Justia Maryland Supreme Court Opinion Summaries

After having been convicted on an agreed-upon statement of the facts of wearing, carrying, or transporting a handgun illegally and of being in possession of a handgun after conviction of a disqualifying offense, Defendant appealed. Before any action was taken by the court of special appeals, the Supreme Court granted certiorari to consider whether the use by police of a Taser that fired two metal darts in the back of Defendant affected a Terry stop or Defendant's arrest. The Court of Appeals reversed, holding (1) the use of a Taser in this case converted what otherwise may have been a Terry stop into a de facto arrest for Fourth Amendment purposes, and there did not exist sufficient probable cause to arrest Defendant; and (2) Defendant's statement to the police that he had a gun in his pocket and the gun recovered from him should have been suppressed. Remanded for a new trial. View "Reid v. State" on Justia Law

Petitioner was convicted of first-degree felony murder. Petitioner's defense at trial was that his participation in the crimes with which he was charged was coerced. Petitioner argued on appeal that the trial court's refusal to instruct the jury with respect to duress was error. The court of special appeals affirmed, rejecting, in the process, the State's argument that the defense of duress is not applicable to felony murder. The Supreme Court reversed, holding (1) in Maryland, duress is a defense to felony murder; but (2) to establish and be entitled to the defense of duress, a defendant need not first prove he attempted to stop or thwart the offense that he was compelled to commit. Remanded for a new trial. View "McMillan v. State" on Justia Law

At issue in this case was when "meaningful trial proceedings" begin for purposes of Md. Rule 4-215(e) regarding a defendant's request to discharge counsel. Defendant in this case requested to discharge counsel preceding voir dire the morning before trial. After roll call of the jury was taken, the judge excused the venire panel and allowed Petitioner to discharge counsel and proceed pro se. Defendant was tried and convicted. The court of special appeals affirmed, holding that, because meaningful trial proceedings had begun, Rule 4-215(e) did not apply to Defendant's request to discharge counsel. Therefore, the court of special appeals reviewed the trial judge's decision for abuse of discretion, finding none. The Court of Appeals affirmed, holding (1) the court of special appeals correctly held that once the venire panel was summoned to the courtroom, meaningful trial proceedings had begun; and (2) therefore, the court of appeals did not err in holding Rule 4-215(e) did not apply to Defendant's request to discharge his counsel. View "Marshall v. State" on Justia Law

Respondent sustained six injuries while playing for the Washington Redskins on four separate occasions. Consequently, Respondent filed with the Maryland Workers Compensation Commission six separate claims against his employer, the Washington Redskins (Petitioner). The Commission denied five of Respondent's claims on the ground that he was not a "covered employee" because he was working for the Redskins outside of the State when he sustained the injuries underlying the claims. The circuit court affirmed. The court of special appeals reversed. The Court of Appeals affirmed, holding that a football player employed by the Washington Redskins is a "covered employee," and therefore entitled to avail himself of Maryland's workers' compensation laws, when injured while practicing and playing football outside of Maryland. View "Pro-Football, Inc. v. McCants" on Justia Law

This case related to an arbitration award denying an express easement on Petitioners' property. Petitioners filed a petition in the circuit court to confirm the arbitration award, and Respondent filed a motion to vacate the same. Respondent argued that the award was irrational because, without an easement over Petitioners' land, his land would be landlocked. The circuit court confirmed the arbitration award, relying upon the Uniform Arbitration Act. The court of special appeals (CSA) reversed, overturned the arbitrator's denial of the easement, and directed that an easement by necessity be located over Petitioners' land. While recognizing the Act's limitation on the authority of the courts to overturn arbitration awards, the CSA pointed out that arbitration awards that were completely irrational or which were manifestly in disregard of the law had been overturned in previous opinions. The Court of Appeals vacated the judgment of the CSA and remanded with directions to vacate the circuit court, holding (1) the arbitration award, in part, was contradictory; and (2) Md. Code Ann. Cts. & Jud. Proc. 3-225(a) authorizes a court to vacate an award and order a rehearing before arbitrators when the award is ambiguous or contradictory. Remanded for further proceedings pursuant to section 3-225(a). View "Downey v. Sharp" on Justia Law

This case involved a claim by a former professional football player (the athlete) for benefits under the Maryland Workers' Compensation Act based on an injury during pre-game warm-up at the employer's stadium in Maryland. The employment agreement contained a forum selection clause providing, inter alia, that claims for workers' compensation benefits should be governed by Virginia law and that the Virginia Workers' Compensation Commission should have exclusive jurisdiction to resolve such claims. The Maryland Workers' Compensation Commission decided that it could properly exercise jurisdiction over the athlete's claim, that the athlete had sustained an accidental injury arising out of the course of his employment, and that the athlete's disability was causally related to his accidental injury. The circuit court upheld the decision. The court of special appeals affirmed. The Court of Appeals affirmed, holding (1) the forum selection clause in the employment contract was ineffective to divest the Commission of the ability to exercise jurisdiction; and (2) injuries occurring while playing and practicing professional football are accidental injuries and thus compensable under the Act. View "Pro-Football, Inc. v. Tupa" on Justia Law

Defendant was on probation for a drunken driving offense when his DNA was collected for a separate murder investigation. The DNA was taken from saliva that Defendant left on a straw in the course of complying with an alcohol monitoring program mandated by the terms of his probation. The DNA test resulted in incriminating evidence against Defendant. The State introduced the DNA and lab report into evidence, and Defendant was convicted of involuntary manslaughter. The court of special appeals affirmed, concluding that Defendant did not have a reasonable expectation of privacy in the testing straw or the DNA on it, and therefore, the seizure of Defendant's DNA without a warrant did not violate the Fourth Amendment. The Court of Appeals affirmed, holding (1) Defendant's Fourth Amendment rights were not violated when the State recovered his DNA from the straw utilized for the mandatory test; and (2) the evidence was sufficient to sustain Defendant's conviction. View "Corbin v. State" on Justia Law

Father filed for divorce from Mother. In that proceeding, the parties contested physical and legal custody of their daughters. Prior to the merits hearing, a circuit court judge ordered preparation by court-related personnel a custody investigation report to evaluate the custodial abilities of each parent. The report was completed one week before the merits hearing, and Mother's counsel was able to review the report for only ninety minutes. As a consequence, Mother's attorney moved to exclude the report. The circuit court denied the motion. The judge then granted a divorce and awarded custody of the children to Father with visitation to Mother. The court of special appeals affirmed. At issue on appeal was whether the circuit court's unwritten policy that limits counsel of record in child custody proceedings to viewing custody investigation reports only in person in the clerk's office during normal business hours was viable. Without affirming or reversing, the Court of Appeals remanded for supplementation of the record as to the full contours of the relevant policy. View "Sumpter v. Sumpter" on Justia Law

After a jury trial, Defendant was convicted of manslaughter by motor vehicle, participating in a race or speed contest, and failing to remain at the scene of an accident resulting in death. Defendant appealed, arguing that the trial court unduly restricted his counsel during closing argument by limiting which comparative standards of proof he could argue to the jury. The court of special appeals affirmed. The Court of Appeals affirmed because the trial court's refusal to allow a discussion of extraneous legal standards was not an abuse of its broad discretion in controlling the scope of closing argument so as to avoid potential confusion of the jury. View "Ingram v. State" on Justia Law

Respondent was injured in an automobile collision involving Norman Iglehart while both were acting within the scope of their employment with the Board of Education of Prince George's County. The workers' compensation commission awarded Respondent compensation. Subsequently, Respondent filed a complaint against Iglehart and the Board (collectively, Petitioners) seeking damages as a result of Iglehart's negligence and the respondeat superior liability of the Board. The trial judge dismissed the Board from the action but directed it remain a party for the purposes of potential indemnification of Iglehart required under Md. Code Ann. Cts. & Jud. Proc. 5-518(h). The judge then ordered that judgment be entered against Iglehart and the Board. The intermediate appellate court affirmed. The Court of Appeals affirmed, holding (1) section 5-519 contains an indemnification provision that allows an injured party to bring a tort suit against the county board of education employee who caused the injury, and accordingly, the injured party must join the employer board as a defendant in the action; and (2) this statutory scheme does not violate the exclusivity rule stating that an injured employee's sole remedy against her employer is through the Workers' Compensation Act. View "Bd. of Educ. v. Marks-Sloan" on Justia Law