Justia Maryland Supreme Court Opinion Summaries

The Maryland Transit Administration (MTA) fired Plaintiff, a bus operator that suffered from a heart condition. MTA terminated Plaintiff's employment for failing to meet the standard adopted by the State establishing that an individual is not qualified to drive a commercial motor vehicle if that individual suffers from certain cardiovascular diseases. The standard had previously been adopted by the United States Department of Transportation (DOT). Plaintiff brought this action in the circuit court, alleging that the MTA violated his rights under the Americans with Disabilities Act (ADA). After a jury trial, MTA was found guilty of discrimination. The court of special appeals reversed, holding that Plaintiff's inability, because of his heart condition, to meet the DOT standards rendered him unqualified as a matter of law for an MTA bus operator position. The Supreme Court affirmed, holding (1) as a matter of law, the MTA's use of the federally-created qualification standard governing drivers suffering from cardiovascular disease satisfied the ADA's requirements of being "job-related" and of "business necessity" and that "performance cannot be accomplished by reasonable accommodation"; and (2) because Plaintiff failed to meet this properly imposed qualification standard, he was not a "qualified individual" under the ADA. View "Zei v. Md. Transit Admin." on Justia Law

The two consolidated criminal cases before the Court of Appeals here involved Jeffrey Valonis, who was convicted of robbery and related criminal charges in a bench trial, and Anthony Tyler, who was convicted of burglary and malicious destruction of property in a bench trial. At issue before the court was whether the amendment to Maryland Rule 4-245(b), which added the language "the court determines and announces on the record" and requires a trial judge to make an explicit finding of jury trial waiver on the record is subject to strict compliance and whether the failure to make such a factual determination is reversible error. The Court remanded the cases for a new trial, holding that in these two cases, the trial judges committed reversible error in failing to comply with the determine and announce requirement of Rule 4-246(b) and thereby failed to demonstrate a valid waiver of Defendants' right to a trial by jury. View "Valonis v. State" on Justia Law

Defendant was charged with third-degree sex offense and sexual solicitation of a minor. To satisfy the age element of the charge for the third-degree sex offense, the State had to prove Defendant was at least twenty-one years old at the time he had the alleged inappropriate contact with a fourteen-year-old girl. To satisfy that element, the State presented the testimony of a police officer, who interviewed Defendant and had an opportunity to examine Defendant's driver's license. Defendant objected to that testimony on hearsay grounds. The State argued that, even if the date of birth was hearsay, it was admissible as an adoptive admission of a party-opponent under Md. R. Evid. 5-803(a)(2). The trial court allowed the detective to testify, and a jury convicted Defendant on both counts. The Court of Appeals affirmed, holding that the trial court did not clearly err in finding that Defendant's conduct of providing the driver's license to the detective constituted an adoptive admission under Rule 5-803(a)(2). View "Gordon v. State" on Justia Law

After a jury trial, Defendant was convicted of rape, kidnapping, and related charges. Nine years later, Defendant filed a revised petition for postconviction DNA testing, which the circuit court granted. Thereafter, because of what Defendant interpreted as "favorable" DNA results, Defendant requested a new trial. The postconviction court denied the motion, concluding that the testing results were unfavorable to Defendant. The Court of Appeals affirmed, holding that, even if the DNA test results could be considered "favorable" evidence, the postconviction court did not abuse its discretion in ruling that the test results did not provide a substantial possibility that Defendant would not have been found guilty if the DNA evidence had been introduced at trial. View "Brown v. State" on Justia Law

Defendant was charged for multiple criminal offenses. Prior to the conclusion of jury deliberations during trial, the jury sent a completed verdict sheet to the trial judge indicating that the jury voted to acquit Defendant on charges of first degree assault, conspiracy to commit first degree assault, and conspiracy to commit robbery. The jury sheet indicated further, however, that the jury had not agreed as to disposition of the charge of robbery and second degree assault. The jury was unable to reach a unanimous verdict regarding the counts as to which it was undecided. The judge declared a mistrial as to all counts. Defendant filed a motion to bar retrial on the charges for which he believed the first jury acquitted him. The motion was denied. The court of special appeals reversed, determining that there was no manifest necessity for a mistrial and that retrial on the three counts for which the jury indicated a unanimous vote on the verdict sheet was barred by double jeopardy. The Court of Appeals affirmed after noting that Maryland law permits partial verdicts under the circumstances present here, holding that retrial of Defendant on the three disputed charges was prohibited by principles of double jeopardy. View "State v. Fennell" on Justia Law

Petitioner was a passenger in a motor vehicle accident in which her husband, the driver, was killed and Petitioner suffered serious injuries. At the time of the accident, Petitioner and her husband had a motor vehicle liability insurance policy with State Farm Auto and an umbrella policy with State Farm Fire and Casualty Company (collectively, State Farm). State Farm denied Petitioner's claim under the umbrella policy pursuant to a household exclusion, which excluded coverage in certain instances for injury the insured's family members. Petitioner contended that the household exclusion in the umbrella policy was void in light of Md. Code Ann. Ins. 19-504.1, which requires an insurer to offer liability coverage for family members in the same amount of liability coverage for nonfamily members under a policy of "private passenger motor vehicle liability insurance." The circuit court ruled in favor of State Farm. The Court of Appeals affirmed, holding that the umbrella policy did not fit within the definition of "private passenger motor vehicle liability insurance" as contained in section 19-504.1, such that State Farm was not required to offer Petitioner and her husband liability coverage for family members in the same amount as the liability coverage for nonfamily members. View "Stickley v. State Farm Fire & Cas. Co. " on Justia Law

When a property or casualty insurer becomes insolvent, the Maryland Property & Casualty Insurance Guaranty Corporation (PCIGC) assumes responsibility for any outstanding claims or litigation. In this case, an insurance company settled a claim with an insured party but became insolvent before the agreement could be approved by a court. Respondents filed a complaint against PCIGC seeking declaratory relief, asking the circuit court to find they settled the claim and that PCIGC was obligated to pay the statutory maximum on both an underlying insurance policy and an umbrella policy. PCIGC sought to challenge the settlement reached by the parties and argued that it should not have to pay its statutory maximum on the policies when the claims stemmed from a single incident. The court of special appeals held (1) PCIGC may challenge a settlement only on limited grounds, such as fraud or collusion, and the corporation bears the burden of proving its reason for challenging a claim, and (2) PCIGC was liable for the statutory maximum on both policies. The Court of Appeals affirmed, holding (1) PCIGC had no sufficient grounds for properly challenging the settlement; and (2) requiring PCIGC to pay covered claims under separate policies was within its statutory mandate. View "Prop. & Cas. Ins. Guar. Corp. v. Beebe-Lee" on Justia Law

After a jury trial, Petitioner was convicted of first-degree assault and aggravated cruelty to animals. The court of special appeals affirmed the convictions. Petitioner petition for writ of certiorari, arguing (1) the evidence was insufficient to support his felony animal cruelty conviction, and (2) his attorney's failure, after the close of all evidence, to renew the motion for judgment of acquittal constituted ineffective assistance. The Court of Appeals affirmed, holding (1) the evidence presented at trial was sufficient to support Petitioner's conviction of felony animal cruelty; and (2) it was unnecessary to address Petitioner's claim of ineffective assistance since it rested solely on his assertion that the evidence presented against him was insufficient to sustain his felony animal cruelty conviction. View "Haile v. State" on Justia Law

Petitioners challenged the validity of two Prince George's County ordinances regulating the packaging, sale or other distribution of cigars on several alternative grounds. One of Petitioners' arguments was that the General Assembly had legislated in the area so extensively that an intent to occupy the entire field must be implied. The circuit court granted Respondents' motions for summary judgment, rejecting each of Petitioners' contentions. The Court of Appeals reversed and remanded for the entry of a declaratory judgment and injunctive relief, holding that state law occupies the field of regulating the packaging and sale of tobacco products, including cigars, and thus impliedly preempts the two ordinances enacted by the county council of Prince George's County. View "Altadis U.S.A., Inc. v. Prince George's County" on Justia Law

Landowners believed they had the right to use a ten-foot wide strip of land that was used as a driveway to property owned by a Trust. The community homeowners association (Association) and six residents of the subdivision (collectively, Plaintiffs) filed suit against the Trust and the Trust's settlor (collectively, Petitioners) seeking a declaratory judgment that the Association held fee simple title to the strip and that the Landowners' property enjoyed an easement over the strip. Petitioners responded with a counterclaim seeking a declaratory judgment that the Trust held fee simple title to the strip and no easement existed in favor of any plaintiff. The circuit court concluded that the Trust held all title and interest in the strip and that the Trust's interest was subject to an easement appurtenant to the Landowners' property for the purposes of ingress and egress. The court of special appeals affirmed. The Court of Appeals affirmed in part and reversed in part, holding that the Landowners had an easement over a five-foot wide portion of the strip. View "Lindsay v. Annapolis Roads Prop. Owners Ass'n" on Justia Law