Justia Maryland Supreme Court Opinion Summaries

After his convictions for attempted second-degree murder, attempted armed carjacking, and first-degree assault, Petitioner Chaz Bazzle appealed, arguing that the trial court erred by (1) failing to instruct the jury on voluntary intoxication and (2) allowing a witness to testify as to the certainty of his eyewitness identification. The court of special appeals affirmed. The Court of Appeals affirmed, holding (1) the evidence did not generate an instruction on voluntary intoxication because it was insufficient to allow a jury to rationally conclude that Petitioner was so intoxicated that he was unable to form the intent necessary to constitute his crimes; and (2) Petitioner failed to preserve his objection to the witness's testimony because the trial court, by stating that it would overrule the objection unless grounds were provided, triggered the requirement that Petitioner provide grounds or lose the opportunity to raise the objection on appeal. View "Bazzle v. State" on Justia Law

Petitioner Daniel McNeal was convicted by a jury of possessing a handgun after conviction of a disqualifying crime but, in the same trial, acquitted of wearing, carrying, or transporting a handgun. McNeal appealed, arguing that the Court of Appeals' opinion in Price v. State, which held that clearly and legally inconsistent jury verdicts in criminal cases were prohibited in Maryland, prohibited these factually inconsistent jury verdicts. The court of special appeals upheld McNeal's guilty verdict because the inconsistency between an acquittal for wearing, carrying, or transporting a handgun and a conviction for possession of a handgun after prior conviction of a disqualifying crime was based on the jury's conclusions of fact, not of law. The Court of Appeals affirmed, holding that its opinion in Price, which applies to verdicts that are legally inconsistent, does not apply to jury verdicts in criminal cases that are merely inconsistent factually, illogical, or "curious." View "McNeal v. State" on Justia Law

Petitioner Michael McCloud applied for a handgun permit but was denied because in 2006 he had been convicted in the District of Columbia of attempting to carry a pistol without a license. In denying Petitioner's application, the state police relied on the Maryland attorney general's opinion advising that an out-of-state conviction can disqualify an applicant from obtaining a handgun permit. The permit denial was reversed by the state police's handgun permit review board, which held that the opinion did not apply to Petitioner's situation. The denial was reinstated by the circuit court. The court of special appeals affirmed. The Court of Appeals affirmed, holding (1) the court of special appeals did not err in adopting the views expressed in the attorney general's opinion to determine what constitutes a disqualifying crime; (2) accordingly, Md. Code Ann. Pub. Safety 5-101(g)(3) and 5-133(b)(1), which define a disqualifying crime, include out-of-state convictions; and (3) when determining whether such a conviction is a disqualifying crime, an agency must look to the maximum penalty for the equivalent offense in Maryland. View "McCloud v. Handgun Permit Review Bd." on Justia Law

Appellees, the Libertarian Party and the Green Party, enjoyed ballot access privileges from 2007 to 2010, when they were unable to show their respective memberships consisted of at least one percent of registered Maryland voters or that their nominees for Governor received at least one percent of the total vote. Appellees then submitted 10,000 petition signatures to Appellant, the State Board of Elections, to regain their ballot access privileges. Appellant determined that many of the submitted petition signatures were invalid and, thus, Appellees did not satisfy the statutory requirements. Appellees sought a declaratory judgment that Appellant incorrectly applied the law regarding validation of petition signatures and that the applicable law was whether there was "sufficient cumulative information" from which Appellant could identify a signatory on a petition as a registered voter. The circuit court granted summary judgment for Appellees. The Court of Appeals vacated the circuit court, holding (1) the court erred in relying on a supposed "sufficient cumulative information" standard, as the requirements for petition signatures under Md. Code Ann. Elec. Law 6-203(a) are mandatory; and (2) pursuant to section 6-203(b), Appellant appropriately refused to validate and count duplicate signatures of individuals who previously signed the same petition. Remanded. View "Bd. of Elections v. Libertarian Party" on Justia Law

Appellant and Appellee were two women validly married in California. The parties later agreed to separate, and Appellant filed a divorce complaint in Maryland. The circuit court denied the requested relief, explaining in its written order that the marriage was not valid pursuant to Maryland law and was contrary to the public policy of Maryland. The parties filed timely appeals. The Supreme Court noted that, under the principles of comity applied in the State, Maryland courts will withhold recognition of a valid foreign marriage only if that marriage is "repugnant" to State public policy. The Court reversed the circuit court, holding (1) no viable decision by the Court had deemed a valid foreign marriage to be "repugnant," despite being void or punishable as a misdemeanor or more serious crime were it performed in Maryland; and (2) therefore, a valid out-of-state same-sex marriage should be treated by Maryland courts as worthy of divorce, according to the applicable statutes, reported cases, and court rules of the State. Remanded with direction to grant a final divorce to the parties. View "Port v. Cowan" on Justia Law

Following a jury trial, Petitioner McKenzie Nicolas was convicted of resisting arrest and second degree assault stemming from a confrontation with two officers at Petitioner's home. The court of special appeals affirmed. The Court of Appeals affirmed in part and reversed in part, holding (1) a jury note with no date or time stamp found in the appellate record does not establish that the trial court received the jury communication in order to trigger the requirements of Md. Rule 4-326(d); but (2) the court of special appeals erred in holding that Petitioner's convictions for second degree assault do not merge into his conviction for resisting arrest for sentencing purposes where the record is ambiguous as to whether the jury convicted Petitioner of second degree assault based on acts different than those underlying his conviction for resisting arrest. Remanded. View "Nicolas v. State" on Justia Law

Decedent Elliott Multi died in March 2005. Plaintiffs were the widow of Decedent and the adult children of her marriage with Decedent. Plaintiffs filed a claim against the University of Maryland Medical Systems Corporation (Defendant), alleging medical malpractice and wrongful death. Defendant moved to dismiss the complaint for failure to join a necessary party, a stepson whom Decedent had adopted during a prior marriage. The circuit court dismissed Plaintiffs' wrongful death claims for failure to join the stepson as a "use" plaintiff. The Court of Appeals reversed, holding that, under the totality of the circumstances, the circuit court abused its discretion in dismissing Plaintiffs' wrongful death claims as a sanction for the omission of the stepson as a use plaintiff, as there was no basis for inferring that the stepson was omitted for the purpose of hiding the litigation from him or in the hope that Plaintiffs would increase their recovery. Remanded. View "Univ. of Md. Med. Sys. Corp. v. Muti" on Justia Law

Petitioner Ocie Black was convicted of child sexual abuse, second degree sex abuse, and third degree sex abuse and sentenced to thirty-two years incarceration. Petitioner appealed, claiming that the trial court erred in failing to disclose a jury note to him and his trial counsel. The intermediate appellate court affirmed. The Court of Appeals affirmed, holding (1) a jury note with no date or time stamp found in the appellate record does not establish that the trial court received the jury communication at issue in order to trigger the requirements of Md. Rule 4-326(d), which governs communications between a jury and the trial court; and (2) therefore, the trial court's responsibilities under the rule were never triggered. View "Black v. State" on Justia Law

Dr. Shailendra Kumar sued Dr. Anand Dhanda, alleging breach of contract and breach of a covenant not to compete. The contract at issue provided for disputes to be initially addressed through mandatory, non-binding arbitration. Dhanda filed a motion to dismiss the action, asserting that the suit was barred by the applicable statute of limitations. Kumar opposed dismissal, arguing that the complaint was timely because his cause of action had either not accrued or that limitations was tolled until the completion of arbitration. The trial court dismissed the action as time-barred, and the court of special appeals affirmed. The Court of Appeals affirmed, holding that while non-binding arbitration may have been a condition precedent to litigation, it neither affected the accrual of the underlying breach of contract claims, nor otherwise tolled the statute of limitations applicable to maintaining an action in court. View "Kumar v. Dhanda" on Justia Law

Montgomery County law enforcement officers, situated at a "listening post" in Montgomery County, and operating under an ex pare order issued by a judge of the county circuit court under the Maryland Wiretapping and Electronic Surveillance Act, intercepted a mobile phone communication from a target mobile phone, caller, and receiver located in Virginia. As a result of the intercepted communication, the police seized from the caller, Tyrone Davis, controlled dangerous substances when he returned to his Maryland residence. Davis moved to suppress the evidence, arguing that the wiretap order did not authorize interception of the extraterritorial communication. The hearing judge denied Davis's motion to suppress, citing federal case law defining the location of an "interception" as where the mobile communication was first intercepted or redirected and where it was first heard by law enforcement officers. The court of special appeals affirmed. The Court of Appeals affirmed after adopting the federal standard for determining the proper jurisdiction and scope for an ex parte wiretap order, holding that as long as the "listening post" where an officer first hears the intercepted communications is within the geographical jurisdiction of the court issuing the order, the interception is proper under the Maryland statute. View "Davis v. State" on Justia Law