Justia Maryland Supreme Court Opinion Summaries

In two separate cases, Petitioner was convicted of second-degree murder and two counts of solicitation to obstruct justice, among other offenses. The cases were consolidated for appeal, and the court of special appeals affirmed. At issue before the Court of Appeals, among other things, was whether the trial court abused its discretion in disqualifying one of Petitioner’s defense counsel, who had a previous attorney-client relationship with a key state’s witness, where the witness refused to waive the conflict of interest and Petitioner’s counsel had arranged for co-counsel to cross-examine the witness. The Court of Appeals affirmed, holding (1) the trial court did not abuse its discretion in disqualifying Petitioner’s attorney, as Petitioner’s waiver of the conflict was not sufficient to cure the conflict; and (2) merger was precluded for convictions of the two counts of solicitation, where the relevant statutes contained parallel anti-merger provisions. View "Alexis v. State" on Justia Law

Prince George’s County enacted a resolution creating the Victoria Falls Special Taxing District (District) under authority granted by a State enabling act (Act). Taxpayers challenged the resolution and sought tax refunds. The tax court denied the Taxpayers’ claims. The circuit court and intermediate appellate court affirmed. The Supreme Court affirmed, holding (1) the tax court properly upheld the County’s resolution creating the District, where changes in land ownership within the District occurred after the time of application for creation of the District but before final action on the application, as the State Legislature did not intend to require that the County determine whether any change in land ownership may have affected the super-majority landowner requirement expressed in the Act for applying for the District; and (2) the tax court properly ruled that the County’s approval of the request to create the District that did not include twenty-five of the 609 lots contained within the planned Victoria Falls community was lawful under the Act’s requirement that the District be used to finance infrastructure improvements in “any defined geographic region within the county.” View "Victoria Falls Comm. for Truth in Taxation, LLC v. Prince George's County" on Justia Law

Petitioner was charged with certain traffic offenses in the district court. The district court acquitted Petitioner as to the charge of disobeying a lawful order or direction of a police officer but convicted Petitioner of four counts of fleeing and eluding police. Petitioner filed notice of a de novo appeal. Prior to trial, Petitioner filed a motion to dismiss the fleeing and eluding counts, arguing that, because he was acquitted of disobeying a lawful order, prosecution of the fleeing and eluding charges would violate the state and federal prohibitions against double jeopardy. The circuit court denied the motion. The Supreme Court affirmed, holding that prosecution of the fleeing and eluding charges did not violate the prohibitions against double jeopardy or the doctrine of collateral estoppel. View "Scriber v. State" on Justia Law

After a jury trial, Petitioner was found guilty of two counts of first-degree murder and related offenses. Petitioner appealed the denial of his motion to suppress the contents of a storage locker belonging to him, arguing that it was the tainted fruit of the consent he had given to police while he was unlawfully detained at the police station. The court of special appeals affirmed the conviction. The Court of Appeals affirmed, holding (1) the police obtained Petitioner’s consent to search his locker during their lawful detention of him; and (2) therefore, the suppression court correctly ruled that Petitioner was not entitled to suppression of the evidence found in the locker. View "Barnes v. State" on Justia Law

Ember Buckley was a passenger in a motor vehicle driven by Harvey Betts when the vehicle was involved in an accident. Buckley, who sustained injuries in the accident, settled with GEICO, Betts’ insurer, for the full policy limits and signed a full release of all claims against Betts and a hold harmless agreement in favor of GEICO. Buckley then attempted to recover for the remainder of her outstanding medical bills under her uninsured/underinsured motorist (“UM”) policy with The Brethren Mutual Insurance Company (“Brethren”), which denied coverage. Buckley filed suit, alleging breach of contract and seeking the policy limit in compensatory damages. The circuit court entered summary judgment for Brethren, concluding that the release was a general release, and thus released all entities from future claims, regardless of whether they were a party to the release. The court of special appeals reversed, holding that the general release did not prejudice Buckley’s claim against Brethren. The Court of Appeals affirmed, holding (1) the broad, all-inclusive language of the release must be read with an eye toward the parties’ overall intent; and (2) that the court of special appeals correctly held that the release did not waive Buckley’s UM claim against Brethren. View "Brethren Mut. Ins. Co. v. Buckley" on Justia Law

Defendant was charged with misuse of telephone facilities and harassment. Prior to the start of trial, Defendant’s public defender informed the court: “Your Honor, on behalf of [Defendant], I’d request a postponement. He indicates that he would like to hire private counsel in this matter.” The trial judge denied postponement, and, after a trial, Defendant was convicted as charged. Defendant appealed, arguing that reversal was required because the trial court denied his request to obtain private counsel without complying with the requirements of Md. R. Crim. P. 4-215(e). The court of appeals affirmed, concluding that Defendant did not express a “clear intent” to discharge or replace his attorney, and therefore, Rule 4-215(e) was not implicated. The Court of Appeals reversed, holding (1) when an ambiguous statement by a defendant or his or her counsel is made under Rule 4-215(e), the trial judge must engage in a Rule 4-215(e) colloquy with the defendant; and (2) in this case, the trial judge could have reasonably concluded from defense counsel’s statements that Defendant wanted to discharge his attorney and thus had a duty to engage in a Rule 4-215(e) colloquy with Defendant. View "Gambrill v. State" on Justia Law

After she was injured in a motor vehicle accident, Petitioner filed suit against Charles Serio, the tortfeasor. Petitioner’s motor vehicle insurer, GEICO, with whom Petitioner had underinsured motorist (“UM”) coverage, intervened as a defendant to protect its possible interest in the litigation. At trial, the parties stipulated that Serio was at fault for the accident, and the only issues before the jury were causation and damages. Petitioner’s counsel offered a proposed jury instruction on the nature of UM coverage, but the trial court refused the instruction, noting that insurance was not the issue at trial. The jury returned a verdict in favor of Petitioner for the amount of her medical bills but did not award damages for future medical expenses or pain and suffering. Petitioner unsuccessfully filed a motion for a new trial, arguing in not giving an instruction about the nature of UM coverage, the trial court confused the jury. The Court of Appeals affirmed, holding that the trial court did not err in declining to instruct the jury about the reason Plaintiff’s UM carrier was a party to the tort suit because the issue of UM coverage was not before the jury. View "Keller v. Serio" on Justia Law

At issue in this case was Chapter 286 of the 2007 Session Laws of Maryland. The legislation revised existing law by replacing ejectment with a lien-and-foreclosure process for defaulting lessees of ground leases when more than six months of rent is overdue. Plaintiffs, a group of lessors holding ground leases, brought an action against the State challenging Chapter 286 on constitutional grounds, claiming that the Legislature impermissibly abrogated their vested rights. The State counted that the legislation simply substituted one remedy for another remedy that achieves the same purposes. The circuit court held that the General Assembly exceeded its power and that Chapter 286 operated as an unconstitutional taking of the ground lease holder’s property. The Court of Appeals affirmed, holding (1) the foreclosure-and-lien remedy of Chapter 286 does not provide the same safeguards for leaseholders as the prior ejectment remedy did; (2) accordingly, the foreclosure-and-lien remedy cannot effectively replace the ejectment remedy, which is essential for the right of re-entry in Maryland ground rents; and (3) thus, Chapter 286 cannot survive constitutional scrutiny because the right of re-entry is vested in ground rents entered prior to its enactment. View "State v. Goldberg" on Justia Law

This case concerned a dispute over the paving of a parking lot located on park land leased to a restaurant. A formal agreement between the restaurant and a community organization restricted the paving of the property, and the restriction was incorporated in administrative zoning orders. Still, the lot was paved. Baltimore County was, in this case, landlord of the property, code enforcer, and final administrative adjudicator of disputes arising under local land use laws. As administrative adjudicator, the County forbade the paving. As landlord, the County directed its tenant, Oregon, LLC, to pave the lot. As code enforcer, it refrained from taking action in response to the apparent violation of a final administrative order issued by the Board of Appeals. Plaintiffs brought suit against the County and Oregon seeking declaratory and mandamus relief. The circuit court ruled against Plaintiffs. The court of special appeals affirmed, concluding that Plaintiffs had failed to exhaust administrative remedies. The Court of Appeals largely affirmed, albeit on different grounds, holding (1) Plaintiffs need not initiate an administrative proceeding to pursue enforcement of the Board’s orders; (2) the circuit court properly granted summary judgment with respect to the mandamus counts of the complaint; and (3) the circuit court has authority to issue a declaratory judgment as to whether the Board’s orders were violated. Remanded. View "Falls Road Cmty. Ass’n, Inc. v. Baltimore County" on Justia Law

A holding company, whose subsidiaries owned power-generating facilities, filed a complaint against multiple insurers regarding the terms of liability policies the company purchased in the 1970s and 1980s. At issue in this case was whether New York or Pennsylvania law applied to the interpretation of the policies. The circuit court granted summary judgment in favor of the holding company, determining that Pennsylvania law governed the interpretation of the policies. One of the insurers, TIG Insurance Company (“TIG”), appealed. The court of special appeals affirmed, concluding that there was no genuine dispute of material fact that the insurance contracts were made in Pennsylvania, and therefore, Pennsylvania law applied to the policies at issue. The Court of Appeals affirmed and adopted the opinion of the court of special appeals with the exception of the court’s discussion addressing TIG’s argument that the place of countersigning a policy determines the applicable state law because that argument was not preserved for appeal. View "TIG Ins. Co. v. Monongahela Power Co." on Justia Law