Justia Maryland Supreme Court Opinion Summaries

The district court convicted Petitioner of second-degree assault and reckless endangerment. Petitioner exercised his right to have his case tried do novo in the circuit court. After a jury-waived trial, the circuit court acquitted Petitioner of reckless endangerment and convicted him of second-degree assault. Petitioner filed a petition for certiorari in the Court of Appeals, which the Court issued. The Court then affirmed Petitioner's conviction, holding (1) Petitioner's right to a de novo appeal of his district court conviction was not violated when his testimony from the district court trial was admitted into evidence in his circuit court trial; and (2) Petitioner's Fifth Amendment privilege against self-incrimination was not violated when his testimony from the district court trial was admitted into evidence in his circuit court trial. View "Oku v. State" on Justia Law

CareFirst, Inc., a nonstock, nonprofit Maryland corporation, is a holding company with two subsidiaries that provides health insurance for millions of Maryland residents. State law confers broad authority on the Maryland Insurance Commissioner to oversee its operation and adherence to its mission. This case arose from the termination of Leon Kaplan, a former executive of CareFirst. CareFirst declined to pay part of the post-termination compensation set forth in Kaplan's employment contract, reasoning that the compensation was not for "work actually performed," as that standard had been interpreted by the Commissioner. The Commissioner affirmed the decision not to pay the benefits, concluding that the payments would violate Md. Code Ann. Ins. 14-139. The Court of Appeals affirmed, holding (1) the Commissioner's determination was not preempted by ERISA; (2) the Commissioner's construction of the insurance code was legally correct; and (3) there was substantial evidence to support the Commissioner's determination in this case. View "Md. Ins. Comm'r. v. Kaplan" on Justia Law

Petitioner, which operated an animal crematory, filed an action against Respondent, a planning and engineering firm, alleging breach of contract and professional negligence. The complaint failed to attribute Respondent's alleged failings to a licensed engineer and was not accompanied by a certificate of a qualified expert. The circuit court dismissed the complaint for failure to file a certificate within the required time period. The Court of Appeals reversed, holding that where the allegations of Petitioner's complaint did not fault a licensed engineer, it was premature to conclude that an expert certificate was required, as the certificate requirement applies only to a cause of action based on a licensed engineer's negligent act or omission in rendering engineering services within the scope of the engineer's license. View "Heavenly Days Crematorium, LLC v. Harris, Smariga & Assocs." on Justia Law

Dorothy Urban's estate (Estate) filed suit against Robert Street, asking the circuit court to declare null and void a deed executed by Urban to Street for a residential property on the grounds that the execution of the deed was procured through fraud. Street subsequently executed a deed of trust for a loan that was secured by the property. The majority of the loan was used to pay off a mortgage on the property placed by Urban. Later, the circuit court directed that the property be conveyed in Street's name to the Estate. The court created a constructive trust on the property without expressly declaring the Urban-to-Street deed void ab initio. Street subsequently defaulted on the deed of trust and Petitioners filed a foreclosure action on the property. The Estate filed a motion to dismiss the foreclosure proceedings, which the circuit court denied. The court of special appeals reversed. The Court of Appeals reversed, holding that although Petitioners were not bona fide purchasers of the property, under the doctrine of equitable subrogation, Petitioners were entitled to priority for the amount loaned to Street used to pay off the balance owed on the preexisting Urban mortgage. View "Fishman v. Murphy" on Justia Law

Plaintiffs were the parents of a daughter who died and another daughter who received injuries after Michael Eaton struck the Plaintiffs' car. Plaintiffs filed suit against the owner of the Dogfish Head Alehouse (Dogfish Head), claiming that Dogfish Head had served alcohol to Eaton while he was "clearly intoxicated" and thus breached its duty to them not to furnish alcohol to intoxicated persons. The circuit court granted summary judgment for Dogfish Head, concluding that the court was bound by the Supreme Court's decisions in State v. Hatfield and Fedler v. Butler in which dram shop liability was not recognized as a cause of action in the state. At issue before the Court of Appeals was whether it should recognize dram shop liability. The Court affirmed the judgment, holding (1) Maryland does not recognize a cause of action against a tavern for harm caused off premises by an intoxicated person in the absence of a special relationship between the tavern and the person harmed or the actor who caused the harm; and (2) absent such a relationship in this case, Dogfish Head did not owe a duty to Plaintiffs, as members of the general public, to prevent the harm caused by Eaton. View "Warr v. JMGM Group, LLC" on Justia Law

Joan Dixon died from mesothelioma caused by exposure to asbestos. Joan's husband, Bernard, handled asbestos in brake products while working for Ford Motor Company. The Dixons also used a compound manufactured by Georgia-Pacific Corp. in building their home and an adjacent structure that possibly contained asbestos. Bernard, Joan's estate, and the couple's children pursued legal action against Ford and Georgia-Pacific, claiming negligence for failing to warn Joan of the dangerous nature of their products. The jury returned verdicts in favor of Plaintiffs against Ford. The court disagreed with the jury's conclusion that the Georgia-Pacific compound was not also a substantial contributing factor and entered judgment for Ford on its cross-claim against Georgia-Pacific. The court of special appeals reversed the judgment entered in favor of Plaintiffs, concluding that the trial court erred in allowing opinion evidence by Plaintiffs' principal expert. The Court of Appeals (1) reversed and remanded with instructions to affirm the judgments entered against Ford, holding that the trial court did not err in allowing the expert's testimony; and (2) reversed the judgment granting Ford's cross-claim against Georgia-Pacific, holding that the jury's verdict on the issue of Georgia-Pacific's liability was not against the weight of the evidence. View "Dixon v. Ford Motor Co." on Justia Law

After Petitioner pled and was found not criminally responsible for the murder of two people by reason of a mental disorder, Petitioner was committed to a state-run medical facility run by the Department of Health and Mental Hygiene (DHMH), where he spent seven years as a patient. Thereafter, Petitioner applied for conditional release. An ALJ recommended that Petitioner be released subject to specified conditions. On appeal, the circuit court judge ruled that the ALJ's finding that Petitioner would not be a danger to himself or others was not supported by substantial evidence and ordered Petitioner's continued confinement. The court of special appeals affirmed. The Supreme Court reversed, holding that the lower courts erred in considering only whether Petitioner posed any risk to himself or the community without taking into account the conditions of release. Remanded. View "Hawkes v. State" on Justia Law

Child spent twenty-seven months in foster care without progress by his parents toward reunification and without consistently active involvement by other relatives. The juvenile court subsequently decided to pursue a plan of adoption by non-relatives. The court's order, which changed the permanency plan to adoption, triggered the filing of a termination of parental rights petition. Mother succeeded on her appeal of the plan change but not on her motion to stay the termination case. Consequently, by the time the court of special appeals ruled in Mother's favor on the plan change, Mother's parental rights had been terminated. At issue on appeal was whether the juvenile court erred in terminating Mother's parental rights while her appeal of the permanency plan change was pending. The Court of Appeals affirmed, holding (1) whether to stay a termination of parental rights case is within the juvenile court's discretion, and in this case, the court did not abuse its discretion because a stay would not have been in Child's best interests; and (2) the court did not err when it took into account Child's attachment to his foster parents in terminating parental rights. View "In re Adoption/Guardianship of Jayden G." on Justia Law

Following a bench trial, Petitioner was convicted of sexual abuse of a minor and attempted sexual abuse of a minor. The convictions arose from messages thirty-eight-year-old Petitioner wrote to an eight-year-old student professing his love for her. The court of special appeals affirmed the convictions. The Court of Appeals upheld Petitioner's convictions, holding (1) the lower courts did not err in holding that Petitioner did not enjoy a reasonable expectation of privacy in his work desk for purposes of a Fourth Amendment challenge to a search of the desk; (2) sexual abuse of a minor can be committed by the exchange of non-sexually explicit letters and drawings; and (3) a rational trier of fact could have found the essential elements of child sexual abuse beyond a reasonable doubt. View "Walker v. State" on Justia Law

Plaintiff contracted mesothelioma allegedly from exposure to asbestos fibers brought into her home on the clothing of her grandfather, who was exposed to asbestos-laden products during the course of his employment. Plaintiff sued her grandfather's employer (Employer), asserting strict liability and negligence claims. After a trial, a judgment was entered against Employer for more than $5 million. Employer appealed, claiming, among other things, that it had no duty to warn Plaintiff. The Court of Appeals reversed, holding that, at the relevant time back in 1968-69, there was no duty to warn persons such as Plaintiff of the danger of exposure to the dust on her grandfather's clothes. Remanded. View "Georgia Pac., LLC v. Farrar" on Justia Law