Justia Maryland Court of Appeals Opinion Summaries

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The Court of Appeals recognized the tort of intentional interference with a prospective gift or inheritance and adopted the standards set forth in Section 19 of the Third Restatement of Torts. Petitioner, the residuary beneficiary of the Estate of Peter A. Castruccio, alleged that Respondent, Peter's widow, maliciously depleted her inheritance by forcing the Estate's expenditure of attorneys' fees to defend against Respondent's groundless lawsuits and efforts to initiate criminal charges. Petitioner alleged, as relevant to this appeal, intentional interference with an expectancy. The circuit court granted Respondent's motion to dismiss, ruling that the cause of action for intentional interference with an inheritance is not a cause of action under Maryland law. The Court of Special Appeals affirmed. The Court of Appeals affirmed, holding (1) this Court recognizes the tort of intentional interference with an inheritance or gift; but (2) the allegations in Petitioner's complaint were insufficient to survive a motion to dismiss. View "Barclay v. Castruccio" on Justia Law

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In this criminal case in which Defendant was charged with various drunk driving offenses the Court of Appeals reversed the judgment of the trail court denying Defendant's motions in limine to exclude field sobriety tests and a breath test from the evidence, holding that, in giving advice of rights, law enforcement officers must use methods that reasonably convey the warnings and rights in the implied consent statute. Police officers found Defendant asleep at the wheel of his truck and brought him to the station after he failed several field sobriety tests. An officer read in English an "Advice of Rights" form, commonly referred to as a DR-15 form, to Defendant, who spoke Spanish. Defendant signed the DR-15, agreeing to take a breath test, and failed the test. Defendant moved to exclude the tests, arguing that he did not understand the field sobriety test instructions or the advice of rights because he did not understand English. The trial court denied the motions, and Defendant was convicted. The Supreme Court reversed and remanded for a new trial at which the breath test evidence must be suppressed, holding that the officer in this case did not use methods that reasonably conveyed the warnings and rights in the implied consent statute. View "Funes v. State" on Justia Law

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The Court of Appeals affirmed the opinion of the Court of Special Appeals affirming the circuit court's denial of Petitioner's petition for a writ of habeas corpus, holding that Maryland lacked jurisdiction over Petitioner to commit him to the Department of Health and that the Interstate Agreement on Detainers (IAD) required Petitioner's return to Ohio to serve the remainder of his sentence there. After commencing a sentence in Ohio for felony assault, Petitioner requested a transfer under the IAD to Maryland where a murder charge was pending against him. Petitioner pled guilty in Maryland to second degree murder. After a trial, the jury returned a verdict of "not criminally responsible." The State asserted that the IAD required that Petitioner first return to Ohio to finish his sentence. Petitioner filed a habeas corpus petition seeking to remain in Maryland, but the circuit court denied relief. The Court of Special Appeals affirmed. The Court of Appeals affirmed, holding (1) under the the plain language of the IAD, Maryland had custody of Petitioner only for the purpose of resolving the pending murder charge and thus did not have jurisdiction to commit him to the Department; and (2) article VI(b) of the IAD did not prevent Petitioner's return to Ohio. View "Aleman v. State" on Justia Law

Posted in: Criminal Law
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The Court of Appeals held that the bifurcated hybrid trial procedure split between two factfinders is not permitted under Maryland Rule 4-253(c) and is inconsistent with this Court's holding in Carter v. State, 824 A.2d 123 (Md. 2003). Petitioner filed a motion to bifurcate counts of possession of a regulated firearm by a prohibited person and ammunition counts from the remaining counts in an indictment. Petitioner suggested that some counts be decided by a jury and that the trial judge determine his guilt as to other counts in a singular hybrid judge/jury trial. The trial court denied the motion. Petitioner was subsequently found guilty. The Court of Appeals affirmed, holding (1) a hybrid judge/jury trial in which the judge determines the defendant's guilt with respect to the charge of possession of a regulated firearm by a prohibited person and the jury determines guilt as to the remaining charges is not permitted under Rule 4-253(c); but (2) Rule 4-253(c) permits a Joshua-style bifurcated criminal jury trial, under which the bifurcation of possession of a regulated firearm by a prohibited person counts from other charges is allowed if a defendant's guilt as to all of the charges is determined by the same factfinder. See United States v. Joshua, 976 F.2d 844 (3d Cir. 1992). View "Hemming 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 holding that a police-initiated procedure resulting in the identification of Defendant was not governed by constitutional criminal procedure law concerning out-of-court identifications made by an eyewitness, holding that the identification of Defendant was a "confirmatory identification" not subject to constitutional scrutiny. Shortly after a murder, investigating detectives focused on Defendant as the suspected killer. The detectives were aware that the murder victim's current girlfriend, Jennifer McKay, knew Defendant and until recently had been in an intimate relationship with him. When interviewing McKay at the police station the detectives asked her to review camera footage captured with a surveillance camera mounted on a building adjacent to the apartment where the murder occurred. McKay did so and determined that a person depicted on the footage looked like Defendant. Defendant moved to suppress McKay's identification of him, arguing that the identification was obtained during an impermissible suggestive process. The circuit court granted the suppression motion. The Court of Special Appeals reversed. The Court of Appeals affirmed, holding that the identification at issue in this case did not implicate the constitutionally-based identification law paradigm. View "Greene v. State" on Justia Law

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The Court of Appeals affirmed the decision of the circuit court holding that the General Assembly's amendment of the Maryland tax code authorizing the State Comptroller to pay refunds to taxpayers affected by a provision held to be invalid and providing for the State to pay interest on those refunds at a certain rate did not violate the dormant Commerce Clause of the federal Constitution. This litigation arose when Appellants challenged the credit allowed by State law against a Maryland resident's income tax liability based on taxes the resident paid to other states on income derived from those states. The Court of Appeals and the Supreme Court agreed with Appellants' argument that the tax scheme violated the dormant Commerce Clause. In response, the General Assembly amended the tax code. After the Comptroller issued Appellants a refund in compliance with the new legislation, Appellants appealed, seeking a higher rate of interest on the refunds. Following an administrative ruling in Appellants' favor, the circuit court held that the interest rate did not violate the dormant Commerce Clause. The Court of Appeals affirmed, holding that Appellants failed to meet their burden of showing discrimination in effect. View "Wynne v. Comptroller of Maryland" on Justia Law

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The Court of Appeals reversed the judgment of the Court of Special Appeals reversing the judgment of the circuit court quashing Respondent's writ of garnishment, holding that Md. Code Ann. Cts. & Jud. Proc. (CJ) 5-102(a)(3) does not operate to toll the statute of limitations on claim against a bankruptcy debtor that does not result in a dismissal of the petition. Petitioner was an insolvent debtor participating in an active bankruptcy case. Respondent was an unsecured creditor of Petitioner who held a claim in Petitioner's bankruptcy case arising from a judgment he obtained against her. Respondent sought to garnish the proceeds of a settlement Petitioner received that the bankruptcy court, but Petitioner argued that Respondent's judgment had expired under Md. Code Ann. Cts. & Jud. Proc. (CJ) 5-102(a)(3) because it had not renewed it. The circuit court quashed the writ of garnishment. The Court of Special Appeals reversed, holding that CJ 5-202 tolled the statute of limitations. The Court of Appeals reversed, holding that under the plain language of section CJ 5-202, the statute does not operate to toll the statute of limitations on a claim against a bankruptcy debtor that does not result in a dismissal of the petition. View "Hoang v. Lowery" on Justia Law

Posted in: Bankruptcy
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The Court of Appeals reversed the judgment of the Court of Special Appeals reversing the circuit court's judgment awarding damages to the Estate of Jeffrey Blair after finding that Baltimore City Police Officer David Austin used excessive force during his encounter with Blair, holding that the Court of Special Appeals erred when it overturned the jury's factual finding that Officer Austin exceeded the level of force that an objectively reasonable officer in his situation would have used. After Blair died of causes unrelated to the incident at issue Blair's Estate filed a complaint against Officer Austin. The jury determined that Officer Austin used excessive force in his interaction with Blair and awarded damages. The Court of Special Appeals reversed and held in favor of Officer Austin based on its independent weighing of a surveillance video. The Court of Appeals reversed, holding (1) the Court of Special Appeals erred when, based solely on its interpretation of the video evidence, it overturned the jury's factual finding that Officer Austin exceeded the level of force that an objectively reasonable officer in his situation would have used; and (2) legally sufficient evidence supported the trial court's decision to submit the case to the jury regarding Officer Austin's use of excessive force. View "Estate of Blair v. Austin" on Justia Law

Posted in: Personal Injury
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The Court of Appeals held that the statute of limitations begins to run in an underinsured motorist claim against an insurer when the insurer breaches the contract to provide underinsured motorist benefits by denying the insured's claim. Insured was injured in an automobile accident with an underinsured motorist. The underinsured tortfeasor extended to Insured a policy limits settlement offer of $20,000. Insured accepted the offer and then attempted to collect additional underinsured motorist benefits from Insurer. The motor vehicle liability insurance policy covered up to $300,000 per person for bodily injury caused by an uninsured or underinsured motorist. Insured later filed suit against Insurer seeking the balance of unpaid damages not covered by the $20,000 settlement. The circuit court dismissed the complaint as untimely. The Court of Special Appeals reversed. The Court of Appeals affirmed, holding (1) the statute of limitations in an underinsured motorist claim begins to run when the insurer denies an insured's demand for benefits, thereby breaching the insurance contract; and (2) Insured's underinsured motorist claim was not time barred. View "Nationwide Mutual Insurance Co. v. Shilling" on Justia Law

Posted in: Insurance Law
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The Court of Appeals affirmed the conclusion of the Court of Special Appeals that the release Bernard Collins provided in settlement of his workers' compensation claims did not bar Peggy Collins from asserting her independent claim for death benefits under the Maryland Workers' Compensation Act, Md. Code Ann. Lab. & Empl. Title 9. Two years before he died, Bernard settled claims he had brought under the Act against Petitioners, his former employer and its insurers, for disability benefits related to his heart disease. In the parties' settlement agreement, Bernard purported to release Petitioners from any claims that he or his spouse might have under the Act relating to his disability. After Bernard died, Peggy filed her claim for benefits based on Bernard's death from heart disease. The circuit court granted summary judgment in favor of Petitioners based on release. The Court of Special Appeals reversed. The Court of Appeals affirmed, holding (1) because Peggy was not a party to the settlement agreement, Petitioners may not enforce the release against Peggy; and (2) Bernard's settlement of his claims under the Act did not extinguish Peggy's future claim for death benefits. View "In re Bernard L. Collins" on Justia Law