Justia Maryland Supreme Court Opinion Summaries
Robinson v. State
After a jury trial, Defendant was convicted of conspiracy to commit first degree burglary. The court of special appeals affirmed the conviction. At issue before the Court of Appeals was whether the trial court committed reversible error in giving an "anti-CSI effect" instruction to the jury after defense counsel remarked in opening statement that no scientific evidence existed linking Defendant to the crimes for which he was charged. The Court of Appeals reversed, holding (1) an "anti-CSI effect" instruction, limited only to curative administration, shall not be entertained without legal and empirical proof that a "CSI effect" exists, and is only triggered when a material misstatement of law occurs; and (2) the trial court erred in this case by giving the contested instruction. Remanded for a new trial. View "Robinson v. State" on Justia Law
Posted in:
Criminal Law
Mathews v. Cassidy Turley Md., Inc.
After Petitioner sold certain properties, he used the proceeds to purchase fractional interests in commercial office buildings. The fractional interests were called Tenants in Common Interests (TICs), and each of the TICs was promoted by a company called DBSI, Inc. DBSI later filed a petition for bankruptcy, and the properties underlying Petitioner's TICs became the subject of foreclosure proceedings. The bankruptcy court determined that many of DBSI's transactions were fraudulent. Petitioner filed a complaint against Cassidy Turley Maryland (Defendant), under whose advice Petitioner acted in purchasing the TICs, alleging that Defendant failed to disclose material facts regarding the investment. The circuit court granted summary judgment for Defendant. The Court of Appeals affirmed in part and reversed in part, holding (1) Petitioner's investment in this case was a "security" for purposes of the Maryland Securities Act; (2) the circuit court erred in determining that Petitioner's claims under the Act relating to fraud and misrepresentation by Defendant were barred by limitations; (3) the court erred in concluding that Petitioner's common law tort claims were time-barred as a matter of law; and (4) the court did not err in deciding to reserve judgment on the admissibility of a bankruptcy examiner's report until it had further information. View "Mathews v. Cassidy Turley Md., Inc." on Justia Law
Ellis v. Housing Auth of Baltimore County
These two consolidated appeals concerned two appellants who separately sued the Housing Authority for Baltimore County (HABC) for negligence and violations of the Maryland Consumer Protection Act (CPA) for injuries arising out of Appellants' alleged exposure to lead paint in properties that HABC owned and operated. The circuit court granted summary judgment in favor of HABC, finding that Appellants in both cases did not substantially comply with the notice requirement of the Local Government Tort Claims Act (LGTCA). The Court of Appeals affirmed, holding (1) the circuit court properly concluded that Appellants did not substantially comply with the LGTCA notice requirement; (2) the circuit court did not abuse its discretion in determining that Appellants did not show good cause for their failure to comply with the LGTCA notice requirement; and (3) the LGTCA notice requirement, as applied to a minor plaintiff in a lead paint action against HABC, does not violate Article 19 of the Maryland Declaration of Rights.
View "Ellis v. Housing Auth of Baltimore County" on Justia Law
Posted in:
Consumer Law, Injury Law
Butler v. S&S P’ship
Petitioner filed a complaint against multiple defendants alleging negligence and violations of Maryland's Consumer Protection Act (CPA) for injuries resulting from his exposure to lead-based paint when he lived at two properties in Baltimore City while he was an infant. At the close of discovery, Defendants filed several dispositive and evidentiary motions, which the trial court granted. The court of special appeals affirmed. At issue before the Court of Appeals was the exclusion of a lead test report, the exclusion of testimony by Petitioner's medical expert, and the grant of summary judgment as to Petitioner's CPA cause of action. The Court of Appeals reversed in part and affirmed in part, holding (1) the court of special appeals erred in holding that the trial judge did not abuse her discretion in excluding the lead test report and the testimony by Petitioner's medical expert; and (2) the court of special appeals did not err in affirming the circuit court's grant of summary judgment as to Petitioner's cause of action under the CPA. Remanded. View "Butler v. S&S P'ship" on Justia Law
Posted in:
Consumer Law, Injury Law
Sturdivant v. Dep’t of Health & Mental Hygiene
Plaintiffs here were employees who had been laid off from their jobs at a State psychiatric hospital and, when the hospital filled vacancies for positions comparable to those previously occupied by the laid-off employees, were not rehired in order of seniority. An administrative law judge denied Plaintiffs' grievance, concluding that they did not have a right to be rehired under a reinstatement process. The circuit court affirmed. The court of special appeals remanded the case for further factfinding, concluding (1) there is no statutory preference for reinstatement, as opposed to recruitment, in the State Personnel Management System; but (2) if an agency elects to fill vacancies through recruitment, it must follow statutory procedure that includes public notice and transparency as to the selection criteria. The Court of Appeals affirmed, holding (1) the lower court correctly analyzed the legal issue concerning the interpretation of State personnel law; and (2) because the record did not definitely answer the question whether the agency in this case was filling vacancies by a reinstatement process, rather than recruitment, remand for further factfinding was appropriate. View "Sturdivant v. Dep't of Health & Mental Hygiene" on Justia Law
Miles v. State
After a jury trial in 1998, Appellant was convicted of murder and sentenced to death. In 2011, Appellant filed a second motion to correct an illegal sentence, claiming that his death sentence was unconstitutional and illegal under Article 16 of the Maryland Declaration of Rights, which provides that "sanguinary Laws ought to be avoided as far as is consistent with the safety of the State[.]" Appellant claimed that at the time the clause was adopted as Article 14 in 1776, a sanguinary law meant the death penalty for any crime, and therefore, Article 14 abrogated capital punishment for any offense that did not impact State security. The circuit court denied Appellant's motion. The Court of Appeals affirmed, holding (1) where death was the common law penalty for murder and the sanguinary laws clause applied only to legislative action, the death penalty was not abrogated by Article 14; and (2) if the sanguinary laws clause was retroactive, it was not intended to include death as a possible penalty for murder. View "Miles v. State" on Justia Law
Williams v. State
After a jury trial, Petitioner was convicted of controlled substance and resisting arrest offenses. The court of special appeals affirmed, holding (1) the trial court did not violate Maryland Rule 4-215(e) by failing to respond to a letter Petitioner sent to the court prior to trial seeking to discharge his counsel; and (2) the evidence was sufficient to support Petitioner's conviction for resisting a lawful arrest. The Court of Appeals reversed in part and affirmed in part, holding (1) Petitioner's letter to the trial court was sufficient to trigger Rule 4-215(e), and the trial court's failure to inquire into the reasons behind Petitioner's request to discharge counsel was reversible error; and (2) the court of special appeals did not misinterpret Maryland's resisting arrest statute in finding that the evidence was sufficient to support Petitioner's conviction for resisting arrest. Remanded. View "Williams v. State" on Justia Law
Holt v. State
Petitioner was charged with assault, reckless endangerment, firearms violations, and a drug-related offense. Petitioner sought to suppress detectives' observations during and after an investigatory stop of Petitioner on the ground that the stop violated the Fourth Amendment. The suppression court granted Petitioner's request, determining that the investigatory stop violated the Fourth Amendment because the detectives did not have a reasonable suspicion that Petitioner had committed a drug-related crime or a traffic infraction. The court of special appeals reversed. The Court of Appeals affirmed, holding that, although the suppression court correctly concluded that the series of acts the detectives observed were by themselves innocent, taken together, those acts supported the detectives' suspicion that Petitioner was engaged in criminal activity. View "Holt v. State" on Justia Law
Litz v. Md. Dep’t of Env’t
Petitioner owned land in the Town of Goldsboro in Caroline County. Lake Bonnie provided the water source for the property, on which Petitioner operated a campground. In the mid-1990s, the Maryland Department of Environment (MDE) reported water quality impacts on Lake Bonnie due to failing septic systems in the Town and ordered the Town to take action regarding the septic systems. As of 2010, however, the Town had failed to comply with the order, and MDE had failed to enforce the order. Consequently, Lake Bonnie was polluted, the campground was destroyed, and the bank foreclosed on Petitioner's property. Petitioner sued the Town, County, MDE, and State, alleging several causes of action. All counts were dismissed against the Town, County, and State. The court of appeals affirmed. The Supreme Court affirmed in part and reversed in part, holding (1) because it was not clear from the face of her complaint that Petitioner's causes of action for negligence, trespass, and inverse condemnation were barred by limitations, the court of special appeals erred in affirming the motion to dismiss on those counts; and (2) Petitioner's causes of action for nuisance were barred by limitations, and the court of appeals correctly affirmed the motion to dismiss. View "Litz v. Md. Dep't of Env't" on Justia Law
In re Ryan W.
Ryan W. entered the care of the Department of Social Services at age nine as a child in need of services (CINA) and was placed in foster care. After Ryan's parents died, the Department was appointed by the Social Security Administration (SSA) as Ryan's representative payee for Old Age and Survivor's Disability Insurance (OASDI) benefits to which Ryan was entitled. The Department received Ryan's benefit payments and applied them to partially reimburse itself for the current cost of Ryan's foster care. The circuit court determined that the Department violated Ryan's due process and equal protection rights by failing to notify him before applying his OASDI benefits toward the current costs incurred by the Department on his behalf. The court of special appeals reversed. The Court of Appeals affirmed in part and reversed in part, holding (1) a local department of social services, acting in the capacity as an institutional representative payee appointed by the SSA, has discretion to apply a CINA foster child's OASDI benefits to reimburse the Department for its costs incurred for the child's current maintenance; but (2) the department must provide notice to the child that the department applied to the SSA and received such benefits on the child's behalf. View "In re Ryan W." on Justia Law