three questions of law. The Court of Appeals answered the first question in the negative, thereby eliminating the need to address the remaining questions, holding that there was not a justiciable controversy where Plaintiff had not been prosecuted under the statutes, nor did Plaintiff allege or prove that there was a credible threat of prosecution for the acts proscribed by the statutes. Remanded with instructions to dismiss. View "State v. G & C Gulf" on Justia Law

Blackstone International, Ltd. was insured by Insurers for commercial general liability insurance. The policy included coverage for personal advertising injury liability. Blackstone was sued for breach of contract, among other causes of action, after disputes arose regarding a joint business venture to market and sell lighting products. Blackstone requested coverage and litigation defense under the personal and advertising injury provisions of the policy. Insurers filed a complaint for declaratory judgment seeking a judgment that they had no duty to defend the claims because the complaint did not allege that Blackstone had engaged in advertising, that the plaintiff had suffered an advertising injury, or that there was any causal connection between the plaintiff’s claimed damages and any advertising conducted by Blackstone. The circuit court entered summary judgment for Insurers. The intermediate appellate court reversed. The Court of Appeals reversed, holding that Insurer had no duty to defend Blackstone where Blackstone did not show an advertising injury suffered by the plaintiff. View "Md. Cas. Co. v. Blackwell Int'l Ltd." on Justia Law

Defendant was charged with robbery with a dangerous weapon, conspiracy to commit robbery and first degree assault. During voir dire, the trial judge failed to accede to Defendant’s request that he be brought to the bench for conferences during voir dire. During one of those conferences, a juror who was questioned at the bench without Defendant’s presence was selected to serve on the jury. The Court of Special Appeals reversed Defendant’s conviction, concluding that his exclusion from bench conferences during voir dire was not harmless beyond a reasonable doubt. The Court of Appeals affirmed, holding that the judge’s error in failing to bring Defendant to the bench for conferences during voir dire was not harmless where the juror who was questioned at the bench without Defendant’s presence was selected to serve. View "State v. Yancey" on Justia Law

In this companion case to Anne Arundel County v. Bell, Respondents challenged the adoption by the County Council for Anne Arundel County of a comprehensive zoning ordinance for a large portion of the County, but a different portion of the County than was involved in Bell. In Bell, the Court of Appeals held that the doctrine of property owner standing is not the appropriate test for a judicial challenge to a comprehensive zoning action, but rather, plaintiffs wishing to challenge a legislative action adopting a comprehensive zoning are required to demonstrate taxpayer standing. The plaintiffs in this case (“Respondents”), several non-profit community associations and individual property owners, filed suit challenging the ordinance. The circuit court dismissed the two complaints filed by Respondents, concluding that Respondents lacked standing. The Court of Special Appeals reversed, concluding that property owner standing principles apply to a judicial challenge to comprehensive zoning legislation, and Respondents satisfied those principles. The Court of Appeals reversed, holding (1) the holding in Bell answered the first two questions presented in this appeal; and (2) Respondents in this case did not sufficiently allege a basis for their standing to challenge the adoption of the ordinance. View "Anne Arundel County v. Harwood Civic Ass'n" on Justia Law

In 2011, the County Council for Anne Arundel County adopted a comprehensive zoning ordinance for a large portion of the County. County property owners and community associations (“Respondents”) filed suit challenging the rezoning of multiple parcels of land. Several County property owners and ground leaseholders whose properties had been rezoned to desired classifications (collectively, with the County, “Petitioners”) intervened. Petitioners moved to dismiss Respondents’ suit, claiming that Respondents lacked standing. The circuit court granted the motion to dismiss, determining that Respondents lacked standing because they failed to meet their burden of proving special aggrievement. The Court of Special Appeals vacated the judgment of the circuit court and remanded, concluding that property owner standing principles apply to a judicial challenge to comprehensive zoning legislation, and Respondents satisfied those principles. The Court of Appeals reversed, holding (1) plaintiffs wishing to challenge a legislative action adopting a comprehensive zoning are required to demonstrate taxpayer standing; and (2) Respondents in this case did not allege facts sufficient to meet the correct standing requirement. View "Anne Arundel County v. Bell" on Justia Law