Justia Maryland Supreme Court Opinion Summaries

Plaintiffs were the parents of a daughter who died and another daughter who received injuries after Michael Eaton struck the Plaintiffs' car. Plaintiffs filed suit against the owner of the Dogfish Head Alehouse (Dogfish Head), claiming that Dogfish Head had served alcohol to Eaton while he was "clearly intoxicated" and thus breached its duty to them not to furnish alcohol to intoxicated persons. The circuit court granted summary judgment for Dogfish Head, concluding that the court was bound by the Supreme Court's decisions in State v. Hatfield and Fedler v. Butler in which dram shop liability was not recognized as a cause of action in the state. At issue before the Court of Appeals was whether it should recognize dram shop liability. The Court affirmed the judgment, holding (1) Maryland does not recognize a cause of action against a tavern for harm caused off premises by an intoxicated person in the absence of a special relationship between the tavern and the person harmed or the actor who caused the harm; and (2) absent such a relationship in this case, Dogfish Head did not owe a duty to Plaintiffs, as members of the general public, to prevent the harm caused by Eaton. View "Warr v. JMGM Group, LLC" on Justia Law

Joan Dixon died from mesothelioma caused by exposure to asbestos. Joan's husband, Bernard, handled asbestos in brake products while working for Ford Motor Company. The Dixons also used a compound manufactured by Georgia-Pacific Corp. in building their home and an adjacent structure that possibly contained asbestos. Bernard, Joan's estate, and the couple's children pursued legal action against Ford and Georgia-Pacific, claiming negligence for failing to warn Joan of the dangerous nature of their products. The jury returned verdicts in favor of Plaintiffs against Ford. The court disagreed with the jury's conclusion that the Georgia-Pacific compound was not also a substantial contributing factor and entered judgment for Ford on its cross-claim against Georgia-Pacific. The court of special appeals reversed the judgment entered in favor of Plaintiffs, concluding that the trial court erred in allowing opinion evidence by Plaintiffs' principal expert. The Court of Appeals (1) reversed and remanded with instructions to affirm the judgments entered against Ford, holding that the trial court did not err in allowing the expert's testimony; and (2) reversed the judgment granting Ford's cross-claim against Georgia-Pacific, holding that the jury's verdict on the issue of Georgia-Pacific's liability was not against the weight of the evidence. View "Dixon v. Ford Motor Co." on Justia Law

After Petitioner pled and was found not criminally responsible for the murder of two people by reason of a mental disorder, Petitioner was committed to a state-run medical facility run by the Department of Health and Mental Hygiene (DHMH), where he spent seven years as a patient. Thereafter, Petitioner applied for conditional release. An ALJ recommended that Petitioner be released subject to specified conditions. On appeal, the circuit court judge ruled that the ALJ's finding that Petitioner would not be a danger to himself or others was not supported by substantial evidence and ordered Petitioner's continued confinement. The court of special appeals affirmed. The Supreme Court reversed, holding that the lower courts erred in considering only whether Petitioner posed any risk to himself or the community without taking into account the conditions of release. Remanded. View "Hawkes v. State" on Justia Law

Child spent twenty-seven months in foster care without progress by his parents toward reunification and without consistently active involvement by other relatives. The juvenile court subsequently decided to pursue a plan of adoption by non-relatives. The court's order, which changed the permanency plan to adoption, triggered the filing of a termination of parental rights petition. Mother succeeded on her appeal of the plan change but not on her motion to stay the termination case. Consequently, by the time the court of special appeals ruled in Mother's favor on the plan change, Mother's parental rights had been terminated. At issue on appeal was whether the juvenile court erred in terminating Mother's parental rights while her appeal of the permanency plan change was pending. The Court of Appeals affirmed, holding (1) whether to stay a termination of parental rights case is within the juvenile court's discretion, and in this case, the court did not abuse its discretion because a stay would not have been in Child's best interests; and (2) the court did not err when it took into account Child's attachment to his foster parents in terminating parental rights. View "In re Adoption/Guardianship of Jayden G." on Justia Law

Following a bench trial, Petitioner was convicted of sexual abuse of a minor and attempted sexual abuse of a minor. The convictions arose from messages thirty-eight-year-old Petitioner wrote to an eight-year-old student professing his love for her. The court of special appeals affirmed the convictions. The Court of Appeals upheld Petitioner's convictions, holding (1) the lower courts did not err in holding that Petitioner did not enjoy a reasonable expectation of privacy in his work desk for purposes of a Fourth Amendment challenge to a search of the desk; (2) sexual abuse of a minor can be committed by the exchange of non-sexually explicit letters and drawings; and (3) a rational trier of fact could have found the essential elements of child sexual abuse beyond a reasonable doubt. View "Walker v. State" on Justia Law

Plaintiff contracted mesothelioma allegedly from exposure to asbestos fibers brought into her home on the clothing of her grandfather, who was exposed to asbestos-laden products during the course of his employment. Plaintiff sued her grandfather's employer (Employer), asserting strict liability and negligence claims. After a trial, a judgment was entered against Employer for more than $5 million. Employer appealed, claiming, among other things, that it had no duty to warn Plaintiff. The Court of Appeals reversed, holding that, at the relevant time back in 1968-69, there was no duty to warn persons such as Plaintiff of the danger of exposure to the dust on her grandfather's clothes. Remanded. View "Georgia Pac., LLC v. Farrar" on Justia Law

Defendants were tried jointly and convicted of numerous crimes arising from a shooting in Baltimore that left one man dead and two other individuals wounded. The court of special appeals reversed the judgments against both men. Defendants were retried jointly before a jury and were again convicted. The court of special appeals affirmed, for the most part, the judgments of conviction of both Defendants. Defendants appealed, contending, among other things, that where an internal affairs investigator for the police found "facts sustained" against officers, the trial court erred (1) in refusing to permit the defense to inspect internal investigation division files concerning misconduct by certain law enforcement officers, and (2) at trial, in refusing to allow the defense to cross-examine the officers about the misconduct. The Supreme Court reversed with instructions to vacate the judgments of conviction and remand the case for retrial, holding that the denial of access to potentially significant impeachment evidence and the subsequent denial of an opportunity to demonstrate a reasonable actual basis for cross-examination was not harmless beyond a reasonable doubt. View "Fields v. State" on Justia Law

Plaintiff was a soccer player who had volunteered to assist in coaching a team of young soccer players in a program of the Soccer Association of Columbia (Defendant). Plaintiff was injured when the soccer goal, which was not anchored to the ground, fell on top of him after he grabbed the upper crossbar. Plaintiff subsequently filed a negligence complaint against Defendant. Defendant asserted the defense of contributory negligence. The trial court entered judgment in favor of Defendant, finding that because both parties were negligent, Plaintiff was barred from any recovery. Plaintiff appealed, arguing that the Court of Appeals should abrogate Maryland's long-established common law principle of contributory negligence. The Court of Appeals affirmed, holding that the Court would not change the common law and abrogate the contributory negligence defense in negligence actions in the face of the General Assembly's repeated refusal to do so. View "Coleman v. Soccer Ass'n of Columbia" on Justia Law

County Council enacted a bill providing that Appellant forfeited his councilmanic position, concluding that Appellant had moved his residence from his councilmanic district to a correctional facility in South Carolina after having been convicted of failing to file a federal tax return. Appellant challenged the authority of the County Council to expel him as a member based upon its interpretation of the term "residence" in the County Charter as a "temporary place of abode." The circuit court granted summary judgment for the County and County Council. The Court of Appeals reversed, holding that "residence" in the Charter embodies the notion of domicile, such that Appellant did not move his residence by virtue of his five-month incarceration. View "Jones v. Anne Arundel County" on Justia Law