Justia Maryland Supreme Court Opinion Summaries

In the Matter of Antavis Chavis, the Supreme Court of Maryland ruled that a bar applicant diagnosed with Attention Deficit Hyperactivity Disorder (ADHD) had met his burden to prove that he had a "disability" under the Americans with Disabilities Act of 1990 (ADA) and that the testing accommodation he requested—50% additional time to take the Uniform Bar Examination (UBE)—was warranted. The court adopted a two-step test to determine whether a bar examination test accommodation request should be granted. First, the court must determine if the applicant meets the ADA definition of "disability." Second, the court must determine if the test accommodation requested by the applicant is "reasonable, consistent with the nature and purpose of the examination and necessitated by the applicant’s disability." The court observed that under the ADA and related federal regulations, the definition of disability should be broadly construed and that evidence of past test accommodations must be given considerable weight. The court sustained the applicant’s exceptions to the denial of his test accommodation request by the State Board of Law Examiners (SBLE), reversed the denial, and remanded the matter to the SBLE with instruction to grant the applicant’s test accommodation request. View "In the Matter of Antavis Chavis" on Justia Law

The Supreme Court reversed the judgment of the appellate court reversing the judgment of the circuit court concluding that Defendant could not show that he was prejudiced by his counsel's assistance under Strickland v. Washington, 466 U.S. 668 (1984), holding that the circuit court correctly concluded that trial counsel's performance was deficient.At issue was whether trial counsel's failure to object to an order prohibiting any consultation regarding the case between Petitioner and trial counsel during Petitioner's murder trial resulted in the actual denial of the Sixth Amendment's guarantee of assistance of counsel. The Supreme Court held (1) prejudice was presumed under the circumstances of this case; and (2) the circuit court correctly concluded that trial counsel's failure to object was objectively unreasonable. View "Clark v. State" on Justia Law

The Supreme Court upheld the judgment of the circuit court on postconviction review ordering a new trial for Petitioner, holding that Petitioner was provided ineffective assistance of counsel due to trial counsel's failure to object to the trial court's order prohibiting any consultation about the case (a no-communication order) between Petitioner and trial counsel under the circumstances of this case.At issue was a no-communication order entered into between Petitioner and trial counsel during an overnight recess prior to the final day of testimony in Petitioner's murder trial and trial counsel's failure to object to the order. The circuit court ruled that the no-communication order, and trial counsel's failure to object, deprived Petitioner of the assistance of counsel, in violation of the Sixth Amendment, and presumed prejudice, thus ordering a new trial. The appellate court reversed, concluding that Petitioner could not show prejudice. The Supreme Court reversed, holding (1) trial counsel's conduct in this case resulted in the actual denial of the assistance of counsel, and prejudice was presumed; and (2) therefore, the circuit court properly ordered a new trial for Petitioner. View "Clark v. State" on Justia Law

The Supreme Court affirmed the decision of the appellate court affirming the circuit court's grant of summary judgment in favor of Defendant in this action brought under the Maryland Health Care Worker Whistleblower Protection Act (the Act), Md. Code Ann., Health Occ. (HO) 1-501 through 1-506, holding that Plaintiff was not entitled to relief on her allegations of error.Specifically, the Supreme Court held (1) the lower court did not err by requiring Plaintiff to show that the protected conduct was the but-for cause of the challenged personnel action; (2) a plaintiff may avail herself of the burden-shifting framework established by McDonnell Douglas to prove but-for causation; (3) Plaintiff failed to genuinely dispute Defendant's evidence that she was terminated for reasons unrelated to her alleged protected disclosure; and (4) the circuit court did not err by granting judgment to Defendant as a matter of law. View "Romeka v. RadAmerica II, LLC" on Justia Law

The Supreme Court affirmed the decision of the post-conviction court denying Defendant's petition for post-conviction relief, holding that the post-conviction court did not err in ruling that trial counsel had not rendered ineffective assistance and that the State had not violated its Brady obligations during the underlying proceedings, holding that there was no error.After a jury trial, Defendant was convicted of distribution of heroin and sentenced to eight years' imprisonment. The appellate court affirmed. Defendant later filed a pro se petition for post-conviction relief, which the post-conviction court denied. On appeal, the appellate court certified questions of law to the Supreme Court. The Supreme Court answered (1) the post-conviction court did not err in ruling that trial counsel had not rendered ineffective assistance by failing to move production of certain evidence; and (2) assuming, without deciding, that the State was required to disclose challenged impeachment evidence prior to the hearing on Defendant's motion to suppress, Defendant failed to establish the Brady materiality standard. View "Blake v. State" on Justia Law

The Court of Appeals held that Defendant had a reasonable expectation of privacy in data contained on his hard drive and that the government conducted an unreasonable search by examining data without any authority to do so either by a warrant or an exception to the warrant requirement.At issue was whether the consensual creation of a copy of the hard drive of Defendant's seized laptop computer permanently eliminated Defendant's privacy interest in the hard drive. The circuit court denied Defendant's motion to suppress and ultimately convicted him of three counts of distribution of child pornography. The appellate court reversed, concluding that individuals have a legitimate expectation of privacy in the digital data within their computer and that Defendant's revocation of his consent to examine the data from his laptop precluded a forensic examination of the mirror-image copy of its hard drive without a warrant. The Court of Appeals affirmed, holding that the search in this case was unreasonable after Defendant withdrew his consent. View "State v. McDonnell" on Justia Law

The Court of Appeals affirmed the judgment of the appellate court reversing the decision of the circuit circuit court that examination of data contained on Defendant's hard drive was not a search in violation of the Fourth Amendment, holding that the government violated Defendant's Fourth Amendment rights in this case.Defendant voluntarily consented to government agents seizing his laptop computer, creating a copy of its hard drive, and searching the data on it. After the copy was made but before the government examined the data Defendant withdrew his consent. Defendant moved to suppress the evidence from the forensic examination of the copy of his laptop's hard drive. The circuit court denied the motion. On appeal, Defendant asserted that he had a legitimate expectation of privacy in the mirror-image copy of his laptop hard drive. The appellate court agreed and reversed. The Court of Appeals affirmed, holding (1) Defendant had a reasonable expectation of privacy in the data contained on his hard drive; (2) because the government did not examine the data before Defendant withdrew his consent Defendant did not lose his reasonable expectation of privacy in the data; and (3) the government conducted an unreasonable search by examining the data without any authority to do so. View "State v. McDonnell" on Justia Law

The Court of Appeals affirmed the judgment of the appellate court dismissing Appellant's appeal of the circuit court's ruling affirming the judgment of the Maryland Commission on Civil Rights finding no probable cause to believe that Krav Maga MD, LLC (KMMD) engaged in disability discrimination, holding that the appellate court correctly dismissed Appellant's appeal.Appellant alleged that KMMD, her gym, engaged in disability discrimination by deleting a comment that Appellant had posted on the gym's Facebook account relating to her disability and then later by terminating her membership. The Commission ultimately found no probable cause the find that KMMD had discriminated against Appellant based on her disability. The circuit court affirmed the Commission's finding of no probable cause. On appeal, the appellate court ruled that it lacked jurisdiction to consider Appellant's appeal. The Court of Appeals affirmed, holding that the appellate court correctly dismissed Appellant's appeal. View "Rowe v. Md. Comm'n on Civil Rights" on Justia Law

In this case considering whether unprovoked flight in a high-crime area should no longer be considered a factor that gives rise to rebate articulable suspicion for a Terry stop, the Court of Appeals held that, under the totality of the circumstances, Defendant's rights under either the Fourth Amendment or Article 26 of the Maryland Declaration of Rights were not violated.Defendant, who was standing in an high-crime area in Baltimore City, fled when he saw an unmarked vehicle. Ultimately, detectives stopped Defendant and found a gun in his waistband. Defendant filed a motion to suppress, arguing that the detectives lacked reasonable suspicion to stop him based solely on his unprovoked flight in a high-crime area. The Supreme Court affirmed the denial of the motion, holding that, under under the totality of the circumstances analysis, a court may consider whether unprovoked flight is an indication of criminal activity that, together with evidence of a high-crime area and any other relevant factors, establishes reasonable suspicion for a stop, or whether unprovoked flight, under the circumstances of the case, is a factor consistent with innocence that adds little or nothing to the reasonable suspicion analysis. View "Washington v. State" on Justia Law

The Court of Appeals affirmed the judgment of the court of special appeals reversing the decision of the post-conviction court determining that Appellant's trial counsel provided ineffective assistance by failing to object to certain incomplete or missing jury instructions, holding that defense counsel's failure to object to a "CSI effect" voir dire question did not render her performance constitutionally deficient.In 2007, Appellant was convicted by a jury of murder. In 2010 and 2011, the Court of Appeals held in three cases that a CSI effect message from the bench constituted reversible error. In 2014, Appellant filed a pro se petition for post-conviction relief arguing that he received ineffective assistance of counsel based on his counsel's failure to object to the trial court's CSI effect voir dire question. In 2020, the post-conviction court granted the petition for post-conviction relief and ordered a new trial. The court of special appeals reversed. The Court of Appeals affirmed, holding that under the professional norms that existed at the time of Appellant's trial, defense counsel's failure to object to a CSI-effect voir dire question did not render her performance constitutionally deficient. View "McGhee v. State" on Justia Law