Justia Maryland Supreme Court Opinion Summaries

After a re-trial, a jury found Defendant guilty of first degree murder, second degree murder, and related offenses. At issue on appeal was whether pre-trial statements made by and on behalf of Defendant on the morning of the commencement of his re-trial should have been construed by the trial court as requests to discharge his counsel under Maryland Rule 4-215(e) or merely as a request for a continuance. Defendant claimed the circuit court failed to comply with Rule 4-215(e) and violated his constitutional right to counsel when Defendant was denied permission to discharge his counsel after he made several purported requests to do so. The court of special appeals reversed. The Court of Appeals reversed, holding (1) even assuming that the statements made to the trial court were sufficient collectively to engage a Rule 4-215(e) inquiry into the putative merits of Defendant's purported request to discharge his counsel, the conduct of the judges who considered Defendant's request as such complied with the requirements of Rule 4-215(e); and (2) the trial court did not violate Defendant's constitutional right to counsel of choice by denying his request for a continuance. Remanded with directions to affirm the judgment of the circuit court. View "State v. Taylor" on Justia Law

This dispute arose out of a contract to sell a shopping center. The contract was amended on several occasions. In one provision, the buyer agreed to indemnify the seller for a real estate commission, which they both disclaimed in the contract itself, that might ultimately be owed to a particular real estate broker. Another provision provided for forfeiture of the buyer's deposit if the transaction did not close on the timetable in the contract. The transaction ultimately closed after the appointed date, and the real estate broker successfully sued the seller for a commission. The buyer went bankrupt, and the seller and the assignee investors were left to sort of the consequences of the course of events. The Court of Appeals held (1) the seller here was not entitled to indemnification from the assignee investors for its liability for the broker's commission, even though the buyer (their assignor) was obligated to indemnify the seller; (2) the seller was not entitled to forfeit the deposit funded by the investors; and (3) the seller was entitled to have the investors' claim for refund of the deposit offset by the amount of indemnification that the buyer owed the seller. View "Pines Plaza Ltd. P'ship v. Berkley Trace, LLC" on Justia Law

Petitioners in this case were two residents of Howard County who filed a complaint seeking a declaratory judgment that a variety of County resolutions, ordinances, zoning decisions, and administrative actions violated the Howard County Charter. Specifically, Petitioners alleged that the County, by taking certain actions by resolution or administrative decision, rather than passing an original bill as the Charter requires for all legislative acts, denied Petitioners the opportunity to petition those acts to referendum, which, consequently, violated their interests in their constitutional rights to free speech and to vote. The circuit court dismissed the complaint, concluding that Petitioners lacked standing. The court of special appeals affirmed, holding that Petitioners failed to show a concrete injury to their voting rights and thereby lacked standing. The Court of Appeals affirmed, holding that Petitioners failed to establish standing because they alleged no specific and personal injuries stemming from the County's actions. View "Kendall v. Howard County" on Justia Law

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