Justia Maryland Supreme Court Opinion Summaries

Plaintiff filed this action for negligence and assault against Defendant. Upon reaching a verdict, the jury foreman answered the court clerk's questions about the negligence count by using the verdict sheet submitted to and completed by the jury. The trial court found Defendant to be negligent based on these answers. However, it was not until after the jury was dismissed that the judge received the jury's completed copy of the verdict sheet, upon which the jury indicated that it intended to award damages. The trial judge enrolled the verdict sheet as the jury's verdict, awarding damages accordingly. The court of appeals vacated the award because that portion of the jury's verdict had not been announced in open court. The Supreme Court reversed, holding (1) after a jury verdict is orally announced, the verdict is subject to a judge's revisory powers; (2) revision is permissible only when the intent of the jury is manifest beyond doubt; and (3) the trial judge properly exercised his discretion in revising the verdict to include the award of damages as shown on the verdict sheet, as the revision effectuated the intent of the jury. View "Turner v. Hastings" on Justia Law

In 2009, Respondents, residents of the Jacksonville community, were awarded damages by a jury for an Exxon contractor's puncture of an underground gasoline feed line at an Exxon Mobil-owned gasoline service station. Several thousand gallons of gasoline leaked into the local underground aquifer and contaminated the source of the wells supplying water to Respondents' households. The Supreme Court affirmed in part and reversed in part the damages award and ordered all costs to be paid pro rata by Respondents. Respondents subsequently filed a motion for reconsideration. Exxon responded with an amended request for bond premium costs seeking reimbursement. The Supreme Court denied the motion for reconsideration and Exxon's request but changed the mandate in Ford to order that the parties shall bear their own costs, concluding that requiring Respondents to bear $1 million in premium bond costs was unreasonable under the circumstances. View "Exxon Mobil Corp. v. Ford" on Justia Law

Plaintiffs, in two separate lawsuits, sued a medical doctor and medical center for medical negligence, lack of informed consent, and fraud. Prior to the trial date, Defendants successfully moved to bifurcate the trials. The administrative judge of the circuit court vacated the trial judge's orders bifurcating the trials and reassigned the cases to another judge for trial. Defendants filed a petition for writ of mandamus or prohibition to reverse the administrative judge's orders. The Court of Appeals vacated the administrative judge's orders and reinstated the orders of the trial judge, holding that, under the circumstances, the administrative judge did not have the authority to review and vacate the trial judge's decision to bifurcate the trials and to unilaterally reassign the cases. View "St. Joseph Med. Ctr. v. Circuit Court (Turnbull)" on Justia Law

In 1997, the Bellevale Respondents sold an agricultural preservation easement on their dairy farm, Bellevale Farms, to a state agency (MALPF). Twelve years later, Bellevale asked MALPF to permit it to construct a creamery operation on the farm under the terms of the easement. MALPF approved the proposal, despite challenges from owners of real property adjacent to Bellevale Farms and a community association (collectively Petitioners). Petitioners filed this action against Bellevale Farms, MALPF, and others (collectively Respondents), seeking a declaration that the creamery violated the easement and an order prohibiting the construction of the creamery. The circuit court dismissed the action, concluding that Petitioners lacked standing to enforce the easement. Petitioners appealed, arguing that the easement constituted a charitable trust, and therefore, they possessed standing as "interested persons" under Md. Code Ann. Est. & Trusts 14-302(a). The Court of Appeals affirmed, holding (1) the instrument creating the easement and the statutory scheme of the MALPF program through which the easement was purchased did not indicate that Respondents intended to or created a charitable trust with a charitable purpose; and (2) therefore, Petitioners did not have standing under 14-302(a) to maintain a cause of action to enforce the easement. View "Long Green Valley Ass'n v. Bellevale Farms, Inc." on Justia Law

After various reports of neglect by their mother, the juvenile court determined two sisters to be children in need of assistance (CINA) and placed them in foster care pending implementation of a plan for their permanent placement. After the girls had been in foster care for nearly a year, the court of special appeals reversed the CINA designation of the younger sister and the foster care placement of both girls due to the insufficiency of the juvenile court's factual findings. The juvenile court subsequently again determined the younger sister was a CINA. The juvenile court then again took up the matter of deciding on a plan for the girls' permanent placement. In so doing, the court considered the girls' positive experiences with their foster parent and their mother's failure to cooperate with court orders and social workers. As a result, the court approved a change of the permanency plan from reunification with the mother to adoption for both girls. The Supreme Court affirmed, holding that the juvenile court, in deciding to approve a permanency plan of adoption, properly regarded all the relevant circumstances and facts before it in reaching a decision that was in the children's best interests. View "In re Ashley S." on Justia Law

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