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In this workers’ compensation case, the Court of Appeals clarified an exception to the "going and coming rule" - the special mission or errand doctrine. Employee, who was employed by Montgomery County, was injured in a car accident while driving from her home to a mandatory work training on a Saturday, which was normally her day off. The Workers’ Compensation Commission awarded compensation, finding that Employee’s injury arose out of and in the course of employment. The County sought judicial review, arguing that the going and coming rule prohibited recovery because accidental injuries sustained while going to or coming from work do not ordinarily arise out of and in the course of employment, and none of the exceptions to the rule applied. The circuit court granted summary judgment for the County. The Court of Special Appeals affirmed. The Court of Appeals reversed, holding (1) the going and coming rule, rather than the traveling employee doctrine, controlled Plaintiff’s case; but (2) the undisputed facts permitted a reasonable conclusion that the special mission exception to the going and coming rule applied in this case. View "Calvo v. Montgomery County, Maryland" on Justia Law

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In this workers’ compensation case, the Court of Appeals clarified an exception to the "going and coming rule" - the special mission or errand doctrine. Employee, who was employed by Montgomery County, was injured in a car accident while driving from her home to a mandatory work training on a Saturday, which was normally her day off. The Workers’ Compensation Commission awarded compensation, finding that Employee’s injury arose out of and in the course of employment. The County sought judicial review, arguing that the going and coming rule prohibited recovery because accidental injuries sustained while going to or coming from work do not ordinarily arise out of and in the course of employment, and none of the exceptions to the rule applied. The circuit court granted summary judgment for the County. The Court of Special Appeals affirmed. The Court of Appeals reversed, holding (1) the going and coming rule, rather than the traveling employee doctrine, controlled Plaintiff’s case; but (2) the undisputed facts permitted a reasonable conclusion that the special mission exception to the going and coming rule applied in this case. View "Calvo v. Montgomery County, Maryland" on Justia Law

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The Court of Appeals here adopted the “prison mailbox rule” - under which the papers or pleadings of unrepresented, incarcerated litigants are deemed “filed” when formally delivered to prison authorities for mailing to the circuit court - in the postconviction context and applied it to the case at bar. Petitioner, who was unrepresented and incarcerated at the time of the relevant events, testified that he delivered a petition for postconviction relief to prison authorities three days before a statutory ten-year filing deadline. Prison authorities mailed the petition to the circuit court two days later, and the petition arrived and was date-stamped by the clerk one day after the deadline. The circuit court rejected the petition as untimely. The court of special appeals affirmed. The Court of Appeals reversed, holding (1) this Court hereby adopts the prison mailbox rule; and (2) as applied to Petitioner, Petitioner’s petition for post-conviction relief was timely filed when he delivered it to prison authorities at least two days before the limitations period expired. The Court remanded the case with directions that the circuit court accept the petition as timely filed and proceed to consider the merits of the petition. View "Hackney v. State" on Justia Law

Posted in: Criminal Law

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The Court of Appeals here adopted the “prison mailbox rule” - under which the papers or pleadings of unrepresented, incarcerated litigants are deemed “filed” when formally delivered to prison authorities for mailing to the circuit court - in the postconviction context and applied it to the case at bar. Petitioner, who was unrepresented and incarcerated at the time of the relevant events, testified that he delivered a petition for postconviction relief to prison authorities three days before a statutory ten-year filing deadline. Prison authorities mailed the petition to the circuit court two days later, and the petition arrived and was date-stamped by the clerk one day after the deadline. The circuit court rejected the petition as untimely. The court of special appeals affirmed. The Court of Appeals reversed, holding (1) this Court hereby adopts the prison mailbox rule; and (2) as applied to Petitioner, Petitioner’s petition for post-conviction relief was timely filed when he delivered it to prison authorities at least two days before the limitations period expired. The Court remanded the case with directions that the circuit court accept the petition as timely filed and proceed to consider the merits of the petition. View "Hackney v. State" on Justia Law

Posted in: Criminal Law

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At issue was the proper procedure before an orphans’ court when an interested party files a petition to caveat a will and when an interested party requests that the orphans’ court transmit an issue to the circuit court for a trial by jury. In this case, the Court of Appeals held (1) when it enacted Md. Code Ann. Est. & Trusts 5-207(b), the General Assembly intended to mandate a judicial probate hearing as the single procedure after a party files a petition to caveat, and as such, an automatic stay is not required when a petition to caveat a will is filed; (2) when an interested party in a caveat case makes a request to transfer undecided factual issues to a circuit court, the orphans’ court is required to transmit the issues to a court of law pursuant to Md. Code Ann. Est. & Trusts 2-105(b); and (3) in this case, the orphans’ court did not err in refusing to stay the judicial probate proceeding simply because a petition to caveat was filed, but the court did err when it refused a party’s request to transmit unresolved factual issues to a court of law, and the error was not harmless. View "Shealer v. Straka" on Justia Law

Posted in: Trusts & Estates

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At issue was what findings a court must make in order to require attorney’s fees to be paid to an adverse party who was subjected to proceedings that were brought in bad faith or lacked substantial justification and what the appropriate means are for calculating attorney’s fees when a court determines that a party’s complaint includes claims that have substantial justification and claims that lack substantial justification. Respondents prevailed in having the trial judge dispose of Petitioner’s claims after the close of the evidence. The hearing judge found no substantial justification for each of Petitioner’s claims against Respondents and awarded $300,000 in attorney’s fees to Respondents. The court of special appeals vacated the circuit court’s judgment, concluding that there was substantial justification as to some of Petitioner’s claims. The Court of Appeals affirmed, holding that the hearing judge (1) did not commit clear error in finding no substantial justification for the claims brought by Petitioner; but (2) abused his discretion in assessing $300,000 in attorney’s fees against Petitioner without articulating how he calculated his fees. View "Christian v. Maternal-Fetal Medicine Associates of Maryland, LLC" on Justia Law

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At issue was what findings a court must make in order to require attorney’s fees to be paid to an adverse party who was subjected to proceedings that were brought in bad faith or lacked substantial justification and what the appropriate means are for calculating attorney’s fees when a court determines that a party’s complaint includes claims that have substantial justification and claims that lack substantial justification. Respondents prevailed in having the trial judge dispose of Petitioner’s claims after the close of the evidence. The hearing judge found no substantial justification for each of Petitioner’s claims against Respondents and awarded $300,000 in attorney’s fees to Respondents. The court of special appeals vacated the circuit court’s judgment, concluding that there was substantial justification as to some of Petitioner’s claims. The Court of Appeals affirmed, holding that the hearing judge (1) did not commit clear error in finding no substantial justification for the claims brought by Petitioner; but (2) abused his discretion in assessing $300,000 in attorney’s fees against Petitioner without articulating how he calculated his fees. View "Christian v. Maternal-Fetal Medicine Associates of Maryland, LLC" on Justia Law

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The Court of Appeals reversed the judgment of the Court of Special Appeals, which held that the police did not have probable cause to search the trunk of a car owned and driven by Respondent. The suppression court denied Respondent’s motion to suppress, ruling that, under the totality of the circumstances, the officers had reasonable suspicion that the individuals in the vehicle were involved in criminal activity, permitting the continued detention, and that by the time the officers searched the trunk of Respondent’s vehicle they had amassed probable cause - based in part on drug evidence found on the person of Respondent’s front-seat passenger - to believe the trunk contained evidence of drug-related activity. The Court of Special Appeals reversed. The Court of Appeals vacated the judgment of the Court of Special Appeals, holding that the intermediate appellate court failed to review, in their entirety, the facts and circumstances that led the police to search the trunk of Respondent’s car and instead isolated certain facts while ignoring or minimizing others. View "State v. Johnson" on Justia Law

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The Court of Appeals reversed the judgment of the Court of Special Appeals, which held that the police did not have probable cause to search the trunk of a car owned and driven by Respondent. The suppression court denied Respondent’s motion to suppress, ruling that, under the totality of the circumstances, the officers had reasonable suspicion that the individuals in the vehicle were involved in criminal activity, permitting the continued detention, and that by the time the officers searched the trunk of Respondent’s vehicle they had amassed probable cause - based in part on drug evidence found on the person of Respondent’s front-seat passenger - to believe the trunk contained evidence of drug-related activity. The Court of Special Appeals reversed. The Court of Appeals vacated the judgment of the Court of Special Appeals, holding that the intermediate appellate court failed to review, in their entirety, the facts and circumstances that led the police to search the trunk of Respondent’s car and instead isolated certain facts while ignoring or minimizing others. View "State v. Johnson" on Justia Law

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The Court of Appeals vacated the judgment of the circuit court affirming the finding of the administrative law judge (ALJ) that Respondent was coerced into submitting to an alcohol breath test required by Md. Code Ann. Transp. 16-205.1. In affirming, the circuit court concluded that substantial evidence supported the ALJ’s decision that Respondent did not voluntarily submit to the testing. The ALJ found, specifically, that the due process afforded to Respondent was insufficient and that the officer’s actions impermissibly induced Respondent to submit to an alcohol breath test. The Court of Appeals disagreed, holding that the ALJ’s determination was erroneous because Respondent failed to establish that there was an insufficient advisement of rights in violation of her due process protections. View "Motor Vehicle Administration v. Smith" on Justia Law