Justia Maryland Supreme Court Opinion Summaries

Petitioner was charged with various offenses, including reckless endangerment. Because the indictment did not set out the elements of the charged offense or the factual basis for that offense, Petitioner requested that the State provide him with a bill of particulars. Rather than answer each question Petitioner asked in his request, the State simply directed Petitioner to discovery. The trial court overruled Petitioner’s exceptions, finding that the State’s responses satisfied the statutory requirement that the State’s response “furnish the particulars sought.” A jury found Petitioner guilty of reckless endangerment. Petitioner appealed, arguing that the trial court abused its discretion by denying his exceptions to the State’s non-specific responses to the questions posed in his request for a bill of particulars. The court of special appeals affirmed. The Court of Appeals reversed, holding (1) the State’s responses to the questions posed in Petitioner’s demand for a bill of particulars were inadequate; and (2) therefore, the trial court abused its discretion when it overruled Petitioner’s exceptions to those responses. View "Dzikowski v. State" on Justia Law

Respondents filed a complaint for accounting against Petitioner, their employer, after a dispute over the terms of their employment agreement. In response, Petitioner filed a petition to compel arbitration, asserting that, because Respondents’ claims arose out of their employment agreements, the circuit court was required to compel arbitration under an arbitration clause contained in the employment agreement. The circuit court denied Petitioner’s petition. The intermediate appellate court dismissed Petitioner's appeal, concluding that the denial of Petitioner’s motion to compel arbitration did not constitute a final judgment. The Supreme Court affirmed, holding that an order denying a request to compel arbitration filed in an existing action is not a final judgment because the denial of the petition does not put the parties out of court or otherwise terminate the proceedings and does not deny the party requesting arbitration the means of further prosecuting or defending rights and interests in the subject matter of the proceeding. View "Am. Bank Holdings, Inc. v. Kavanaugh" on Justia Law

In two cases, Montgomery County took a portion of properties owned by Respondents. Because the parties disputed the value paid for either taking the County filed a complaint for condemnation. During the proceedings, the circuit court imposed discovery violation sanctions precluding Respondents from introducing evidence as to the fair market value of the taken properties. Respondents were therefore unable to generate a genuine issue of material fact concerning the County's appraisal valuations. As a result, the circuit court granted summary judgment for the County on the issue of just compensation. The court of special appeals reversed, concluding that summary judgment on the question of just compensation is not available in condemnation proceedings because a property owner cannot be deprived of the constitutional right to have a jury determine just compensation. The Court of Appeals reversed, holding (1) permitting summary judgment does not violate the constitutional right to have the opportunity for a jury trial to ascertain just compensation in compensation actions provided the landowner litigates the case according to the Maryland Rules; and (2) summary judgment was properly granted in each case because there was no genuine dispute of material fact and the County was entitled to judgment as a matter of law. View "Montgomery County v. Soleimanzadeh" on Justia Law

A state trooper pulled over Respondent's vehicle for failing to obey a traffic control device. When the trooper approached the vehicle, he detected a "moderate odor" of an alcoholic beverage on Respondent's breath. The trooper placed Respondent under arrest and, after Respondent refused to take an alcohol content test, Respondent was subjected to a suspension of his driver's license. An administrative law judge affirmed the suspension. The circuit court reversed, holding that the record was "deplete of any sufficient indicia of alcohol use" to establish reasonable grounds for a request to take an alcohol content test. The Court of Appeals reversed, holding that a moderate odor of alcohol emanating from the person of a motorist, alone, constitutes reasonable grounds to request the motorist to take an alcohol test. View "Motor Vehicle Admin. v. Spies" on Justia Law

Petitioner was charged in two cases with second-degree burglary, theft, and malicious destruction of property. Petitioner moved to suppress all evidence obtained as the result of law enforcement's global positioning system (GPS) tracking of his vehicle. The motions were denied, and Petitioner was convicted of various charges arising out of the two cases. While Petitioner's appeal of the convictions was pending, the U.S. Supreme Court decided United States v. Jones, which held that GPS tracking of a vehicle constitutes a search under the Fourth Amendment. The court of special appeals affirmed the consolidated appeals. The Court of Appeals affirmed, holding that Petitioner was not entitled to the suppression of evidence where (1) before Jones, binding appellate precedent in Maryland authorized the GPS tracking of a vehicle on public roads; (2) law enforcement officers acted in objectively reasonable reliance on that authority when they conducted their GPS tracking of Petitioner's vehicle; and (3) the Davis v. United States good-faith exception to the exclusionary rule applied in this case. View "Kelly v. State" on Justia Law

Defendant was assigned the serving rights to Plaintiff's mortgage on a piece of property. Plaintiff sued Defendant, claiming that Defendant attempted to collect more than was due on the loan. The parties settled. Plaintiff then filed this action against Defendant, alleging breach of the settlement agreement, defamation, and violations of the Maryland Consumer Debt Collection Act and the Maryland Consumer Protection Act. An order of default was later entered against Defendant. Defendant subsequently filed a motion for a new trial or to alter or amend the judgment, requesting that the default judgments be set aside because Plaintiff's claims were legally deficient. The trial court denied the motion. The court of special appeals affirmed. The Court of Appeals affirmed, holding that a defaulting party who does not file a motion to vacate the order of default after a default judgment has been entered cannot file a Maryland Rule 2-534 motion to alter or amend a judgment to contest liability, and the defaulting party cannot appeal that judgment in order to contest liability. View "Franklin Credit Mgmt. Corp. v. Nefflen" on Justia Law

A county-owned police patrol vehicle was damaged in a single-car collision while Respondent, a county police officer, operated the vehicle under the influence of alcohol. The County, a self-insured entity, filed a complaint against Respondent seeking to recover the cost of repairs to the vehicle. The district court ruled that the County could recover damages against Respondent based on an exclusion in the self-insurance guarantee purportedly excluding or disclaiming all insurance coverage on the basis that Respondent operated his vehicle under the influence of alcohol. The circuit court reversed. The Supreme Court affirmed, holding (1) Maryland's compulsory motor vehicle insurance scheme does not permit a self-insurer such as the County to disclaim or exclude insurance coverage in a self-insurance guarantee where an individual causes a collision while driving under the influence of alcohol; and (2) the exclusion in the guarantee in this case was invalid because it violated the state compulsory motor vehicle insurance scheme, was not expressly authorized by the General Assembly, and was against public policy. View "Montgomery Co. v. Distel" on Justia Law

In 2010, Wife filed an amended complaint for divorce, alleging that she and Husband were married in 1993 in a civil ceremony in the Democratic Republic of the Congo. At a merits trial, Husband contested the divorce on the premise that he and Wife were never legally married. The circuit court found that a valid marriage between the parties took place even though Husband was not physically present at the wedding ceremony because he participated in the ceremony by telephone. The court then entered a judgment of absolute divorce in Wife's favor. The court of special appeals affirmed the circuit court's judgment that the marriage between the parties was valid. The Court of Appeals affirmed, holding that, under the principles of comity, Maryland recognizes wedding ceremonies where the groom participated only by telephone. View "Tshiani v. Tshiani" on Justia Law

After a jury trial, Petitioner was convicted of first-degree murder and sentenced to life imprisonment. The court of special appeals affirmed the conviction. The Supreme Court affirmed, holding that trial court (1) complied with Md. Code Ann. Crim. Proc. 3-104(a) when it allowed Petitioner to withdraw his request for a competency evaluation and afterwards did not make a competency determination on the record, because Petitioner's withdrawal of his request for a competency evaluation, in addition to the slight evidence on the record to support a finding of incompetency, supported the circuit court's acknowledgment that the issue of competency was moot and the presumption that Petitioner's competency was not rebutted; and (2) properly denied Petitioner's request for an instruction on legally adequate provocation because the evidence presented did not generate such a defense. View "Wood v. State" on Justia Law

Petitioner was charged with murder and other related offenses. During defense counsel's opening statement, counsel referenced Petitioner's willingness to take a lie detector test during his interrogation by the police. The trial judge gave a curative instruction to the jury immediately following the improper reference. Two days further into the trial, the prosecutor filed a motion for a mistrial for reason of that improper remark. The trial judge granted the motion. Petitioner subsequently filed a motion to dismiss, arguing that retrial was prohibited under double jeopardy principles. The court of special appeals affirmed, concluding that the trial judge properly determined that manifest necessity existed for a mistrial, and therefore, double jeopardy principles did not prevent a retrial. The Court of Appeals affirmed, holding that the trial judge did not abuse his discretion in making a determination of manifest necessity to declare a mistrial where the judge considered his previously issued curative instruction and found it insufficient to cure the prejudice caused by defense counsel's improper remark. View "Simmons v. State" on Justia Law