Justia Maryland Supreme Court Opinion Summaries

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Defendants Matthew Meyer and Helen Rivera were placed on probationary terms and, as a special condition of probation, prohibited from operating a motor vehicle. The circuit court denied Meyer’s motion to correct and illegal sentence, concluding that Meyer’s sentence was not illegal. In Rivera’s case, the court of special appeals held that Rivera’s no-driving condition of probation violated the separation of powers doctrine. The State filed a petition for writ of certiorari with the Court of Appeals in both cases. The Court consolidated the cases to address the common questions of law and fact and held (1) Sheppard v. State, which prohibits a court from restricting a defendant’s driving privileges as a condition of probation under certain circumstances, was wrongly decided and is thus overruled; and (2) in Meyer, the circuit court properly denied the defendant’s motion to correct an illegal sentence, and in Rivera, the court of appeals’ judgment holding that the no-driving condition of probation violated the separation of powers doctrine is reversed. View "Meyer v. State" on Justia Law

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A local public school superintendent decided to terminate a school nurse, who was a “noncertificated” employee. The school nurse challenged her termination by way of a grievance process set forth in a collective bargaining agreement (CBA) between the school board and a union. The superintendent denied the grievance, asserting that the termination was an illegal subject of collective bargaining. The union, on behalf of the school nurse, made a demand for arbitration. The school board filed a motion for injunctive relief seeking to enjoin the arbitration. The Maryland State Board of Education (State Board) and the Public School Labor Relations Board (PSLRB) both issued opinions in the matter. The circuit court affirmed the decision of the State Board, which concluded that the binding arbitration provision of the CBA was illegal, and reversed the decision of the PSLRB, which came to the opposite conclusion. The court of special appeals reversed, holding that the PSLRB was the entity with the jurisdiction to resolve the dispute. The Supreme Court affirmed, holding that the termination of a noncertificated employee is a proper subject of binding arbitration pursuant to a collective bargaining agreement. View "Bd. of Educ. v. Howard County Educ. Ass'n" on Justia Law

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Dustin R., who was born in 1992, has lived in a foster home since 1995. Guardianship was granted to the Department of Social Services. Dustin is medically fragile and has special needs. In 2010, Dustin began to seek the provision of services for himself after age twenty-one. In 2013, the Department of Health and Mental Hygiene (DHMH) consented to co-commitment. The parties, however, continued to debate Dustin’s request that services continue after his twenty-first birthday after the guardianship terminates. The juvenile court ordered DHMH to continue to provide services to Dustin after the age of twenty-one. DHMH appealed. The Court of Special Appeals dismissed the appeal, concluding that the juvenile court’s order was not a final, appealable order. The Supreme Court reversed, holding (1) the juvenile court’s order is appealable as an interlocutory order granting an injunction; (2) the juvenile court had jurisdiction and statutory authority to order DHMH to enter into a plan to obtain “life-sustaining services” for Dustin to continue after he reached age twenty-one; and (3) the juvenile court did not violate the separation of powers in the instant case. View "In re Adoption/Guardianship of Dustin R." on Justia Law

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Respondents manufactured steam pumps that were sold to the United States Navy. Although Respondents’ pumps contained asbestos gaskets and packing when they were delivered to the Navy, Respondents’ manuals did not contain any warnings regarding the danger of inhaling asbestos dust or directions to wear protective gear. Petitioner was the widow of a machinist mate who served on active duty in the Navy from 1956 until 1976. Petitioner’s husband was only exposed to asbestos after other Navy mechanics, who performed maintenance on Respondents’ pumps, replaced Respondents’ gaskets and packing with new components also containing asbestos that were acquired from third parties. Petitioner filed suit against Respondents, alleging negligence. The circuit court granted summary judgment in favor of Respondents, concluding that Respondents had no duty to warn of the dangers of the asbestos-containing replacement parts that they neither manufactured nor placed into the stream of commerce. The Court of Special Appeals affirmed. The Court of Appeals reversed, holding (1) summary judgment on Petitioner’s negligent failure to warn claims was inappropriate; and (2) Petitioner supplied sufficient evidence to survive Respondents’ motion for summary judgment on her strict liability claim. View "May v. Air & Liquid Systems Corp." on Justia Law

Posted in: Injury Law
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Petitioner was convicted of first degree murder and sentenced to life imprisonment. The Court of Special Appeals affirmed. Two issues were presented in this appeal, first, whether Petitioner’s statement, “I don’t want to say nothing. I don’t know” was an ambiguous or clear invocation of his right to remain silent under Miranda, and second, whether Petitioner’s confession, given after he waived his Miranda rights, was voluntary or the product of inducement. The Court of Appeals affirmed, holding (1) Petitioner’s statement, “I don’t want to say nothing. I don’t know” was an ambiguous invocation of his right to remain silent; and (2) Petitioner’s confession was voluntary. View "Williams v. State" on Justia Law

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Petitioner was charged with theft of property with a value of at least $500 and embezzlement. The charges arose from Petitioner’s removal of funds from a multiple-party bank account, to which Petitioner and her father were parties, to use for her own benefit without her father’s permission. After a bench trial, the circuit court found Petitioner guilty. The Court of Special Appeals affirmed. The Court of Appeals affirmed, holding (1) the evidence was sufficient to support a conviction for theft, as an individual can commit theft from a joint or multiple-party bank account to which the individual is a party under certain circumstances; and (2) the evidence was sufficient to support a conviction for embezzlement. View "Wagner v. State" on Justia Law

Posted in: Criminal Law
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Petitioner was terminated from her position as the Clerk-Treasurer of the Town of Hurlock two and one-half years after she entered into a written employment agreement with the Mayor-elect. Under the employment agreement, Petitioner was to serve a four-year term. Petitioner brought this action against Respondent, the Town, alleging breach of contract and seeking damages and other relief. The circuit court dismissed the complaint, concluding that the four-year term of employment in the agreement was inconsistent with the Town Charter and therefore ineffective. The Court of Special Appeals affirmed. The Court of Appeals affirmed, holding (1) the language of the Town Charter means that an official like the Clerk-Treasurer is an at-will employee; and (2) the Mayor and Council of Hurlock lacked authority under the Town Charter to enter into an agreement conferring a fixed term of employment in this case. View "Clough v. Mayor & Council of Hurlock" on Justia Law

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In 1999, Petitioner pleaded guilty to a drug offense. In 2012, after being subject to sentencing as an armed career criminal, Petitioner filed a petition for coram nobis relief, contending that he pleaded guilty to an offense other than possession of heroin with intent to distribute, which was one of the predicate offenses to be used for his enhanced sentence. The State filed a response to the coram nobis petition, asserting that the doctrine of laches barred Petitioner from seeking coram nobis relief. After a hearing, the circuit court granted the coram nobis petition. The Court of Special Appeals reversed, concluding that the doctrine of laches barred the coram nobis petition. The Court of Appeals affirmed, holding (1) the doctrine of laches may bar the right to seek coram nobis relief; and (2) the doctrine of laches barred Petitioner’s right to seek coram nobis relief in this case. View "Jones v. State" on Justia Law

Posted in: Criminal Law
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In 1999, Petitioner was charged with, among other crimes, three counts of first degree assault. In 2000, the circuit court determined that Petitioner was incompetent and ordered that he be committed. In 2004, Petitioner was found competent to stand trial. Petitioner pled not guilty to the charges of second degree assault. Petitioner was found guilty. The circuit court determined vacated Petitioner’s sentence and ordered a new trial, concluding that Petitioner’s counsel provided ineffective assistance because he had not advised Petitioner of the immigration consequences of his assault conviction. After a retrial, the jury found Petitioner guilty of two counts of first-degree assault and two counts of second-degree assault, among related crimes. Petitioner was sentenced to ten years’ imprisonment. Petitioner appealed, arguing that the trial court erred in failing to determine, prior to trial, that he was competent to stand trial and erred in finding at sentencing that he was competent to stand trial. The court of special appeals affirmed. The Court of Appeals reversed, holding that, pursuant to Md. Code Ann. Crim. Proc.. 3-104, the trial court was required to make a determination upon retrial whether Petitioner was competent to stand trial and therefore clearly erred in determining at sentencing that Petitioner was competent. View "Sibug v. State" on Justia Law

Posted in: Criminal Law
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Respondent had his vehicle serviced at Russel Collision and was billed for the repairs. Jeremy Martin, Russel Collision’s manager, later signed a “Notice of Sale of Motor Vehicle to Satisfy a Lien” for Respondent’s vehicle. The notice listed the “cost of process” at $1,000, which was the amount to which Russel Collision and Allstate Lien agreed they were entitled to keep Respondent’s car and sell it unless Respondent paid the costs related to the future sale of the car. Respondent’s vehicle was eventually sold at auction. Respondent filed suit against Russel Collision, Martin, and Allstate Lien, alleging that Md. Code Ann. Com. Law ("CL") 16-202(c), which provided Russel Collision a lien for Respondent’s vehicle, does not permit lien recovery costs of $1,000 as fees prior to the sale of the car. The jury returned a verdict in favor of Respondent. The Court of Special Appeals affirmed, holding that, under CL 16-202(c), a motor vehicle lien does not encompass “cost of process” fees and that such fees should not be included in the amount the customer must pay to redeem the vehicle. The Court of Appeals affirmed, holding that a garagemen’s lien does not encompass lien enforcement costs or expenses or cost of process fees prior to sale should the owner attempt to redeem the vehicle before sale. View "Allstate Lien & Recovery Corp. v. Stansbury" on Justia Law