Justia Maryland Supreme Court Opinion Summaries

Md. R. Evid. 5-804(b)(1) allows for the admission of "former testimony" hearsay when the party against whom the declarant's statement is offered had an opportunity to develop the testimony at a prior action or proceeding. Petitioner Leon Dulyx was found guilty by a jury of aiding and abetting a robbery and aiding and abetting theft under $500. Petitioner appealed, contending that the circuit court erred under Rule 5-804(b)(1) and the Confrontation Clause in allowing the State to introduce at trial testimony of a witness taken during a pre-trial hearing to suppress the witness's extrajudicial identification of Petitioner. The court of special appeals affirmed the judgments. The Court of Appeals reversed, holding that the court of special appeals erred when it held that Petitioner was given a "full and fair opportunity" to cross-examine the witness despite substantial limitations placed on Petitioner's ability to question him. Consequently, the witness's testimony at that hearing was not admissible at Petitioner's trial under the "former testimony" hearsay exception. Remanded. View "Dulyx v. State" on Justia Law

Respondents Wayne Singleton and his eight-year-old son were passengers in a bus when the bus left the road and collided with a tree. Respondents sued Petitioner, the District of Columbia, alleging that it was liable vicariously for the negligence of its assumed employee, the driver. Respondents produced at trial only themselves as witnesses and argued that res ipsa loquitur supplied an adequate inference of negligence to complete their prima facie case. The trial judge granted the District's motion for judgment. The Court of Appeals affirmed, holding that under the circumstances of this case, Respondents failed to show that they were entitled to an inference of negligence, as Respondents' evidence failed to demonstrate that negligence on the part of the bus driver was more probably than not the cause of the accident or to eliminate other potential causes of the accident. View "Dist. of Columbia v. Singleton" on Justia Law

Petitioner Charles Phillips was arrested and subjected to a custodial interrogation. After about forty-five minutes of conversation, Petitioner expressed a desire to consult with an attorney. Following that expression, a police detective continued to engage Petitioner in conversation, during which Petitioner indicated a desire to continue talking to the detective and ultimately made a number of incriminating statements. Petitioner was subsequently convicted of first degree murder and armed robbery. The court of special appeals affirmed. The Supreme Court granted Petitioner's petition for certiorari to determine whether his inculpatory statements were elicited in violation of Edwards v. Arizona. The Court of Appeals reversed, holding that the conversation that ensued after Petitioner's invocation of his right to an attorney constituted a prohibited interrogation, and thus, Petitioner's inculpatory statements should have been suppressed. View "Phillips v. State" on Justia Law

In this custody modification proceeding, Joanna Davis was ordered by the circuit court to pay her ex-husband, Michael Petito, $30,773 in attorneys' fees and costs because the trial court determined she was in a better financial position than Petito due to Davis having received pro bono representation by the Sexual Assault Legal Institute (SALI), whereas Petito had accumulated over $70,000 in legal fees as a result of retaining private counsel. The court of special appeals affirmed. The Court of Appeals reversed, holding that the court's consideration that Davis was represented on a pro bono basis in order to award attorneys' fees to Petito, who had retained counsel, was erroneous under Md. Code Ann. Fam. Law 12-103. Remanded. View "Davis v. Petito" on Justia Law

After the IRS concluded its audit of the Baltimore Orioles Limited Partnership's tax returns for years 1993-1999 and adjusted various partnership items, the personal income tax liability of Wanda King, one of the limited partners, was lessened and she became eligible for a state tax refund totaling $173,364. King filed a claim for refund, but the Comptroller of the Treasury denied it, stating that the refund claim was not timely filed because the IRS's final report regarding adjustments to King's personal tax liability had been issued more than a year before King filed her refund. On appeal, the Maryland tax court ruled in favor of the Comptroller. The circuit court reversed the tax court, and the court of special appeals reversed. The Supreme Court affirmed the court of special appeals, holding (1) the statute of limitations applicable to King's refund claim began to run when the IRS issued to her certain forms on January 3, 2006, and accordingly, King's refund claim had to have been filed within one year of that date; and (2) thus, King's submission on February 2, 2007 was untimely. View "King v. Comptroller" on Justia Law

The mother of a kindergarten student, who suffered a serious allergic reaction after consuming peanut butter given to her under her school's free lunch program, brought suit against the State and its agents (collectively, Defendants), alleging that the State's obligations under the National School Lunch Act (NSLA) imposed upon Defendants a statutory duty of care to ensure that children with food allergies are not served lunches containing allergens. The trial court granted the State Defendants' motion to dismiss, concluding that the NSLA simply establishes a subsidized lunch program to benefit children at participating schools and does not impose a specific statutory duty of care towards children with food allergies. The court of special appeals affirmed. The Supreme Court affirmed, holding that the NSLA does not impose a statutory duty on the State Defendants to exercise a greater degree of care for students with food allergies than the general level of care the State Defendants exercise for all students in public schools. Because Petitioner could not maintain a suit in negligence, the complaint was properly dismissed. View "Pace v. State" on Justia Law

This case arose from an altercation between Petitioner Kimberly Jones and two deputy sheriffs during the deputies' attempt to serve an arrest warrant for an individual at the home of Petitioner. Petitioner filed a complaint against the deputies and the State, claiming that the State was negligent in its training of the two deputies. The jury returned a verdict finding the State liable for the deputies' negligent training and awarded Petitioner damages. The court of special appeals (CSA) reversed, concluding that there was legally insufficient evidence that the State breached any duty to Petitioner in connection with the tort of negligent training and supervision. The Supreme Court reversed the CSA and remanded with directions to affirm the judgment of the circuit court, holding that Petitioner presented legally sufficient evidence of her claim that the State was liable to her in tort for the negligent training of the two deputies. View "Jones v. State" on Justia Law

In his sixth time before the court of appeals, Anthony Grandison, a prisoner on death row for his role in a pair of 1983 murders, presented various requests for relief. Grandison's previous appeals resulted in one order denying an appeal and four published opinions. Grandison subsequently filed numerous motions, the majority of which the circuit court dismissed. The court did grant Grandison's motion to fire two appointed attorneys, and Grandison proceeded pro se for part of the collateral proceedings. Grandison then argued that he had a right to counsel for those proceedings and requested that he be appointed counsel so that he could go back and litigate the denied collateral claims with the benefit of counsel. Grandison also appealed the denial of his various motions. The Supreme Court (1) held Grandison did not have a right to counsel during the collateral proceedings, and the circuit court did not err or abuse its discretion in allowing Grandison to discharge counsel and continue pro se; and (2) affirmed the denial and dismissal of Grandison's motions by the circuit court. View "Grandison v. State" on Justia Law

In 1990, Appellant Michael Washington was convicted by a jury of first degree rape and related offenses and was sentenced to life in prison. Appellant later petitioned for a search for DNA material pursuant to Md. Code Ann. Crim. Proc. 8-201, after which the sheriff's office conceded it had destroyed biological evidence relating to Appellant's conviction. A hearing judge denied Appellant's subsequent petitions relating to this destruction of evidence. The Supreme Court affirmed, holding (1) the lower court did not err in finding that the State performed a reasonable search for the requested biological identification; (2) the State's duty to preserve scientific identification evidence, pursuant to section 8-201(j) begins as of the date the statute was enacted and is not to be applied retroactively; (3) because the hearing judge did not err in determining that the scientific identification evidence was destroyed prior to the enactment date of the statute, the statute was not applicable and Appellant was not entitled to the relief provided; and (4) the lower court did not err in finding that Appellant's conviction did not rest upon unreliable scientific identification evidence and denying Washington's motion for a new trial on that basis. View "Washington v. State" on Justia Law

Plaintiffs were the widow of a decedent and the adult children of her marriage with the decedent. Plaintiffs asserted claims under the Wrongful Death Statute against University of Maryland Medical Systems Corporation (UMMSC). In their complaint, Plaintiffs did not identify or notify a stepson, Ricky Muti, whom the decedent had adopted during a prior marriage. The circuit court dismissed Plaintiffs' wrongful death claims arising from the failure to name Ricky as a "use" plaintiff in violation of Md. R. 15-1001. The court of special appeals held (1) Plaintiffs violated Rule 15-1001, and (2) the circuit court abused its discretion by denying Plaintiffs' leave to amend without first considering whether Ricky would be prejudiced by the denial. The Supreme Court vacated the judgment of the special court of appeals and remanded with instructions to reverse the judgment of the circuit court, 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, where there was no basis for inferring that Ricky was omitted as a use plaintiff for the purpose of hiding the litigation from home or in the hope that Plaintiffs would increase their recovery. View "Univ. of Md. Med. Sys. Corp. v. Muti" on Justia Law