Justia Maryland Supreme Court Opinion Summaries

Defendant was charged with carjacking and related offenses, various firearms offenses, and possession of illicit drugs. The morning of trial, Defendant’s attorney made an oral motion seeking to exclude evidence derived from a flip cell phone that was seized from Defendant incident to his arrest. The primary evidence obtained from the cell phone was a screen saver image that matched the custom wheel rims of the stolen car. The circuit court denied the motion to suppress. After a jury trial, Defendant was found guilty. The court of special appeals affirmed. Before the Court of Appeals, Defendant relied on the U.S. Supreme Court’s intervening decision in Riley v. California to argue that the arresting officer’s review of photos on Defendant’s cell phone without a warrant was an unconstitutional search, and therefore, the evidence derived from the cell phone should have been suppressed. The Supreme Court affirmed, holding (1) Defendant waived his motion to suppress by failing to make his motion within the time period and with the specificity required by the Maryland Rules; and (2) even had the motion been made in a timely manner, the screen saver image was admissible under Riley. View "Sinclair v. State" on Justia Law

Maryland Rule 2-325 provides that a party’s failure to demand a jury trial within fifteen days after service of the last pleading directed to the issue constitutes a waiver of the party's right to a jury trial. If a party files an amended complaint asserting a new substantive issue and demanding a jury trial, the new claim may revive the previously waived jury trial. In this case, Plaintiff sued Defendant, alleging two counts (Counts I and II). Plaintiff failed to timely demand a jury trial. Plaintiff subsequently filed an amended complaint reasserting Counts I and II and adding a third (Count III). Included with his amended complaint was a jury demand. Counts II and III were subsequently dismissed for failure to state a claim. The circuit court then struck the jury demand. On appeal, the Court of Special Appeals ruled that Plaintiff was entitled to a remand for a jury trial. The Court of Appeals reversed, holding that Plaintiff’s amended complaint, in which he timely demanded a jury trial, added only one new count that was dismissed for failure to state a claim, and that count was an insufficient basis to revive the previously waived jury trial. View "Scarfield v. Muntjan" on Justia Law

An inmate brutally murdered another inmate during a ride on a prison transport bus staffed by five correctional officers. At issue in this case was whether the correctional officer who was in charge of the bus was grossly negligent and, if so, whether he was entitled to common law public official immunity. The jury found that the officer at issue (“Cooper”) was grossly negligent and that his gross negligence was a proximate cause of the inmate’s death.The circuit court granted Cooper’s motion for judgment notwithstanding the verdict by striking the jury’s finding of gross negligence and determining that Cooper was immune from liability. The court of special appeals reversed as to Cooper, concluding that Cooper was grossly negligent and consequently not immune from liability. The Court of Appeals affirmed, holding (1) gross negligence is an exception to common law public official immunity; and (2) the court of special appeals was correct in ruling that Cooper was not entitled to common law public immunity because he acted with gross negligence. View "Cooper v. Rodriguez" on Justia Law

Pursuant to a plea agreement, Respondent pleaded guilty to having engaged in a conspiracy to distribute marijuana. Respondent later sought to have the conspiracy conviction vacated, asserting that her guilty plea was not knowing and voluntary because she had not been informed at the time of the plea of the elements or essential nature of the crime of conspiracy. The circuit court denied coram nobis relief. The Court of Special Appeals reversed, concluding that Respondent’s guilty plea was invalid and must be vacated. The Court of Appeals reversed, holding (1) Respondent did not waive her right to pursue coram nobis relief; and (2) Respondent’s guilty plea was knowingly and voluntarily made. View "State v. Smith" on Justia Law

Defendant was charged with armed robbery. During trial, a DNA expert testified regarding the work of another DNA analyst. The expert was a supervisor in the same lab, reviewed the work of the other analyst, and came to his own conclusion that was consistent with the conclusion of the other analyst. The analyst herself, however, did not testify. The Court of Special Appeals concluded that the admission of the DNA case report without the analyst’s testimony violated Defendant’s ability to confront his accuser. The Court of Appeals affirmed, holding that the language “within a reasonable degree of scientific certainty” in the DNA report rendered the report testimonial within Williams v. Illinois. View "State v. Norton" on Justia Law

Petitioners purchased and financed an automobile from Respondent. Petitioners averred that Respondent failed properly to disclose the vehicle’s history. At issue in this case was the extent to which multiple documents executed on the same day during the course of the purchase and financing could be read together as constituting the entire agreement between the parties. The issue arose in the context of whether Petitioners’ claims against Respondent were subject to a mandatory arbitration provision in the Buyer’s Order, which set forth the purchase price. A Retail Installment Sales Contract (RISC), which contained the financing terms of the purchase, did not include an agreement to arbitrate. The circuit court granted Respondent’s motion to compel arbitration, thus disagreeing with Petitioners that the language of the Buyer’s Order was superseded by the RISC. The Court of Appeals affirmed, holding that, for the purposes of the instant case, the Buyer’s Order may be construed together with the RISC as evincing the entire agreement between the parties. View "Ford v. Antwerpen Motorcars Ltd." on Justia Law

Respondent filed a complaint against a sergeant of the Maryland State Police that was “sustained.” Respondent subsequently sought records of the internal investigation conducted by the State Police in response to her complaint, but the State Police denied the request. Respondent subsequently filed a complaint for declaratory and injunctive relief under the Maryland Public Information Act. The circuit court granted summary judgment for the State Police, concluding that the records were mandatorily exempt from disclosure as “personnel records.” The Court of Special Appeals vacated the judgment, concluding that the circuit court erred in failing to require the State Police to create an index of the withheld documents and, in addition, by not conducting an in camera review of the documents to determine whether the documents could be redacted. The Court of Appeals vacated the judgment of the Court of Special Appeals and remanded to the circuit court for the entry of a declaratory judgment, holding that the internal affairs records of an investigation into the conduct of a specifically identified state trooper is a “personnel record” under the Act, and, in this case, not capable sufficiently of redaction were disclosure necessary. View "Dep’t of State Police v. Dashiell" on Justia Law

Respondents, three married couples, obtained home equity lines of credit from Petitioners, a bank and its loan officer. Approximately four years later, Petitioners filed a putative class action alleging that these transactions were part of an elaborate “buy-first-sell-later” mortgage fraud arrangement carried out by Petitioners and other defendants. Petitioners alleged numerous causes of action, including fraud, conspiracy, and violations of Maryland consumer protection statutes. The circuit court granted summary judgment for Petitioners, concluding that the statute of limitations barred several of Respondents’ claims and that no Petitioner violated the Maryland Secondary Mortgage Loan Law as a matter of law. The Court of Special Appeals reversed. The Court of Appeals reversed, holding that the Court of Special Appeals (1) erred in concluding that Respondents stated a claim upon which relief could be granted under the Maryland Secondary Mortgage Loan Law; and (2) erred in concluding that it was a question of fact to be decided by the jury as to whether Respondents’ claims against Petitioners were barred by the relevant statute of limitations. View "Windesheim v. Larocca" on Justia Law

At the center of this case was the report of a Baltimore Sun reporter that a high-ranking Maryland law enforcement ballistic expert named Joseph Kopera had lied, as an expert witness for the prosecution, about his credentials and qualifications in Maryland trials for more than twenty years. Kopera testified in the trials of Ronnie Hunt and Kevin Hardy (together, Respondents). Respondents, both incarcerated, filed petitions for writ of actual innocence in their related cases, alleging that the questions about Kopera’s qualifications were newly discovered evidence that created a substantial or significant possibility that the outcomes in their trials may have been different had Kopera not lied. Respondents also asserted that the newly discovered evidence could not have been discovered in time to move for a new trial under Maryland Rule 4-331. The circuit court denied the petitions without a hearing. The Court of Special Appeals reversed in both instances and remanded for further proceedings. The Court of Appeals affirmed, holding that because the petitions filed by Respondents satisfied the pleading standards established by Md. Code Ann. Crim. Proc. 8-301 and evaluated in Douglas v. State, Respondents were entitled to hearings on their petitions. View "State v. Hunt" on Justia Law

Lafarge North America, Inc., the operator of a ready-mix concrete plant, sought a refund from the Washington Suburban Sanitary Commission (WSSC) for allegedly improperly assessed and paid water and sewer service charges for operation of the plant. Large’s claim was deemed denied because of the WSSC’s failure to render a timely decision. The circuit court reversed the WSSC’s deemed denial of Lafarge’s claim and remanded the matter to the WSSC with directions to determine and issue an appropriate refund, concluding that the deemed denial was not supported by substantial evidence in the record and was arbitrary and capricious. The Court of Appeals affirmed, holding that, given the legislative intent to provide for refunds when charges are erroneously assessed, it is appropriate to remand the case to the WSSC for calculation of the amount of the refund due. View "Washington Suburban Sanitary Comm’n v. Lafarge N.A., Inc." on Justia Law