Justia Maryland Supreme Court Opinion Summaries

Defendant, who was indigent and whose mental competency was questioned by the court and counsel at several junctures, appeared before a series of judges concerning his dissatisfaction with appointed counsel, an assistant public defender. The circuit court advised Defendant about his right to, and the merits of, having counsel, but, upon finding that good cause existed to discharge the assistant public defender, the court treated Defendant’s decision to discharge that counsel as a waiver of counsel, despite Defendant’s clear requests for counsel. Defendant represented himself at trial and was convicted. The Court of Appeals reversed Defendant’s conviction, holding that the trial court erred in failing to appoint counsel for Defendant and in stating that it lacked the authority to appoint counsel for Defendant after finding a meritorious reason to discharge Defendant’s assistant public defender. Remanded for appointment of counsel and a new trial. View "Dykes v. State" on Justia Law

Defendant was indicted on multiple counts of burglary, theft, and related offenses. Defendant was found to be indigent, and an assistant public defender was assigned to represent him. Before trial, Defendant discharged his attorney. Defendant then filed a motion asking the circuit court to help him obtain “pro bono counsel.” The circuit court denied the motion. Defendant represented himself at trial and was found guilty on twenty-one counts. The Court of Special Appeals reversed, holding that the circuit court erred by failing to determine and announce on the record that Defendant was knowingly and voluntarily waiving the right to counsel. The Court of Appeals reversed, holding (1) to the extent Defendant asserts that the court’s “waiver inquiry” was deficient because the court did not make an explicit finding on the record that Defendant was acting knowingly and voluntarily by waiving counsel, Defendant failed to preserve the issue by making a contemporaneous objection; and (2) the trial court did not abuse its discretion in declining to appoint counsel for Defendant when Defendant lacked good cause for discharging his assigned assistant public defender. View "State v. Westray" on Justia Law

Petitioners, registered Republican voters and duly elected members of the Republican Central Committee of Carroll County (Committee), filed a complaint for mandamus, declaratory judgment, and injunctive relief seeking to enjoin the Committee from submitting more than one name to the Governor to fill a vacancy in the House of Delegates. Thereafter, Petitioners filed an amended complaint along with a motion for a temporary restraining order. The circuit court denied all relief sought. The Court of Appeals affirmed, holding that Md. Const. art. III, 13 does not impose a duty on a party central committee to submit any fixed number of names to the Governor to fill a vacancy. Instead, a party central committee may submit multiple names to fill a vacancy, and the Governor must appoint a person from among those whose names were submitted. View "Fuller v. Republican Cent. Comm’n" on Justia Law

Respondent lived in his home for nearly ten years before razing the existing house in order to build a new house on the lot. Respondent benefitted from the application of the homestead tax credit with respect to increases in the value of the prior structure while he lived in it. The new construction increased the value of the property by approximately $500,000. The tax assessor, while retaining Respondent’s existing credit, included the full value of the renovation in the value to be taxed. The Maryland Tax Court affirmed the assessor’s interpretation. The circuit court reversed, and the Court of Special Appeals affirmed. At issue on appeal was whether the “taxable assessment” used to compute the homestead tax credit under Md. Code Tax-Property (TP) 9-105 should include the value of renovations when a homeowner razes and rebuilds a home. The Court of Appeals reversed the judgments of the Court of Special Appeals and circuit court affirmed the decision of the tax court, holding that, when a homeowner razes and rebuilds a home, the homeowner may retain existing homestead tax credit if the homeowner satisfies certain criteria and the tax credit computation for the property with the rebuilt house is to be done in accordance with TP 9-105(c)(5) and TP 9-105(e)(1). View "Dep’t of Assessments & Taxation v. Andrecs" on Justia Law

Zimmer Development Company wished to construct on a parcel of property in Prince George’s County a small retail center and filed a proposed Comprehensive Design Plan (CDP) and Specific Design Plan (SDP) for the development of the property. The Planning Board approved the CDP and SDP subject to conditions. The District Council elected to review the approval and remanded the CDP and SDP to the Planning Board to consider specific areas of concern. On remand, the Planning Board again approved the CDP and SDP. The District Council elected again to review the Board’s revised decision and, after oral arguments, denied the CDP and SDP. The circuit court reversed and remanded to the District Council with directions to approve the CDP and SDP as approved by the Planning Board. The Court of Appeals affirmed, holding (1) the District council was authorized to reverse the Planning Board’s decision regarding the CDP and SDP only if it was not supported by substantial evidence, was arbitrary, capricious, or illegal otherwise; (2) the District Council’s ultimate consideration of the Planning Board’s approvals was limited to the issues remanded to the Planning Board; and (3) the circuit court’s order reversing the decision of the District Council denying the CPD and SDP was appropriate. View "County Council of Prince George's County v. Zimmer Dev. Co." on Justia Law

Community College of Baltimore County (CCBC) entered into an agreement with Patient First Corporation, a medical provider, under which student medical technicians gained experience doing blood draws at Patient First. In the agreement, CCBC agreed to indemnify Patient First for any liability that Patient First might occur, including attorneys’ fees, arising from a negligent act or omission of a student. As a result of an incident involving a failed blood draw by a student, Patient First was sued. The parties in the suit reached a settlement agreement. CCBC challenged its obligation to indemnify Patient First for the settlement payment and attorneys’ fees, asserting that the liability arose from the Patient First’s own negligence. The circuit court ruled that Patient First was entitled to indemnification. The Court of Appeals affirmed in part and vacated in part, holding (1) the circuit court was not clearly erroneous in concluding that Patient First bore its burden of proving its entitlement to indemnification and that CCBC did not bear its burden of proving, as an affirmative defense, that Patient First was itself negligent and that the liability arose from that negligence; and (2) there was insufficient evidence to support a conclusion that the requested attorneys’ fee award was reasonable. Remanded. View "Bd. of Trs., Cmty. Coll. of Baltimore County v. Patient First Corp." on Justia Law

In 2012, Petitioner voluntarily consented to a search of his person in the form of saliva and penile swabs for the purpose of furnishing DNA evidence to the police department to use in the investigation of a rape allegation. The DNA profile created from the extraction of Petitioner’s DNA excluded Defendant as a suspect of the alleged rape. Defendant’s DNA profile was subsequently uploaded to the local DNA database. Later, an automatic search resulted in a match between Defendant’s DNA profile and a DNA profile associated with an unsolved burglary committed in 2008. Based on that DNA evidence, Defendant was charged with burglary and related charges. Defendant moved to suppress the State’s DNA match evidence on the grounds that the subsequent use of his DNA to conduct a comparison search of the DNA databank exceeded the scope of his consent and therefore constituted an unlawful search under the Fourth Amendment. The suppression hearing judge denied the motion. The Court of Appeals affirmed, holding that, where Defendant’s consent to search was not expressly limited by him, the State, or the law, the Fourth Amendment did not preclude the police from retaining and using Defendant’s DNA profile created from his voluntarily provided DNA sample for additional, unrelated criminal investigations. View "Varriale v. State" on Justia Law

Petitioner, a former employee and a minority shareholder in Quotient Inc., filed this action alleging that he had been oppressed by Clark Lare, whose shares together with those owned by his wife, Jodi Lare, were the majority interest in Quotient. The trial court found that Clark oppressed Petitioner by firing him for refusing to sell his shares. The court ordered an accounting and awarded Petitioner damages, unpaid corporate distributions, and attorneys’ fees. The court, however, declined to dissolve Quotient, to require Quotient to reinstate Petitioner as an employee, or to award other employment-related relief. The court also found that Petitioner failed to meet his burden of proving that Clark’s actions were fraudulent and accordingly declined to award punitive damages. The Court of Appeals affirmed, holding that the trial court did not abuse its discretion in deciding on appropriate relief. View "Bontempo v. Lare" on Justia Law

Shyquille Griffin was indicted on charges related to the shooting of Andrew Lindsey. Pursuant to a plea agreement with the State, Griffin pleaded guilty to attempted robbery. The agreement did not mention restitution. Upon sentencing, the State advised the court that Lindsey was seeking $9,700 in restitution. The circuit court concluded that it could not order restitution because it would violate the agreement by adding to the penalty. Invoking Md. Code Ann. Crim. Proc. 11-103(e), Lindsey filed a motion for reconsideration of restitution and request for hearing (“CP 11-103(e) motion”), arguing that the hearing court improperly denied his request for restitution. The circuit court denied the CP 11-103(e) motion. Lindsey appealed. The Court of Special Appeals reversed, holding that the circuit court had discretion to order restitution as a condition of Griffin’s probation without violating the agreement or Griffin’s double jeopardy rights. The Court of Appeals reversed, holding that Lindsey’s appeal was untimely because Md. Code Ann. Crim. Proc. 11-103(b) does not permit a crime victim to file an application for leave to appeal the denial of a CP 11-103(e) motion. View "Griffin v. Lindsey" on Justia Law

Petitioner was charged in a five-count indictment with burglary and related crimes. On the morning of trial, the prosecutor asked the court to amend Count Four from theft of less than $1,000 to theft of at least $1,000 but less than $10,000. The amendment of Count Four substituted felony theft for misdemeanor theft. The court allowed the amendment of the indictment. After a trial, the jury found Petitioner guilty of fourth degree burglary, theft of goods having a value of at least $1,000, and theft of good valued under $100. The Court of Appeals reversed the conviction, holding (1) the amendment of Count Four of the indictment changed the character of the offense charged, and therefore, the trial court violated Maryland Rule 4-204 in permitting the State, over Petitioner’s objection, to amend the charging document; and (2) that violation was prejudicial per se, entitling Petitioner to a remand for entry of a judgment of conviction and imposition of sentence on the originally charged misdemeanor of theft of property valued at less than $1,000. View "Counts v. State" on Justia Law