Justia Maryland Supreme Court Opinion Summaries

Decedent worked as a firefighter for Baltimore City. After Decedent died, his widow, Petitioner, began receiving survivorship benefits from Decedent's pension. Petitioner later filed a dependent's claim for death benefits under the Maryland Workers' Compensation Act. The dispute at the hearing concerned what provision of the Act was applicable to Petitioner's claim. The City argued that Md. Code Lab. & Empl. 9-610, which reduces compensation death benefits by the amount of pension benefits, should apply. Petitioner argued that Md. Code Lab. & Empl. 9-503(e), which allows firefighters' dependents to collect both pension and workers' compensation up to the amount of what had been the firefighter's weekly salary, should apply. Petitioner's claim was pending when section 9-503(e) was amended to include dependents in its scope of coverage. The Workers' Compensation Commission determined that section 9-503(e) governed the claim and awarded Petitioner benefits. The circuit court granted summary judgment for the City, ruling that Petitioner had no preexisting right to dual benefits prior to the statute's amendment. The Court of Appeals affirmed, holding that the amendments involved a substantive change in the law that precluded it from applying retroactively to pending cases. View "Johnson v. Baltimore" on Justia Law

Petitioner entered into a consent order with the several Queen Anne's County officials regarding resolution of their disputes over Petitioner's proposed construction of a project in the county. The consent order terminated litigation in Kent Island I in the Anne Arundel County circuit court. Seeking invalidation of the consent order, Respondents filed suit in the Queen Anne's County circuit court (Kent Island II). On Petitioner's motion, the case was transferred to the Anne Arundel County circuit court, which granted summary judgment for Petitioner. The court of special appeals vacated the judgment, finding that venue was appropriate in the Queen Anne's County circuit court. The Supreme Court reversed, holding (1) the circuit court for Queen Anne's County did not have jurisdiction to modify or revise the consent order, a final judgment, entered by the Anne Arundel County circuit court; and (2) moreover, the Anne Arundel County circuit court was not empowered to revise or modify the judgment entered in Kent Island I in a manner sought by Respondents, as none of Respondents were a party in Kent Island I, and therefore, they could not maintain an action seeking either circuit court to exercise revisory power over the judgment in Kent Island II. View "Kent Island, LLC v. DiNapoli" on Justia Law

In 1998, Appellant pleaded guilty to child sexual abuse and third degree sexual offense. Upon conviction, Appellant was required to register as a sex offender for ten years. Since his conviction, however, the statutes changed to require lifetime registration for certain classes of sex offenders. Appellant sought declaratory relief in 2010, claiming he had satisfied the ten-year registration requirement and that he was not subject to lifetime registration. The circuit court declared that Appellant was subject to lifetime registration. The Supreme Court affirmed, holding that Appellant was required to register for life as a sex offender under Md. Code Ann. Crim. Proc. 11-707(a)(4)(iii) because his 1998 convictions made him a tier III sex offender under the current statutory scheme, and he was subject to lifetime registration on September 30, 2010, making retroactive application of the statute proper by its own terms. View "Ochoa v. Dep't of Pub. Safety & Corr. Servs." on Justia Law

In 1982, two elderly widows (the Millers) sold land to one party. Four years later, the Millers purported to sell the same land to Petitioner (the Partnership). The Partnership engaged two title companies (the Title Companies) to complete the title work, and the Title Companies failed to locate and report the Millers' first land sale. Chicago Title Insurance Company (Chicago Title) underwrote the insurance policies on the land. These transactions led to numerous lawsuits. At issue in this appeal was (1) whether a title company owes a duty of care when conducting a title search; and (2) whether a title insurance company may be held vicariously liable as a result of the title company's negligent title search. The Court of Appeals held (1) the Title Companies owed a duty of care to the Partnership in conducting the title search and issuing the title commitment; and (2) under the circumstances, Chicago Title may not be held vicariously liable for the Title Companies' negligence. View "100 Investment Ltd. P'ship v. Columbia Town Ctr. Title" on Justia Law

Taxpayer, a Maryland resident, appealed an assessment by the State Comptroller that did not allow a credit against the county income tax portion of the Maryland income tax. Taxpayer's income consisted of significant "pass-through" income generated by a Subchapter S corporation in other states, which was apportioned to Taxpayer and taxed by the states in which it was generated. The tax court affirmed the assessment. The circuit court reversed and remanded for further factual development and "an appropriate credit for out-of-state income taxes paid" on the corporation's income. The Court of Appeals affirmed, holding that the failure of the Maryland income tax law to allow a credit against the county tax for a Maryland resident taxpayer with respect to pass-through income of an S corporation that arises from activities in another state and that is taxed in that state violates the dormant Commerce Clause of the federal Constitution. View "Md. State Comptroller v. Wynne" on Justia Law

The Maryland State Conference of NAACP Branches (NAACP), pursuant to the Public Information Act, requested certain records from the Maryland State Police Department (State Police) to ensure State Police officers did not engage in racial profiling during traffic stops and searches. Although the State Police did provide the NAACP with reports detailing the number and status of racial profiling complaints, the reports did not contain information concerning the State Police's own internal investigations of these complaints, as it considered those records portions of personnel files. The circuit court concluded that the records constituted personnel records but that they should be disclosed with redaction of names and identification. The court of special appeals held that the unredacted records were not exempt from disclosure, as the files did not constitute personnel records of an individual. The Court of Appeals affirmed but for different reasons, holding (1) the disclosure of unredacted records was not properly before the court of special appeals; and (2) the redacted records were not personnel records, and therefore, the circuit court did not err in its judgment. View "Md. Dep't of State Police v. Md. State Conf. of NAACP Branches" on Justia Law

Petitioner filed a complaint against Respondent for unfair and deceptive trade practices and for common law fraud. Petitioner's complaint was based on an automobile warranty he purchased from Respondent that expired more than two years earlier than he had been led to believe. Petitioner purported to bring his action on behalf of others similarly situated. Before Petitioner filed a motion to certify the class, however, Respondent paid to extend Petitioner's warranty. The circuit court (1) denied Petitioner's motion for class certification, finding that because he had been made whole, Petitioner was no longer a member of any class; (2) granted in part Respondent's motion for summary judgment, finding Petitioner's claim moot; and (3) granted Petitioner attorney's fees for the period before and after Respondent tendered Petitioner individual relief. The Court of Appeals affirmed in part and reversed in part, holding (1) Respondent's tender of individual compensatory relief to Petitioner did not require the court to deny class certification; (2) an award of punitive damages is not foreclosed by the tender of individual compensatory damages; and (3) an award of attorney's fees to Petitioner under a fee-shifting provision of the Consumer Protection Act is not limited to fees incurred before the tender. View "Frazier v. Castle Ford, Ltd." on Justia Law

The Church of Jesus Christ of Latter-day Saints requested that it be exempt from paying property tax on an apartment complex it owned in Maryland to house missionaries. The county supervisor of assessments concluded that the apartment complex did not qualify for a property tax exemption under Md. Code Ann. Tax-Prop. 7-204 because the complex was not exclusively used as a "parsonage" or a "convent." The Maryland tax court upheld the decision. The circuit court reversed, determining that the complex qualified as both a parsonage and a convent. The Court of Appeals affirmed, holding that the tax court applied the wrong standard in assessing whether the apartment complex constituted a convent. Remanded for the tax court to issue an order granting the exemption. View "Green v. Church of Jesus Christ of Latter-day Saints" on Justia Law

Respondent was injured while performing his job as a school police officer in Baltimore City. After the City terminated his employment, Respondent applied for line-of-duty disability retirement. A hearing examiner denied Respondent's application, concluding that Respondent did not satisfy the eligibility requirements of Baltimore, Md., Code 22, 9(j), which requires a claimant to prove he sustained at least a fifty percent total impairment as the direct result of a line-of-duty accident. The hearing examiner concluded that Respondent did not satisfy the statutory requirements because the impairment to Respondent's back was not independent of all other causes, reasoning that Respondent's degenerative disc disease contributed to the disability of his back. The circuit court reversed, and the court of special appeals affirmed. The Court of Appeals affirmed, holding that Respondent's preexisting condition did not preclude him from qualifying for line-of-duty disability retirement because he proved that fifty percent of his total level of disability was the direct result of the injury he sustained while performing in the line of duty. View "Employees' Ret. Sys. of City of Baltimore v. Dorsey" on Justia Law

Petitioners filed a petition for judicial review of the Baltimore City Council's approval of a planned unit development (PUD) with a Wal-Mart supercenter. Both Petitioners' residences were approximately 0.4 miles away from the PUD. The Mayor and City Council of the City, the owners of the property, and the developers of the PUD (Respondents) filed motions to dismiss, alleging that Petitioners lacked standing to challenge the PUD. The circuit court granted Respondents' motions and dismissed Petitioners' petition for review. The court of special appeals affirmed, concluding that Petitioners did not qualify for prima facie aggrieved status and that they had failed to show any special aggrievement different from the general public. The Supreme Court granted certiorari and held that the circuit court did not err in its judgment, as Petitioners failed to allege specific facts that they had been specially aggrieved in a manner different than the public generally. View "Ray v. Baltimore" on Justia Law