Justia Maryland Supreme Court Opinion Summaries

In 1980, Appellant was convicted of first degree sex offense, kidnapping of a child under sixteen years of age, and assault and battery. In 2011, Appellant filed a pro se motion for new trial, later referred to as a petition for DNA testing, requesting that the State produce certain scientific identification evidence that might contain biological material and that was related to the judgment of conviction. A circuit court judge found that the State had performed a reasonable search for the requested evidence and that the evidence no longer existed. The Court of Appeals affirmed, holding that the judge’s findings that the State had performed a reasonable search for the requested evidence and that the evidence was no longer in the possession of the State were not clearly erroneous. View "Johnson v. State" on Justia Law

Defendant was criminally charged with failing to perform home improvement contracts and acting as a contractor without a license. Three separate home improvement contracts with different residents formed the basis of the charges. The charges were resolved through a plea agreement. As a condition of his probation, Defendant was ordered to pay restitution to each of the three victims. Defendant failed to make the restitution payments, and the district court determined that Defendant violated his probation in each of the three cases. In the meantime, Defendant was charged with obtaining property or services by issuing a bad check. Defendant pleaded guilty to the bad check charge and to the three probation violation charges. In sentencing Defendant, the circuit court conditioned probation in the bad check case on the payment of restitution to the victims in the home improvement cases. The court of special appeals struck the restitution requirement of Defendant’s probation, concluding that the circuit court was without authority to condition probation in such a manner, but otherwise upheld the sentence. The Supreme Court reversed, holding that the circuit court had authority to condition Defendant’s probation on the bad check conviction on his payment of restitution to the victims of his home improvement fraud. View "State v. Stachowski" on Justia Law

Several plaintiffs (Plaintiffs) asserted claims against one defendant, and one plaintiff asserted a claim against a second defendant. The circuit court awarded summary judgment for the first defendant against all Plaintiffs, but the decision did not resolve the claim against the co-defendant. Over one year later, the claim as to the co-defendant was voluntarily dismissed by way of a stipulation of dismissal. Plaintiffs subsequently sought to appeal the adverse summary judgment ruling. At issue in this case was whether the stipulation of dismissal satisfied the separate document requirement of Maryland Rule 2-601. Under that rule, the date on which the separate document is docketed triggers the thirty-day deadline for filing a notice of appeal under Maryland Rule 8-202(a). The court of special appeals concluded that the appeal was untimely. The Court of Appeals reversed, holding (1) the stipulation of dismissal did satisfy the requirements of Rule 2-601 for a separate document and therefore did not trigger the thirty-day clock for filing a notice of appeal as to the summary judgment ruling; and (2) Plaintiffs’ notice of appeal was timely under Rule 8-602(d). View "Hiob v. Progressive Am. Ins. Co." on Justia Law

After a jury trial, Defendant was convicted of first-degree rape and first-degree sexual offense. The court of appeals affirmed. Defendant filed a petition for a writ of certiorari, which the Court of Appeals granted, contending, among other things, that the trial judge lacked the authority to deny his motion to postpone because only a county administrative judge or that judge’s designee may deny a motion to postpone. The Court of Appeals affirmed, holding (1) a circuit court judge may deny a motion to postpone in a criminal case; (2) the trial judge did not abuse his discretion in denying the motion to postpone to obtain counsel and to review discovery materials; and (3) Defendant’s constitutional right to a speedy trial was not violated in this case. View "Howard v. State" on Justia Law

After a jury trial, Defendant was convicted of several criminal offenses, including second-degree assault of the intent-to-frighten type against Christine Johnson. The court of special appeals affirmed. Defendant appealed, arguing that the evidence was insufficient to support the conviction for second-degree assault of the intent-to-frighten type because Defendant did not know of Johnson’s presence in the apartment at the time of the assault. The Court of Appeals affirmed, holding (1) a defendant can commit second-degree assault of the intent-to-frighten type against a victim of whose presence in particular the defendant does not know; and (2) the evidence to sufficient to support a finding that Defendant knew multiple people were in the apartment. View "Jones v. State" on Justia Law

An Employer appealed from a decision of the Workers’ Compensation Commission (Commission) ordering Employer to pay additional temporary total disability benefits to Employee, who was injured during his employment. After a jury trial, the trial court granted Employee’s motion for judgment and affirmed the award, concluding that the Commission decision was a piece of evidence that needed to be considered by the jury and that Employer was required to introduce the Commission decision into evidence. The court of special appeals reversed, concluding that Appellant was not required to move the award into evidence. The Court of Appeals affirmed, holding that, in a de novo workers’ compensation jury trial, the appellant is not required to move the Commission decision into evidence. View "Gales v. Sunoco & Amer. Zurich Ins." on Justia Law

At issue in this case was whether a borrower may rescind a loan that has not been consummated pursuant to the federal Truth in Lending Act (TILA). Prior to closing on a home refinancing loan, Respondent submitted to the lender a notice of rescission of the loan. Thereafter, Respondent signed a note and deed of trust consistent with the negotiated terms of the loan. The loan proceeds were distributed as previously agreed to by the parties, and Respondent made payments on the note for approximately two years. Respondent subsequently defaulted on the loan, and the home was sold at a foreclosure public auction. Respondent filed exceptions to the foreclosure sale, arguing that he had rescinded the loan. The circuit court overruled the exceptions and ratified the sale. The court of special appeals reversed, holding that the rescission notice was timely because there was no language in 15 U.S.C. 1635 or TILA’s implementing regulation prohibiting a borrower from rescinding a loan prior to consummation of the transaction, and therefore, such an action was supported by statute. The Court of Appeals reversed, holding that, under TILA, a loan may not be rescinded before it is consummated. View "Burson v. Capps" on Justia Law

Respondent was charged with sexual abuse of a minor and related offenses. Prior to trial, Respondent sought, by means of a subpoena duces tecum, access to the victim’s mental health records. The trial court denied Respondent’s request for an in camera review of those records, concluding that Respondent did not sufficiently establish the likelihood that the records sought would provide exculpatory evidence, as required by Goldsmith v. State. Picking up where Goldsmith left off, the Supreme Court affirmed, holding (1) a criminal defendant’s trial rights may prevail over a victim’s right to assert a privilege in his or her mental health records; (2) a criminal defendant is entitled to an in camera review of a victim’s mental health records if the defendant can establish a reasonable likelihood that the privileged records contain exculpatory information relevant to the defense; and (3) in this case, Respondent’s proffer did not meet the required threshold, and therefore, he was not entitled to review the victim’s counseling records. View "State v. Johnson" on Justia Law

Two years after she was raped, the victim reported her suspicion that Petitioner was the rapist. Petitioner went to the police station for an interview but refused to provide a DNA sample. After Petitioner left the station, the police took swabs of the armrests of the chair in which he had sat and submitted those swabs for DNA analysis. That DNA sample matched DNA collected from the victim’s home on the day of the rape. Petitioner was charged with first-degree rape and related offenses. Petitioner filed a pre-trial motion seeking suppression of the DNA evidence. The suppression court denied the motion, concluding that Petitioner had no reasonable expectation of privacy in the DNA evidence left on the chair. The court of special appeals affirmed the denial of the suppression motion. Petitioner filed a petition for a writ of certiorari but conceded that the police lawfully obtained his genetic material from the armrests of the chair. The issue before the Court of appeals was whether law enforcement’s testing of the identifying loci within that DNA material was a search for purposes of the Fourth Amendment. The Court of Appeals affirmed, holding that the DNA testing at issue was not a search under the Fourth Amendment. View "Raynor v. State" on Justia Law

After Respondent’s employment with a corporation was terminated, she sued the corporation and her sibling business partner, alleging that she was terminated without cause in violation of her employment agreement. The written agreement contained a for-cause provision but no definite term of employment. The trial judge found a breach of the employment agreement, concluding that the agreement transformed what had previously been an “at-will relationship” to a “lifetime contract,” and therefore, Respondent could only be terminated for cause, death, or disability. The court of special appeals affirmed in part and reversed in part, holding that the contract was a for-cause contract of continuous duration rather than a lifetime contract, obviating the need for “special consideration.” The corporation appealed. The Court of Appeals affirmed, holding that the employment agreement was not at-will employment nor an oral lifetime employment contract that has been consistently rejected by Maryland courts, but this type of contract was “continuous for-cause” employment. View "Spacesaver Sys., Inc. v. Adam" on Justia Law