Justia Maryland Court of Appeals Opinion Summaries

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The Court of Appeals affirmed the judgment of the Court of Special Appeals affirming the judgment of the circuit court convicting Defendant of assault in the first degree, use of a firearm in the commission of a crime of violence, and wearing, carrying or transporting a handgun, holding that the Court of Special Appeals did not err.Specifically, the Court of Appeals held that the Court of Special Appeals (1) correctly affirmed the admission of a statement by a witness with memory loss as a prior inconsistent statement given the witness's contradictory testimony at trial; and (2) did not err in expanding the circumstances rule which hearsay is admissible under Md. Rule 5-802.1(a) to include statements containing a "material" inconsistency with the witness's testimony. View "Wise v. State" on Justia Law

Posted in: Criminal Law
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The Court of Appeals affirmed the judgment of the Court of Special Appeals upholding the circuit court's denial of coram nobis relief, holding that the nondisclosure of evidence relating to the alleged misconduct of several of the officers that prompted the charges and pleas in this case was not sufficient to render Petitioner's pleas involuntary.Petitioner pled guilty to have committed, in two separate cases, the crime of possession of heroin with intent to distribute. Upon completion of his sentences and probation, Petitioner filed a petition for a writ of error coram nobis, arguing that prior to the entry of his guilty pleas, the State failed to disclose to him evidence of misconduct on the part of some officers involved in the arrests that prompted the criminal charges and pleas. The circuit court denied the petition, and the court of appeals affirmed. The Supreme Court reversed, holding that the State was under no obligation to disclose the potential evidence of misconduct prior to trial and that the nondisclosure did not constitute a misrepresentation in violation of Brady v. United States, 397 U.S. 742 (1970). View "Byrd v. State" on Justia Law

Posted in: Criminal Law
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The Court of Appeals affirmed the judgment of the Court of Special Appeals reversing the order of the circuit court directing that Saint Luke Institute, Inc. (SLI) produce a patient's mental health records under seal, holding that the circuit court erred by failing to conduct the necessary statutory relevancy analysis required by the Maryland Confidentiality of Medical Records Act, Md. Code Ann. Health-Gen 4-301 through 309.Plaintiffs filed a civil case in Massachusetts alleging that they were sexually abused by a brother or member of a religious order while they were residing in a children's group home that employed the brother. Plaintiffs filed a proceeding in Maryland seeking discovery of the brother's mental health records they believed were in the custody of SLI, a Maryland facility. The circuit court entered an order directing the SLI to produce the brother's mental health records under seal. The Court of Special Appeals reversed. The Court of Appeals affirmed and outlined the process to be undertaken by the trial court prior to disclosure of mental health records requested by a private litigant in a civil case, holding that remand was required. View "St. Luke Institute v. Jones" on Justia Law

Posted in: Health Law
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In this workers' compensation action, the Court of Appeals reversed the judgment of the Court of Special Appeals reversing the judgment of the circuit court denying Uninsured Employers' Fund's (UEF) motion for judgment, holding that the Court of Special Appeals erred in concluding that the evidence was sufficient to establish that Tyson Farms, Inc. was Mauro Garcia's co-employer as a matter of law.Mauro Jimenez Garcia sustained an occupational disease of the lungs while working on a chicken farm. The chickens were raised for and owned by Tyson. The Uninsured Employers' Fund became involved in Garcia's workers' compensation claim, and Tyson was impleaded into the claim. The Commission issued an award of compensation, determination that Garcia was a covered employee that sustained an occupational disease arising of and in the course of his employment and that Tyson was Garcia's co-employer. On judicial review, the jury returned a verdict in favor of Tyson, finding that Tyson was not Garcia's co-employer. The Court of Special Appeals reversed. The Court of Appeals reversed, holding that there was sufficient evidence from which a reasonable jury could find that Tyson was not a co-employer of Garcia. View "Tyson Farms, Inc. v. Uninsured Employers' Fund" on Justia Law

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In this workers' compensation action, the Court of Appeals held that the Workers' Compensation Commission did not err in calculating the deduction of decibels from Claimants' total average hearing losses under Md. Code Ann., Lab. & Empl. (LE) 9-650(b)(3) by counting the number of years between each firefighter's fiftieth birthday and the dates that they each retired from employment with Montgomery County, Maryland.Anthony Cochran and Andrew Bowen, former firefighters, developed hearing loss, and Bowen also developed tinnitus. Both men filed a claim under LE 9-505. The Commission awarded compensation to both claimants, finding that each had sustained hearing loss arising in and out of the course of their employment and that Bowen had sustained tinnitus arising in and out of the course of his employment. The Court of Special Appeals held that the Commission correctly calculated the deduction set forth in LE 9-650(b)(3) but erred in awarding permanent partial disability benefits to Bowen for tinnitus. The Court of Appeals affirmed in part and reversed in part, holding (1) the Commission properly calculated the deduction set forth in LE 9-650(b)(3) by counting the number of years between each man's fiftieth birthday and the date of retirement; and (2) the Court of Special Appeals erred in reversing the Commission's decision as to tinnitus. View "Montgomery County v. Cochran & Bowen" on Justia Law

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The Court of Appeals held that the evidence in this case was sufficient to support Defendant's convictions for witness tampering and obstruction of justice where Defendant married a witness for the State with the corrupt intent of having her invoke the spousal testimonial privilege at his upcoming murder trial.The evidence indicated that Defendant married a potential witness for the State in order to have the witness invoke the spousal testimonial privilege at his murder trial. Before trial, the circuit court granted the State's motion to preclude the witness from invoking the spousal testimonial privilege. A jury subsequently found Defendant guilty of witness tampering and obstruction of justice. The Court of Special Appeals reversed, concluding that the evidence was insufficient to support the convictions because State failed to prove the "corrupt means" element of the convictions. The Court of Appeals reversed, holding (1) when a person marries a potential State witness with the intent to enable the witness to invoke the spousal testimonial privilege at a criminal proceeding the evidence is sufficient to support convictions for witness tampering and obstruction of justice; and (2) Defendant's conviction for witness tampering did not merge for sentencing purposes with his obstruction of justice conviction. View "State v. Wilson" on Justia Law

Posted in: Criminal Law
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The Court of Appeals answered certified questions asking whether Maryland recognizes an independent cause of action for breach of fiduciary duty, holding that this Court recognizes an independent cause of action for breach of fiduciary duty and outlining its scope and parameters.The Court of Special appeals filed a certification pursuant to Maryland Rule 8-304 requesting that the Court of Appeals provide guidance concerning whether an independent cause of action exists for breach of fiduciary duty. The Court of Appeals answered (1) Maryland does recognize such a cause of action, and to establish a breach of fiduciary duty a plaintiff must demonstrate the existence of a fiduciary relationship, breach of the duty owed by the fiduciary to the beneficiary, and harm to the beneficiary; and (2) a court should consider the nature of the fiduciary relationship and possible remedies afforded for a breach on a case by case basis, and the remedy will depend upon the specific law applicable to the specific fiduciary relationship at issue. View "Plank v. Cherneski" on Justia Law

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In this case, the Court of Appeals chose to adopt Daubert v. Merrell Dow Pharmaceuticals, Inc., 509 U.S. 579 (1993), as the governing standard by which trial courts admit or exclude expert testimony, thus replacing Maryland's "Frye-Reed Plus" standard.The Frye-Reed standard, born of Frye v. United States, 293 F. 1013 (D.C. Cir. 1923), and Reed v. State, 283 Md. 374 (1978), started in Maryland and continued to be the standard for determining the reliability of expert testimony after the United States Supreme Court decided Daubert. The Frye-Reed standard eventually morphed into the Frye-Reed Plus standard, which adopted several Daubert principles. For that reason, Appellant argued that this Court should adopt the Daubert standard and apply it to this case. The Supreme Court agreed and reversed this matter for pretrial proceedings and a new trial consistent with this opinion, holding (1) this Court adopts the Daubert standard in Maryland because those factors are persuasive in interpreting Maryland Rule 5-702; and (2) this case is remanded for the circuit court to apply this new evidentiary standard. View "Rochkind v. Stevenson" on Justia Law

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The Court of Appeals affirmed the judgment of the Court of Special Appeals affirming the judgment of the circuit court vacating original development approvals by the Frederick Council Council so that the Council could proceed with a de novo reconsideration proceeding, holding that the circuit court did not err in vacating the development approvals after the Developers refused to participate in a de novo reconsideration proceeding.A local citizens group opposed the Developers' rezoning and development application and sought judicial review. The circuit court found that a former member of the Frederick County Board of Commissioners had violated the ethics statute by engaging in an ex parte communication and remanded the case for reconsideration. The Frederick County Council reconsidered the Developers' application in a de novo proceeding, but the Developers refused to participate. Thereafter, the circuit court vacated the original development approvals and remanded the matter. The Court of Special Appeals affirmed. The Court of Appeals affirmed, holding (1) the County Council had the discretion to determine the scope of the reconsideration proceeding; (2) the doctrine of zoning estoppel does not apply under the facts of this case; and (3) there is no ambiguity in the Ethics Statute. View "75-80 Properties v. RALE, Inc." on Justia Law

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The Court of Appeals affirmed the judgment of circuit court judge upholding the order of the administrative law judge (ALJ) ordering Gregory Johnson's involuntary medication, holding that there was no error in the order authorizing Johnson's involuntary medication.Johnson was charged with attempted first-degree murder and related offenses. The circuit court found Johnson incompetent to stand trial and dangerous and committed him for treatment to a state-run forensic psychiatric hospital. After Johnson repeatedly refused to take prescribed antipsychotic medication the Maryland Department of Health began the process to administer the medication to Johnson involuntarily. An ALJ ordered Johnson's involuntary medication to restore him to competency, and the circuit court upheld the order. The Court of Appeals affirmed, holding (1) Maryland law authorizes involuntary medication to restore an individual's competence to stand trial and does not violate separation of powers by entrusting an ALJ with the power to order such medication subject to judicial review; and (2) because the Department and the ALJ met due process requirements, there was no error in the order authorizing Johnson's involuntary medication. View "Johnson v. Department of Health" on Justia Law