Justia Maryland Supreme Court Opinion Summaries

Respondent filed a medical action against Petitioner, a medical doctor. At issue before the Court of Appeals was whether a completed case information report, on which an election of a jury trial is noted and which is filed with the complaint, but not served on the opposing party, is a proper vehicle for demanding a jury trial. The court of special appeals held that it was and, therefore, reversed the judgment of the circuit court, which had reached the opposite result. The Court of Appeals reversed, holding that a case information report form, being neither a "paper" nor a "pleading" and, in any event, having not been served on the opposing party, is neither a proper nor timely means of demanding a civil jury trial pursuant to Md. R. 2-325(a) and (b). View "Duckett v. Riley" on Justia Law

The parties in this case were the parents of a minor child, whose custody they agreed to share when they both lived in Maryland. Mother subsequently moved to Virginia and filed a motion to modify custody. Concurrently, Mother moved to relinquish jurisdiction to Virginia. The circuit court denied Appellee's motions. The circuit court subsequently granted Mother's motion to alter or amend or alternatively to revise judgment and also relinquished jurisdiction to Virginia. Father appealed. The Court of Appeals affirmed, holding (1) the court was not required to hold a hearing prior to granting Mother's motion seeking to revise the court's dismissal of her action; (2) Md. Code Ann. Fam. Law 9.5-207 clearly and unambiguously contemplates that a party or a court, upon motion, will raise the issue of inconvenient forum, even when the jurisdiction of the court is continuing and exclusive, and therefore, the "inconvenient forum" provisions of section 9.5-207 applied to this child custody case; and (3) the circuit court did not abuse its discretion when it found Maryland to be an inconvenient forum for the underlying child custody dispute and therefore relinquished its jurisdiction to Virginia. View "Miller v. Matthias" on Justia Law

After a jury trial, Petitioner was convicted of distributing and possessing a controlled dangerous substance. The court of special appeals affirmed the conviction. Defendant subsequently filed a petition for postconviction relief, arguing that he had received ineffective assistance of counsel because counsel sued Petitioner during the representation for unpaid legal fees. The postconviction court granted Petitioner a new trial, reasoning that counsel had a conflict of interest in representing Petitioner. The court of appeals reversed after applying the general test set forth in Strickland v. Washington. At issue on appeal was whether the exception to Strickland's general rule applied in this case. The exception, set forth in Cuyler v. Sullivan, states that the defendant is excused from proving the prejudice prong of the Strickland test upon a showing that counsel was burdened by an "actual conflict of interest." The Supreme Court reversed, holding (1) this case entailed a conflict of interest governed by the Sullivan rubric; and (2) Petitioner was entitled under the Sullivan rule to the benefit of the presumption of prejudice only if he could show the conflict of interest was "actual" in the sense that it had an adverse effect upon counsel's performance. Remanded. View "Taylor v. State" on Justia Law

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