Justia Maryland Supreme Court Opinion Summaries

The Supreme Court held that the Maryland Tort Claims Act's (MTCA), Md. Code Ann. State Gov't (SG) 12-104(a)(1), waiver of sovereign immunity as to a "tort action" does not extend to federal statutory claims.Plaintiff brought this action against Defendants, her former employer and supervisor, regarding her termination from Morgan State University (MSU). Because Plaintiff included claims of retaliation in violation of the National Defense Authorization Act (NDAA), 41 U.S.C. 4712, and the American Recovery and Reinvestment (ARRA), Pub. L. No. 11-5, 1553 Defendants removed the suit to federal district court. The district court dismissed the action with prejudice. The United States Court of Appeals for the Fourth Circuit vacated the district court's order and remanded the matter with directions to address whether Maryland has waived state sovereign immunity against federal whistleblower claims by enacting the MTCA. The district court answered the question in the negative. The Supreme Court answered an ensuing certified question by holding that "a tort action" under the MTCA does not include federal statutory claims. View "Williams v. Morgan State University" on Justia Law

The Supreme Court upheld the final determination of the Maryland Department of the Environment to reissue with revisions a general discharge permit to Animal Feeding Operations (AFOs), holding that the Department's final determination was reasonable and complied with applicable water quality standards.The most recent iteration of the general discharge permit the Department issued to AFOs was finalized by the Department pursuant to certain statutory requirements requiring the Department to review and issue or reissue water pollution control permits once every five years. The circuit court vacated the permit and remanded the matter with instructions to incorporate certain water quality standards into the permit. The Supreme Court reversed the judgment of the circuit court, holding (1) the Department's AFO general discharge permit framework was reasonable and consistent with federal and state law; and (2) the Department's decision to evaluate each AFO individually and to require appropriately-tailored best-management practices to control the emissions where they presented a risk of discharge was reasonable and not an abuse of discretion. View "Dep't of Environment v. Assateague Coastal Trust" on Justia Law

The Court of Appeals reversed the judgment of the circuit court convicting Defendant of first-degree murder and related handgun offenses, holding that the circuit court abused its discretion in permitting a firearms examiner to testify, without qualification, that bullets left at a murder scene were filed from a gun Defendant had acknowledged was his, and the error was not harmless.On appeal, Defendant argued that the circuit court abused its discretion in admitting the firearms identification testimony based on testimony, reports, and studies that called into question the reliability of firearms identification analysis. The Court of Appeals agreed and reversed the case for a new trial, holding that the circuit court (1) did not abuse its discretion in ruling that the firearms examiner could testify about firearms identification generally and other information; but (2) erred in permitting the examiner to opine without qualification that the crime scene bullets were fired from Defendant's firearm. View "Abruquah v. State" on Justia Law

The Supreme Court remanded this case for additional fact-finding, holding that this Court declines to reach the merits of the questions for which the Court granted certiorari because additional fact-finding was required as to the origin of a DNA sample collected pursuant to a search warrant.During an investigation in another homicide case the State collected a DNA sample from Petitioner pursuant to a search warrant and developed a DNA profile of Petitioner. The State later charged Petitioner in connection with the homicide but later nol prossed the charges. A DNA profile developed from evidence collected at the crime scene in the instant case matched Petitioner's DNA profile from previous case, and Petitioner was charged with attempted first-degree murder. Petitioner filed a motion to suppress, arguing that his previously-taken DNA sample should have been expunged under section 2-511 of the Public Safety Article. The circuit court denied the motion, concluding that section 2-511 only applies to "arrestee and convicted-offender DNA samples" and not samples gathered pursuant to a search warrant. The Supreme Court held that remand was required because the record was unclear as to whether the circuit court determined that the DNA sample was recovered pursuant to a search warrant or was a so-called arrestee sample or forensic sample. View "Walker v. State" on Justia Law

The Supreme Court reversed the decision of the appellate court affirming the order of the circuit court granting summary judgment in favor of Defendants and dismissing Plaintiff's negligence claim, holding that the circuit court abused its discretion in granting Defendants' motion to preclude the opinions and testimony of Dr. Steven Elliot Caplan, Plaintiff's designated expert in the area of pediatric medicine.Plaintiff alleged that Defendants, who owned and managed property in which Plaintiff lived as a child, were liable for injuries she sustained as a result of exposure to lead-based paint at the property. After Plaintiff designated Dr. Caplan as her expert Defendants moved to preclude his opinions and testimony. The circuit court granted the motion and then entered summary judgment for Defendants, finding that Dr. Caplan lacked a sufficient factual basis for his opinions and that, without his testimony as to causation, Plaintiff was unable to establish a prima facie case of negligence. The Supreme Court reversed, holding (1) in ruling on the motion to preclude, the circuit court erroneously resolved genuine disputes of material fact; (2) therefore, the circuit court erred in granting summary judgment; and (3) Plaintiff presented sufficient evidence to establish a prima facie case of negligence. View "Oglesby v. Baltimore School Associates" on Justia Law

The Supreme Court affirmed the judgment of the appellate court affirming Petitioner's conviction for child sexual abuse and other related sexual offenses, holding that Petitioner was not entitled to relief on his claims of error.At issue on appeal was whether the circuit court erred in granting the State's pre-trial motion to introduce evidence of Petitioner's 2010 conviction for sexual assault against another individual under Md. Cts. & Jud. Proc. Art. (CJP) 10-923, which permits the admission of certain circumstances of prior sexually assaultive behavior in prosecutions for child sexual offenses. The Supreme Court affirmed, holding (1) there is no factor that circuit courts must consider in every case when conducting an analysis under CJP 10-923(e)(4); (2) the motions judge did not abuse his discretion in determining that the probative value of Petitioner's 2010 conviction was not substantially outweighed by the danger of unfair prejudice; and (3) Petitioner waived his remaining argument. View "Woodlin v. State" on Justia Law

The Court of Appeals held that Defendant had a reasonable expectation of privacy in data contained on his hard drive and that the government conducted an unreasonable search by examining data without any authority to do so either by a warrant or an exception to the warrant requirement.At issue was whether the consensual creation of a copy of the hard drive of Defendant's seized laptop computer permanently eliminated Defendant's privacy interest in the hard drive. The circuit court denied Defendant's motion to suppress and ultimately convicted him of three counts of distribution of child pornography. The appellate court reversed, concluding that individuals have a legitimate expectation of privacy in the digital data within their computer and that Defendant's revocation of his consent to examine the data from his laptop precluded a forensic examination of the mirror-image copy of its hard drive without a warrant. The Court of Appeals affirmed, holding that the search in this case was unreasonable after Defendant withdrew his consent. View "State v. McDonnell" on Justia Law

In this appeal stemming from a challenge to Maryland's Digital Advertising Gross Revenues Tax Act the Court of Appeals vacated the orders of the circuit court granting a declaratory judgment that a digital advertising tax was unconstitutional and illegal under federal law the Court of Appeals held that the circuit court lacked jurisdiction over the action.At issue was Maryland's Digital Advertising Gross Revenues Tax Act, codified at Title 7.5 of the Tax-General Article, which imposed a tax on annual gross revenues of certain high revenue businesses derived from state digital advertising services. Plaintiffs, various subsidiaries of Comcast Corporation and Verizon Communications, Inc., filed this action seeking a declaratory judgment that the tax was unconstitutional and illegal. The circuit court granted judgment for Plaintiffs. The Court of Appeals vacated the orders below, holding (1) Plaintiffs failed to exhaust mandatory administrative and judicial review remedies provided in the Tax-General Article for the resolution of tax disputes; and (2) absent exhaustion of the available statutory administrative remedies, the circuit court lacked jurisdiction over the challenge. View "Comptroller v. Comcast" on Justia Law

The Court of Appeals affirmed the judgment of the appellate court reversing the decision of the circuit circuit court that examination of data contained on Defendant's hard drive was not a search in violation of the Fourth Amendment, holding that the government violated Defendant's Fourth Amendment rights in this case.Defendant voluntarily consented to government agents seizing his laptop computer, creating a copy of its hard drive, and searching the data on it. After the copy was made but before the government examined the data Defendant withdrew his consent. Defendant moved to suppress the evidence from the forensic examination of the copy of his laptop's hard drive. The circuit court denied the motion. On appeal, Defendant asserted that he had a legitimate expectation of privacy in the mirror-image copy of his laptop hard drive. The appellate court agreed and reversed. The Court of Appeals affirmed, holding (1) Defendant had a reasonable expectation of privacy in the data contained on his hard drive; (2) because the government did not examine the data before Defendant withdrew his consent Defendant did not lose his reasonable expectation of privacy in the data; and (3) the government conducted an unreasonable search by examining the data without any authority to do so. View "State v. McDonnell" on Justia Law

The Court of Appeals reversed Petitioner's conviction for first-degree murder and use of a handgun in the commission of a crime, holding that the circuit court erred in permitting a firearms examiner to testify, without qualification, that bullets left at a murder scene were fired from a gun that Petitioner had acknowledged was his, and the error was not harmless.In arguing that the circuit court abused its discretion in permitting the firearms examiner's testimony Petitioner cited reports, studies, and testimony calling into question the reliability of firearms identification analysis. The Court of Appeals agreed with Petitioner and reversed and remanded the case for a new trial, holding (1) the reports, studies, and testimony presented to the circuit court demonstrated that the firearms identification methodology employed in this case could not reliably support an unqualified conclusion that the bullets were fired from a particular firearm; and (2) this Court was not convicted, beyond a reasonable doubt, that the error in no way influenced the verdict. View "Abruquah v. State" on Justia Law