Justia Maryland Supreme Court Opinion Summaries

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

In the second year following each Federal decennial census, the Maryland Constitution provides that the Governor and State Legislature shall reapportion the State's legislative representation in accordance with the State's current demographics. At issue before the Court of Appeals in this case was the validity of Maryland's most recently enacted legislative apportionment plan. Three petitions challenging the enacted plan were filed. After a hearing, a Court of Appeals' Special Master denied each petitioner's petition and issued his recommendation that the enacted legislative apportionment plan be upheld against each of the challenges. The Court of Appeals supported the order of the Special Master, holding that Petitioners' exceptions to the Special Master's findings and recommendations were without merit. View "In re 2012 Legislative Districting of the State" on Justia Law

After a jury trial, Petitioner was convicted of multiple counts of second degree murder and other crimes. The court of appeals affirmed, concluding that the trial court erred in prohibiting Petitioner's cross-examination of a State's witness regarding the witness' expectation of leniency in a separate pending case should he testify against Petitioner but that the error was harmless. The Court of Appeals reversed, holding (1) the trial court erred in limiting Petitioner's cross-examination of the witness with regard to his expectation of leniency; and (2) contrary to the conclusion of the intermediate appellate court, the effect of that error was not harmless to the result of the trial. View "Dionas v. State" on Justia Law