Justia Maryland Supreme Court Opinion Summaries

Defendant was convicted of felony murder, kidnapping, and robbery, among other crimes. The circuit court court sentenced Defendant to life imprisonment for felony murder, a term of twenty years concurrent for kidnapping, and a term of ten years concurrent for robbery. The Court of Special Appeals vacated the sentences for the convictions for kidnapping and robbery, concluding that the rule of lenity required merger for sentencing purposes of those convictions with the felony murder conviction because it was unclear which felony was the predicate felony for the felony murder conviction. The Court of Appeals reversed insofar as the Court of Special Appeals vacated the sentence for robbery and otherwise affirmed, holding (1) a conviction for only one predicate felony merges for sentencing purposes with the felony murder conviction, and applying the rule of lenity does not result in merger of additional convictions for predicate felonies; (2) the predicate felony with the greatest maximum sentences merges for sentencing purposes with the felony murder conviction, and the defendant may be separately sentenced for any remaining predicate felonies; and (3) because the kidnapping offense carries the greater maximum sentence, that conviction merges for sentencing purposes with the felony murder conviction, and the sentence for robbery shall remain as imposed by the circuit court. View "State v. Johnson" on Justia Law

Defendant was charged in a seventeen-count indictment with crimes stemming from an incident in which Defendant allegedly shot at Travis Green. Defendant filed a motion to suppress Green’s identification of him, arguing that the identification was blighted by an impermissibly suggestive photographic array as a result of the elongated appearance of the other men in four of the six photographs presented to Green. The trial judge denied the motion. During trial, the trial judge admitted the recorded statement of Elmer Duffy, a witness to the shooting who was later murdered, about seeing Defendant shoot Green, even though another man had been charged for Duffy’s murder. After a trial, Defendant was convicted of attempted first degree murder and other crimes and sentenced to life imprisonment plus ten years. The Supreme Court affirmed, holding (1) the elongation of the face and torso of four of the photographs did not render the photo array impermissibly suggestive; (2) the Court’s jurisprudence provides suitable means to assay an extrajudicial eyewitness identification; and (3) Duffy’s statement was properly admitted under Md. Code Ann. Cts. & Jud. Proc. 10-901 and Maryland Rule 5-805(b)(5)(B) because there was substantial evidence connecting Defendant to Duffy’s killing. View "Smiley v. State" on Justia Law

Two security guards employed by SSA Security, Inc. and four of their confederates carried out a conspiracy to set fire to several homes. The resulting fires destroyed ten homes and damaged twelve others. Appellants asserted various civil claims against SSA and the five convicted arsonists, contending that the Maryland Security Guards Act (“Act”) section 19-501 established a basis for SSA’s strict liability for its employees’ intentional torts and civil rights violations. A federal district judge granted summary judgment in SSA’s favor as to the negligence claims and the claims premised on strict liability under section 19-501, concluding (1) section 19-501 was merely a codification of the common law and did not expand the doctrine of respondeat superior; and (2) any intentional acts of SSA’s employees were outside the scope of employment. Appellants appealed, arguing that the Act extends the vicarious liability of security guard agencies beyond the state common law doctrine of respondent superior. The federal appellate court certified a question of law to the Court of Appeals regarding the meaning of section 19-501. The Court answered that section 19-501 has the same meaning as Maryland’s common law doctrine of respondent superior. View "Antonio v. SSA Sec., Inc." on Justia Law

Appellant was charged with and convicted of possession of a regulated firearm by a person with a disqualifying drug conviction. The statute under which Appellant was convicted carries a mandatory minimum sentence of five years incarceration. Following his sentencing under that statute, Appellant appealed, arguing that his sentence was illegal because, on the same facts, he could have been charged and convicted under a different statute that carries a more lenient sentence. The Supreme Court affirmed, holding (1) the State’s Attorney had discretion to charge Appellant with a violation of either statute at issue in this case, and the decision was not subject to judicial oversight as to whether the statute carrying the mandatory minimum sentence or the statute with the more lenient penalty should have been charged; and (2) there was no need to apply the rule of lenity in these circumstances because there was no unresolvable ambiguity in the statute in question. View "Oglesby v. State" on Justia Law

The United States Bankruptcy Court for the District of Maryland submitted to the Supreme Court a certified question of law. The Court reformulated the question to be this: “Under Maryland law, where there is no allegation of common law fraud, may a court disregard the corporate entity and establish personal liability to enforce a paramount equity?” The Supreme Court answered the question in the affirmative, holding that the corporate veil may be disregarded when necessary and personal liability established to prevent fraud or to enforce a paramount equity. View "Schlossberg v. Bell Builders Remodeling, Inc." on Justia Law

William Lovelace was a member of Amalgamated Transit Union, Local 1300 (Local 1300). For three years, Lovelace and David McClure (together with Local 1300, “the Union”) served together as officers on Local 1300’s executive board. When the men ran for reelection, Lovelace was defeated. Lovelace filed a defamation action against the Union, claiming that his defeat was due to allegedly false and defamatory statements McClure made during the campaign. Lovelace sought both compensatory and punitive damages. The Union filed motions to dismiss, asserting that Lovelace was required to exhaust Local 1300’s internal remedies before filing suit. The circuit court denied the motions. The jury ultimately rendered a verdict in Lovelace’s favor. The Union appealed, challenging the trial court’s denial of their motions to dismiss. The Court of Special Appeals affirmed, concluding that Local 1300’s internal remedies were inadequate because they could not provide the monetary damages that Lovelace sought. The Court of Appeals affirmed, holding that when a union member claims that his union and a fellow union member were liable for defamation and seeks monetary damages and the union's internal remedies do not provide monetary damages, the union’s internal remedies are inadequate and the union member is not required to exhaust them. View "Amalgamated Transit Union v. Lovelace" on Justia Law

Petitioners owned properties located along Farm Road and a ten-foot right-of-way (collectively, the Farm Road), which provided the only means of access to Petitioners’ properties. Petitioners filed suit in the circuit court against the Maryland-National Capital Park and Planning Commission (the Commission) and several other defendants, alleging several claims based on the Commission’s refusal to recognize Farm Road and to issue addresses to Petitioners. The circuit court dismissed the action. The Court of Special Appeals upheld the dismissal. The Court of Appeals affirmed in part and reversed and remanded in part, holding that the Court of Special Appeals (1) properly upheld the circuit court’s dismissal of Petitioners’ state constitutional claims for Petitioners’ failure to comply with the notice requirements of the Local Government Tort Claims Act; (2) properly upheld the trial court’s dismissal of Petitioners’ easement claims for failure to join necessary parties, i.e., adjacent property owners; but (3) erred in determining that Petitioners failed to file their slander of title claim within the statute of limitations. View "Rounds v. Maryland-Nat’l Capital Park & Planning Comm’n" on Justia Law

Elizabeth Duvall died, having been predeceased by her son, Dennis Kelly, only weeks earlier. Respondents, Duvall’s surviving sons, filed a petition for construction of Duvall’s will, asserting that the will left the assets of Duvall’s estate to her living children only. The orphans’ court ruled in favor of Respondents. Petitioner, Kelly’s heir, appealed. The circuit court and Court of Special Appeals affirmed. The Court of Appeals reversed, holding that Petitioner was permitted to inherit, as (1) the will does not express an intent to create a survivorship requirement as a condition precedent to inheritance; and (2) Duvall did not express an intent to negate Maryland’s anti-lapse statute, and therefore, the anti-lapse statute protected the devise from lapse. View "Kelly v. Duvall" on Justia Law

This appeal concerned a dispute over ownership of parking spaces situated between The Falls Homeowners Association (“The Falls”) and Falls Garden Condominium Association (“Falls Garden”). The Falls and Falls Garden executed a letter of intent in settlement of litigation. After problems arose between the parties, The Falls filed a motion to enforce settlement agreement to implement the letter of intent. The circuit court judge granted The Falls’s motion. The court ordered The Falls to prepare a settlement agreement and a release of all claims and ordered Falls Garden to execute the settlement agreement. On appeal, Falls Garden argued that the Letter of Intent was not binding because the parties did not intend to be bound and because the letter did not contain all material terms. The Court of Special Appeals affirmed. The Court of Appeals vacated the judgment of the Court of Special Appeals and remanded, holding (1) the letter of intent was an enforceable contract to which the parties intended to be bound; and (2) because the letter of intent was unambiguous and constituted an enforceable contract, the trial judge did not err in failing to hold a plenary hearing on the merits of the motion to enforce settlement agreement. View "Falls Garden Condo. Ass’n v. Falls Homeowners Ass’n" on Justia Law

Plaintiff, a young lawyer associate, filed a complaint against Defendants, his former Virginia-based law firm employer and its principal, claiming a violation of the Maryland Wage Payment and Collection Law (“MWPCL”) and seeking $1,974 in unpaid wages, treble damages, and attorney’s fees and costs. The trial judge concluded that the employment contract was a “Virginia” contract, and therefore, Plaintiff could not bring a suit in Maryland under the MWPCL. The circuit court reversed the dismissal of Plaintiff’s MWPCL claim. Defendants appealed. The Court of Appeals affirmed, holding that the mere fact that the parties in this case entered into a “Virginia” employment contract did not prohibit maintenance of Plaintiff’s claims under the MWPCL. Remanded. View "Cunningham v. Feinberg" on Justia Law