Justia Maryland Supreme Court Opinion Summaries

After Elms Construction Company, owned by Richard Elms (Elms), began installing windows and doors for Renewal by Anderson (Renewal), Elms fell from a ladder and injured his right foot. Elms filed a workers’ compensation claim with the Workers’ Compensation Commission, alleging that he was Renewal’s common law employee at the time of the injury. The Commission concluded that Elms was an independent contractor, rather than a common law employee of Renewal, and was therefore not entitled to collect workers’ compensation benefits. The circuit court reversed, concluding that Elms was Renewal’s common law employee. The court of special appeals vacated the circuit court’s opinion and remanded. The Supreme Court vacated the court of appeals’ opinion and remanded with directions to affirm the circuit court’s judgment, holding (1) the Commission misconstrued the law as applied to the facts when it concluded that Elms was an independent contractor and not an employee of Renewal; (2) the court of special appeals erred when it held that a statutory employment analysis under section 9-508 of the Workers’ Compensation Act must precede a common law employment analysis; and (3) by application of the common law to the facts of this case, Elms was Renewal’s employee at the time of the accident. View "Elms v. Renewal by Anderson" on Justia Law

At issue in this case was whether apportionment of damages is appropriate in the wrongful death and asbestos litigation context and whether a “use plaintiff” - a plaintiff for whom an action is brought in another’s name and does not join in the action - is precluded from recovering damages by not formally joining in the proceedings. In four asbestos cases, plaintiffs and use plaintiffs were separately awarded damages for their wrongful death claims against Wallace & Gale Asbestos Settlement Trust (WGAST). The court of special appeals concluded (1) the failure of the use plaintiffs to join the action as party plaintiffs before the expiration of the relevant statute of limitations precluded the use plaintiffs from recovering damages; and (2) the circuit court erred in refusing to instruct the jury on apportionment of damages. The Supreme Court reversed, holding (1) apportionment of damages is appropriate only where the injury in question is reasonably divisible among multiple causes, and in this case, the resulting injury was not reasonably divisible; and (2) the use plaintiffs in this case were part of the action for purposes of the trial resulting in jury verdicts and money judgments entered in their favor. View "Carter v. Wallace & Gale Asbestos Settlement Trust" on Justia Law

Ex-Wife and Husband entered into a property settlement agreement that included an allocation of future benefits from the retirement plan sponsored by Husband’s employer. The agreement implied that Husband’s retirement plan was regulated by ERISA, although Husband’s plan was exempt from that law, and incorrectly contemplated that the divorce judgment itself would effect the division of the retirement plan benefits. Husband later remarried and designated his new wife (Wife) as his beneficiary under the retirement plan. After Husband died, Ex-Wife filed a complaint alleging that Wife had been unjustly enriched in receiving Husband’s entire pension and death benefits. The circuit court issued an order establishing a constructive trust in favor of Ex-Wife with respect to a portion of the benefits already paid to Wife and ordered the retirement plan to allocate future benefits between Wife and Ex-Wife in a similar manner. The Court of Appeals affirmed, holding that, under the circumstances of this case, the circuit court did not abuse its discretion in issuing a posthumous order directing the retirement plan to allocate a portion of the Husband’s death benefit to Ex-Wife and in imposing a constructive trust on a portion of those benefits already received by Wife. View "Robinette v. Hunsecker" on Justia Law

This case concerned a request for certain public records for specific nutrient management plans (NMP) of various private farming operations. Waterkeeper Alliance, Inc. (WKA) submitted the requests, without success, to the Maryland Department of Agriculture (MDA) pursuant to the Maryland Public Information Act (PIA). Other parties became involved in the ensuing litigation, including the Maryland Farm Bureau, Inc. (MFB). In 2009, the circuit court issued an order (2009 Order) in which it granted the MDA’s cross-motion for summary judgment and denied MFB’s motion for summary judgment. No further litigation activity was reflected on the docket. In 2010, the MDA received another PIA request regarding specific NMP information, this time from a co-plaintiff in the WKA action. In the resulting litigation, the circuit court issued an order (2011 Order) granting MFB’s motion for clarification and declaring how the 2010 PIA request was controlled by the 2009 decision. The court of appeals affirmed. The Supreme Court dismissed the appeal for lack of jurisdiction, holding that the 2011 Order, like the 2009 Order, was not a final judgment, as it did not resolve all the claims before the trial court, and none of the immediate appealability exceptions to the requirement of a final judgment were applicable. View "Waterkeeper Alliance, Inc. v. Dep’t of Agriculture" on Justia Law

In Doe I, the Supreme Court held that the retroactive application of the provisions in the Maryland sex offender registration statute that the Court deemed punitive violated the prohibition against ex post facto laws in the Maryland Declaration of Rights. At issue in this appeal was whether sex offenders’ federal obligations require them independently to register and whether circuit courts have the authority to order the State to remove sex offender registration information from federal databases. The Supreme Court held that, notwithstanding the registration obligations placed directly on individuals by the Sex Offender Registration and Notification Act, circuit courts have the authority to compel the State to remove sex offender registration information from Maryland’s sex offender registry when the inclusion of such information is unconstitutional as established in Doe I. View "Dep’t of Pub. Safety v. Doe" on Justia Law

David Springer was sued by J.G. Wentworth Originations, LLC for, inter alia, engaging in false and misleading advertising, defamation, and false light. Springer was insured under an insurance policy issued by Erie Insurance Exchange. The policy contained a provision that excluded personal liability coverage arising out of “business pursuits.” Erie refused to provide Springer with a legal defense in the J.G. Wentworth lawsuit, arguing that the suit was triggered by Springer’s business interests and was thus barred under the “business pursuits” exclusion. The circuit court entered judgment in favor of Erie. The Court of Appeals vacated the judgment of the circuit court, holding that Erie and the trial court should have considered more than the face of the J.G. Wentworth complaint before establishing Springer’s alleged business interests and denying Springer’s claim. View "Springer v. Erie Ins. Exch." on Justia Law

Appellant owned property located within the heart of a planned development. The City of Baltimore sought to condemn the property. When the City and Appellant were unable to agree upon a price to be paid for the property, the City filed a petition for condemnation. Prior to trial, the City filed a petition for immediate possession and title, alleging that immediate possession of the property was necessary. Ultimately, the circuit court concluded that Appellant was a “hold-out,” which justified a “quick-take” condemnation of the property. The Court of Appeals affirmed, holding that the facts of this case justified a “quick-take” condemnation action. View "Makowski v. Mayor & City of Baltimore" on Justia Law

Petitioners obtained a loan from a Lender by taking out a second mortgage on their residence secured by a deed of trust on that property. The Lender sold the loan to another entity, to whom it assigned the loan instruments. That entity, in turn, sold the loan and assigned the loan instruments. After Petitioners had paid off the note and Respondent had released the deed of trust, Petitioners sued the Lender and Respondent, alleging that Lender had violated the Maryland Secondary Mortgage Loan Law (SMLL) at the time of the original transaction. The circuit court granted summary judgment for Respondent. The court of special appeals affirmed, holding (1) Petitioners’ sole recourse against an assignee such as Respondent for the Lender’s violations of the SMLL would be by way of recoupment, but (2) because Petitioners filed suit only after they had paid off the loan, that remedy was not available to them. The Court of Appeals affirmed, holding (1) Respondent was not liable for violations of the SMLL committed by the Lender when the loan was originated, and (2) Respondent was not derivatively liable under statute or the common law for a violation of the SMLL committed by the Lender. View "Thompkins v. Mountaineer Invs., LLC" on Justia Law

In each of these two consolidated cases, plaintiffs brought a negligence action against landlords to recover for injuries resulting from lead paint poisoning. Both plaintiffs relied on circumstantial, rather than direct, evidence that lead paint in the subject properties was a substantial contributor to the injuries. In both cases, the trial judges granted summary judgment to the landlords, concluding that the plaintiffs failed to present a prima facie negligence case with regard to the causation element. The Court of Appeals affirmed after setting forth principles under which a lead-paint poisoned plaintiff may establish through circumstantial evidence a prima facie negligence case for lead paint poisoning, holding that plaintiffs in this case failed to meet their initial burden of proving circumstantially a prima facie negligence case. View "Hamilton v. Kirson" on Justia Law

Defendant was charged with one count of murder in the first degree. The case proceeded to trial. During the jury’s deliberations and at 5 p.m. on the Friday before a three-holiday weekend, the foreperson of the jury submitted a note to the trial judge claiming that a fellow juror stated that she was willing to change her original position of voting “not guilty” if she could go home and not return to the courthouse. One-half of an hour later, the judge reminded the jurors of their proper duties. The following Tuesday, the jury found Defendant guilty of murder in the first degree. Defendant appealed, arguing that the trial judge should have granted a mistrial based on the allegations in the note. The court of special appeals disagreed with Defendant and affirmed. The Court of Appeals affirmed, holding that the trial judge, in dealing with the note, (1) did not abuse her discretion in denying Defendant’s motion for a mistrial and in refusing to give a modified Allen instruction; and (2) did not violate Maryland Rule 4-326(d) by recessing for the long weekend after giving additional instructions to the jurors. View "Nash v. State" on Justia Law