Justia Maryland Supreme Court Opinion Summaries

After a jury trial, Petitioners Traimne Allen and Howard Diggs were convicted of attempted first degree murder and related offenses stemming from a home invasion and robbery. Petitioners appealed, arguing that the trial court erred in excluding certain DNA “match” evidence. The Court of Special Appeals affirmed, concluding that the DNA match evidence was properly excluded. The Court of Appeals affirmed, holding that Md. Code Ann. Pub. Safety 2-510 prohibits the introduction at trial by a criminal defense of evidence of a DNA match to prove the identity of another individual without first establishing additional confirmatory testing and does not infringe upon a criminal defendant’s constitutional right to present a defense. View "Allen v. State" on Justia Law

In 2009, Charles Williams, who had been suffering with suicidal ideation and auditory and visual hallucinations, went to a hospital emergency room. Health care providers examined and evaluated Williams, decided not to admit him, and discharged him to the care of his mother. That same night, Williams broke into a residence and invited the responding law enforcement officers to shoot him. When Williams rushed the officers, they fired their weapons at him, killing him. Williams’ family (collectively, Plaintiffs) brought a wrongful death and survivorship action against the health care providers alleging negligence in their decision to release rather than involuntarily admit Williams to the hospital. The circuit court dismissed the complaint, concluding that the health care providers were protected from liability by statutory immunity. The Court of Appeals affirmed, holding that Maryland’s involuntary admission immunity statute applies to health care providers who evaluate an individual and decide in good faith not to involuntarily admit him. View "Williams v. Peninsula Reg’l Med. Ctr." on Justia Law

In 1980, Appellant was convicted of first degree sex offense, kidnapping of a child under sixteen years of age, and assault and battery. In 2011, Appellant filed a pro se motion for new trial, later referred to as a petition for DNA testing, requesting that the State produce certain scientific identification evidence that might contain biological material and that was related to the judgment of conviction. A circuit court judge found that the State had performed a reasonable search for the requested evidence and that the evidence no longer existed. The Court of Appeals affirmed, holding that the judge’s findings that the State had performed a reasonable search for the requested evidence and that the evidence was no longer in the possession of the State were not clearly erroneous. View "Johnson v. State" on Justia Law

Defendant was criminally charged with failing to perform home improvement contracts and acting as a contractor without a license. Three separate home improvement contracts with different residents formed the basis of the charges. The charges were resolved through a plea agreement. As a condition of his probation, Defendant was ordered to pay restitution to each of the three victims. Defendant failed to make the restitution payments, and the district court determined that Defendant violated his probation in each of the three cases. In the meantime, Defendant was charged with obtaining property or services by issuing a bad check. Defendant pleaded guilty to the bad check charge and to the three probation violation charges. In sentencing Defendant, the circuit court conditioned probation in the bad check case on the payment of restitution to the victims in the home improvement cases. The court of special appeals struck the restitution requirement of Defendant’s probation, concluding that the circuit court was without authority to condition probation in such a manner, but otherwise upheld the sentence. The Supreme Court reversed, holding that the circuit court had authority to condition Defendant’s probation on the bad check conviction on his payment of restitution to the victims of his home improvement fraud. View "State v. Stachowski" on Justia Law

Several plaintiffs (Plaintiffs) asserted claims against one defendant, and one plaintiff asserted a claim against a second defendant. The circuit court awarded summary judgment for the first defendant against all Plaintiffs, but the decision did not resolve the claim against the co-defendant. Over one year later, the claim as to the co-defendant was voluntarily dismissed by way of a stipulation of dismissal. Plaintiffs subsequently sought to appeal the adverse summary judgment ruling. At issue in this case was whether the stipulation of dismissal satisfied the separate document requirement of Maryland Rule 2-601. Under that rule, the date on which the separate document is docketed triggers the thirty-day deadline for filing a notice of appeal under Maryland Rule 8-202(a). The court of special appeals concluded that the appeal was untimely. The Court of Appeals reversed, holding (1) the stipulation of dismissal did satisfy the requirements of Rule 2-601 for a separate document and therefore did not trigger the thirty-day clock for filing a notice of appeal as to the summary judgment ruling; and (2) Plaintiffs’ notice of appeal was timely under Rule 8-602(d). View "Hiob v. Progressive Am. Ins. Co." on Justia Law

After a jury trial, Defendant was convicted of first-degree rape and first-degree sexual offense. The court of appeals affirmed. Defendant filed a petition for a writ of certiorari, which the Court of Appeals granted, contending, among other things, that the trial judge lacked the authority to deny his motion to postpone because only a county administrative judge or that judge’s designee may deny a motion to postpone. The Court of Appeals affirmed, holding (1) a circuit court judge may deny a motion to postpone in a criminal case; (2) the trial judge did not abuse his discretion in denying the motion to postpone to obtain counsel and to review discovery materials; and (3) Defendant’s constitutional right to a speedy trial was not violated in this case. View "Howard v. State" on Justia Law

After a jury trial, Defendant was convicted of several criminal offenses, including second-degree assault of the intent-to-frighten type against Christine Johnson. The court of special appeals affirmed. Defendant appealed, arguing that the evidence was insufficient to support the conviction for second-degree assault of the intent-to-frighten type because Defendant did not know of Johnson’s presence in the apartment at the time of the assault. The Court of Appeals affirmed, holding (1) a defendant can commit second-degree assault of the intent-to-frighten type against a victim of whose presence in particular the defendant does not know; and (2) the evidence to sufficient to support a finding that Defendant knew multiple people were in the apartment. View "Jones v. State" on Justia Law