Justia Maryland Supreme Court Opinion Summaries

Mark Hranicka filed a workers’ compensation claim as a result of an injury he sustained during a motor vehicle accident. The workers’ compensation claim was withdrawn. Thereafter, Hranicka submitted to the Workers’ Compensation Commission a second claim. The claim was electronically submitted to the Commission before expiration of the two-year statute of limitations but not filed on paper until after the expiration of the two-year period. Respondents contested the claim, arguing that it was time-barred under Md. Code Ann. Lab. & Empl. 9-709(b)(3). The Commissioner determined that the claim was not time-barred. The Supreme Court reversed, holding that electronic submission of a claim does not constitute “filing” pursuant to Code of Maryland Regulations, and therefore, the Commission erred in ruling that the filing date of a claim could be the date of the claim’s electronic submission for purposes of the statute of limitations. View "Hranicka v. Chesapeake Surgical, Ltd." on Justia Law

These proceedings involved a development project spearheaded by K. Hovnanian’s Four Seasons at Kent Island, LLC (Appellee). Appellee obtained all of the necessary permits and approvals from state and local agencies, except one. At issue in these proceedings was Appellee’s application for a State wetlands license. Appellee filed a complaint for declaratory and injunctive relief and for a writ of mandamus against the Board of Public Works seeking an order compelling the Board to vote promptly on Appellee’s long-outstanding application for the wetlands permit following delays resulting from a perceived appearance of impropriety. The circuit court granted the requested relief and ordered the Board to vote promptly on the application. The Court of Appeals vacated the judgment, holding that the circuit court’s order was improper for want of a prior final administrative decision and because mandamus was unavailable under the circumstances. View "Bd. of Pub. Works v. K. Hovnanian's Four Seasons at Kent Island, LLC" on Justia Law

Plaintiff filed a medical malpractice complaint against Respondent-doctor alleging that Respondent was negligent in failing to diagnose and treat her post-surgical infection. Because Plaintiff failed to file the required expert report to prosecute her first claim against Respondent, Plaintiff voluntarily dismissed the complaint. Plaintiff later filed a three-count complaint that was similar to her first complaint and that included a new claim of negligence related to her initial surgery. The circuit court dismissed the complaint because the claim was filed after the expiration of the relevant period of limitations. The Court of Appeals affirmed, holding that Plaintiff could not rely on the saving provision of Md. Code Cts. & Jud. Proc. 5-119(b) to refile her untimely claim because she voluntarily dismissed her previous claim. View "Wilcox v. Orellano" on Justia Law

Petitioners purchased real property comprised of two lots in a community of single family homes in Hampton. Petitioners later purported to subdivide their property to create an additional undeveloped parcel, which Petitioners offered for sale as separate and buildable. The Hampton Improvement Association (HIA) responded that the restrictive covenants prohibited property owners from erecting more than one house per deeded lot. Petitioners filed a complaint for declaratory relief seeking a declaration that their property consisted of two separate buildable lots and that the restrictive covenants did not prohibit the building of a home on the second lot. The circuit court denied relief. The Court of Special Appeals affirmed, concluding that the circuit court (1) correctly denied the Shaders’s attempted use of offensive non-collateral estoppel, and (2) properly found that the restriction prohibiting the construction of more than one dwelling on a single lot was not abandoned by the HIA. The Court of Appeals affirmed, holding that the circuit court did not err in determining that (1) the HIA was barred from relitigating the enforcement of the restrictive covenants due to a prior judgment entered against the HIA, and (2) the HIA did waive by abandonment the restrictions allowing the construction of numerous buildings. View "Shader v. Hampton Improvement Ass'n" on Justia Law

At issue in these two consolidated civil cases was the circumstances under which an insurer providing uninsured (UM) motorist coverage may disclaim any such liability owed to its insured. In these cases, Petitioners sued their UM carriers for breach of contract. The Court of Special Appeals affirmed the judgments in favor of the UM carriers in both cases, concluding that Petitioners’ failure to comply with the statutory UM coverage settlement procedures were fatal to their claims. The Court of Appeals affirmed, holding that the Court of Special Appeals did not err in concluding that (1) the UM carrier did not waive its right to receive written notice of a pending settlement with the tortfeasor’s insurance carrier even where there was unequivocal testimony from Petitioner’s counsel that he received oral consent to settle from a UM carrier claims representative; and (2) the UM carrier did not bear the burden of proving prejudice arising from Petitioners’ failure to give written notice of the pending settlement with the tortfeasors’ insurance carrier. View "Woznicki v. GEICO Gen. Ins. Co." on Justia Law

Pursuant to a binding plea agreement, Defendant pleaded guilty to two counts of first degree murder. Two decades after he was sentenced, Defendant filed a motion to correct illegal sentence and motion for credit against time spent in custody, arguing that his sentence on Count I was illegal because it exceeded the sentence agreed upon by the parties under the terms of the plea agreement. The State responded by moving to correct the entire sentence, contending that the sentences on both Count I and Count III were illegal. The circuit court concluded that the sentences on both counts were illegal and ordered a resentencing in accordance with the original plea agreement. The Court of Special Appeals affirmed, agreeing that Defendant’s original sentence on Count III was illegal because it was below the binding plea agreement. The Court of Appeals affirmed, holding that a sentence below a binding plea agreement constitutes an illegal sentence within the meaning of Maryland Rule 4-345(a). View "Bonilla v. State" on Justia Law

Respondent filed in the circuit court a “complaint for title by adverse possession and bill to quiet title” against Petitioners concerning the ownership of a piece of land known as the Landing on Watts Creek (the Landing). Respondents answered and filed a countercomplaint alleging that they held title to the Landing and that Respondent’s use of the Landing constituted trespass. The circuit court ruled that Respondent had established a claim to the Landing by adverse possession. The Court of Special Appeals affirmed. The Court of Appeals affirmed, holding (1) the “woodlands exception,” previously applied only to prescriptive easements, also applies to adverse possession where the land at issue is unimproved or otherwise in a general state of nature; (2) the “woodlands exception” does not apply under the circumstances of this case, and therefore, no presumption of permissive use arose; and (3) because Petitioners failed to meet the burden of demonstrating permissive use, both the Court of Special Appeals and the circuit court were correct in holding that Respondent obtained title to the Landing by adverse possession. View "Breeding v. Koste" on Justia Law

Here the Court of Appeals decided whether to overrule Allied Inv. Corp. v. Jasen, in which the Court held that a defendant does not convert a plaintiff’s intangible property where the defendant does not convert a document that embodies the plaintiff’s right to the plaintiff’s intangible property. In this case involving a life insurance policy a jury found Defendant, an insurance broker, liable for negligence, negligent misrepresentation, deceit, conversion, and constructive fraud. The Court of Special Appeals reversed and remanded, holding that Plaintiffs failed to establish claims for conversion and constructive fraud. Plaintiffs appealed, urging the Court of Appeals to overrule Jasen and arguing that a defendant converts a plaintiff’s intangible property by interfering with the plaintiff’s right to the the intangible property, even if the defendant does not convert a document that embodies the plaintiff’s right to the plaintiff’s intangible property. The Court of Appeals affirmed, holding that the circuit court erred in denying Defendant’s motion for judgment notwithstanding the verdict as to conversion, as Defendant did not convert the life insurance policy, and as to constructive fraud, as Plaintiffs failed to establish that the parties were in a confidential relationship. View "Thompson v. UBS Fin. Servs." on Justia Law

These three cases, consolidated for the purposes of this opinion, involved the same legal issues arising out of the Court of Appeals’ opinion in Griffin v. State, in which the Court addressed the admissibility of a screenshot of a MySpace page. This appeal addressed Griffin’s application to the authentication of screenshots of messages allegedly sent through social networking websites. In the three cases, the messages were sent via a Facebook timeline, on Twitter through direct messages and public tweets, and through Facebook messages. The Court of Appeals held that, “in order to authenticate evidence derived from a social networking website, the trial judge must determine that there is proof from which a reasonable juror could find that the evidence is what the proponent claims it to be.” Accordingly, the Court held that, in each of the cases, the trial court did not err in (1) excluding the admission of the four pages of the Facebook conversation; (2) admitting the “direct messages” and “tweets” in evidence; and (3) admitting the Facebook messages authored by the defendant. View "Sublet v. State" on Justia Law

Plaintiff, a towing company, filed a complaint and requested a declaratory judgment, a temporary restraining order, and both a preliminary and permanent injunction against the State and other governmental entities, alleging that two towing statutes enacted by the General Assembly in 2012 - Md. Code Ann., Transp. 21-10A-04(a)(3) and (a)(7) - are arbitrary, oppressive, and unreasonable, as well as unconstitutional. The trial judge granted Plaintiff’s requests for declaratory and injunctive relief. The State appealed, and the Court of Special Appeals certified to the Supreme Court three questions of law. The Court of Appeals answered the first question in the negative, thereby eliminating the need to address the remaining questions, holding that there was not a justiciable controversy where Plaintiff had not been prosecuted under the statutes, nor did Plaintiff allege or prove that there was a credible threat of prosecution for the acts proscribed by the statutes. Remanded with instructions to dismiss. View "State v. G & C Gulf" on Justia Law