Justia Maryland Supreme Court Opinion Summaries

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

Appellant financed the purchase of a car over time pursuant to a loan contract. The car dealer assigned the contract to Appellee, a financial services company. Because Appellant stopped making payments before the loan was paid off, Appellee repossessed and sold the car. Appellant sued Appellee, alleging that the repossession and sale of the car did not comply with the Credit Grantor Closed End Credit Law (CLEC). The circuit court dismissed the complaint, concluding (1) Appellant’s statutory claims were untimely under the Maryland Equal Credit Opportunity Act’s one-year statute of limitations, and (2) Appellant’s complaint did not state a cause of action for breach of contract because the requirements of CLEC were not incorporated into the contract as to Appellee. The Court of Appeals reversed, holding (1) an action alleging a violation of CLEC must be brought no later than six months after the loan is satisfied pursuant to the CLEC’s statute of limitations, and therefore, Appellant’s claims under CLEC on limitations grounds were improperly dismissed; and (2) Appellant may assert a contract claim against Appellee because the loan contract adequately incorporated CLEC as part of the contractual obligations, and Appellee voluntarily accepted that provision in taking the assignment. View "Patton v. Wells Fargo Fin. Md., Inc." on Justia Law

Wife and Husband married in 2003. In 2005 and 2008, Wife and Husband executed marital settlement agreements. In 2009, Husband filed a complaint for divorce, alleging that the separation agreements were voidable at his demand. In support of his demand, Husband argued that the attorney, who earlier assisted the Wife in obtaining permanent resident status and in the United States and largely served as scrivener to the settlement agreements, violated the Maryland Lawyers’ Rules of Professional Conduct by failing to obtain Husband’s informed consent to her representation of Wife in connection with the two settlement agreements. The circuit court held that the separation agreements were not voidable and entered a judgment of absolute divorce in which the separation agreements were incorporated. The intermediate appellate court affirmed. The Court of Appeals affirmed, holding that sufficient grounds to render the agreements voidable were not present in this case. View "Li v. Lee" on Justia Law

The State charged Petitioner with various drug-related crimes. Petitioner’s co-defendant filed three proposed voir dire questions asking whether any prospective juror had ever been the victim of a crime or a member of a law enforcement agency. The circuit court declined to ask any of the proposed voir dire questions. The jury ultimately convicted Petitioner of drug-related crimes. The court of special appeals affirmed. The Court of Appeals reversed, holding (1) a trial court need not ask during voir dire whether any prospective juror has ever been the victim of a crime, but, on request, a trial court must ask whether any of the prospective jurors have strong feelings about the crime with which the defendant is charged; and (2) where all of the State’s witnesses are members of law enforcement agencies and/or where the basis for a conviction is reasonably likely to be the testimony of members of law enforcement agencies, on request, a trial court must ask during voir dire whether any of the prospective jurors have ever been a member of a law enforcement agency. View "Pearson v. State" on Justia Law

After a jury trial, Petitioner was convicted of second degree murder, two counts of attempted second degree murder, and related weapons offenses. The court of special appeals affirmed. During the trial, defense counsel informed the trial court that he had trouble communicating with Petitioner, mentioned that there was “something wrong” with Petitioner, and requested that Petitioner be evaluated. The Court of Appeals granted certiorari to answer the question of whether defense counsel triggered the competency statute, requiring the trial court to order a competency evaluation and make a competency determination. The Court of Appeals affirmed, holding that defense counsel did not trigger the trial judge’s duty to make a competency determination under the circumstances. View "Kennedy v. State" on Justia Law

After a jury trial, Petitioner was convicted of distribution of cocaine and conspiracy to distribute cocaine. The sentencing judge imposed a twenty-five-year mandatory enhanced sentence without the possibility of parole based on Petitioner’s prior drug convictions. Petitioner appealed, alleging that his sentence was illegal under Maryland Rule 4-345(a). The Court of Appeals affirmed, holding (1) Petitioner waived any challenge to the imposition of his sentence because he failed to object during the sentencing proceeding; and (2) even if the Court were to determine that the issue was preserved, the trial court did not err in imposing an enhanced sentence where the evidence was sufficient for the sentencing judge to conclude that Petitioner committed the qualifying predicate offenses beyond a reasonable doubt. View "Bryant v. State" on Justia Law