Justia Maryland Supreme Court Opinion Summaries

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

Respondents, a county, city, village, and other government officials, established speed cameras that recorded, among others, Petitioners traveling in their vehicles over the posted speed limit. Respondents issued citations to Petitioners. Petitioners subsequently filed a complaint in the circuit court, asserting claims sounding in tort and seeking declaratory and injunctive relief. Petitioners asserted that Respondents' contracts with their common speed monitoring contract, ACS State and Local Solutions, violated Md. Code Ann. Transp. 21-809(j), which prohibited the county from remunerating, on a per-citation basis, a contractor who operates a speed monitoring system on the county's behalf. The circuit court granted Respondents' motions for summary judgment on all counts. The intermediate appellate court affirmed. The Court of Appeals affirmed but on different grounds, holding (1) section 21-809 does not provide an express or implied private cause of action in tort; and (2) Petitioners lacked the necessary taxpayer standing to pursue their injunctive and declaratory relief claims. View "Baker v. Montgomery Co." on Justia Law

Respondent recorded a deed he had altered. At a bench trial, Respondent was convicted of counterfeiting pursuant to Md. Code Ann. Crim. Law 8-601. The court of special appeals reversed based on its conclusion that the evidence was insufficient to show an intent to defraud another. The Court of Appeals reversed and reinstated Respondent's conviction, holding (1) the trial's finding that Respondent had committed a fraud on the system of recordation satisfied the specific intent element of section 8-601 that a defendant have acted with the "intent to defraud another" because the fact that Respondent acted with the intent to defraud the system of deed recordation inherently reflected the intent to defraud anyone who would later seek to rely on the accuracy of the deed; and (2) Respondent did not act in good faith. View "State v. Neger" on Justia Law