Justia Maryland Court of Appeals Opinion Summaries

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In this case involving the appropriate standard of review in an appeal on the record from the district court to the circuit court and the interpretation of a promissory note the Court of Appeals reversed the circuit court's judgment after applying the clearly erroneous standard to the district court's interpretation of the promissory note, holding that the circuit court applied the incorrect standard of review and erred in its interpretation of the promissory note. Petitioner offered a tuition loan program to its employee, and Respondent, a former employee of Petitioner, participated in this program until he was fired. Petitioner brought this action against Respondent seeking repayment of his debt. The district court entered judgment for Respondent. The circuit court affirmed, finding that the district court was not clearly erroneous in its interpretation of the promissory note. The Court of Appeals reversed, holding (1) a circuit court, in hearing an appeal on the record from the district court, reviews the district court's factual determinations for clear error and its legal conclusions de novo; and (2) the circuit court erred in construing the promissory note to require repayment only in situations where an employee quits. View "Credible Behavioral Health v. Johnson" on Justia Law

Posted in: Contracts
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The Court of Appeals affirmed the judgment of the Court of Special Appeals determining that, to be entitled to habeas corpus relief under Md. Code Ann. Cts. & Jud. Proc. (CJ) 3-702(a), a person must be physically restrained within Maryland and that Petitioner was not entitled to habeas corpus relief in this case because he was not physically restrained within the State, holding that because Petitioner filed his habeas corpus when he was not significantly restrained in Maryland he was not eligible to seek habeas corpus relief pursuant to CJ 3-702(a). Petitioner was found guilty of fourth-degree sex offense and placed on probation. The district court later found that Petitioner had violated his probation and modified the conditions of probation to be "unsupervised" so that Petitioner could move from Maryland to Michigan. Thereafter, Petitioner filed his habeas corpus petition. The circuit court denied the petition. The Court of Special Appeals dismissed Petitioner's appeal because Petitioner was neither physically restrained nor within the State when he filed his petition. The Court of Appeals affirmed, holding that, under CJ 3-702(a), to be eligible to seek habeas corpus relief, a person must be committed detained, confined, or restrained in the State. View "Sabisch v. Moyer" on Justia Law

Posted in: Criminal Law
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The Court of Appeals affirmed the decision of the Court of Special Appeals affirming the judgment of the circuit court finding that the Taneytown City Council violated some provisions of the Open Meetings Act (OMA), Md. Code, Title 3 of the General Provisions Article, but declining to impose sanctions, holding that the circuit court did not abuse its discretion in not imposing sanctions. Plaintiff alleged that the Council held a meeting that was closed to the public in violation of the OMA and asked the court to impose sanctions. The circuit court entered judgment for Defendant, concluding that the Council had violated certain provisions of the OMA but that those violations were technical, harmless, and not willful. The Court of Special Appeals affirmed. The Court of Appeals affirmed, holding (1) the use of "technicality" and harmless error as reasons to excuse violations of the OMA is rejected; (2) all sanctions under the OMA are discretionary with the trial court, and the court cannot impose such sanctions unless the violations were willful; and (3) although the trial court imposed used the wrong terms, the court did not abuse its discretion in determining that imposing civil penalties on the Council was not appropriate under the circumstances. View "Frazier v. McCarron" on Justia Law

Posted in: Civil Procedure
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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 second-degree assault and misconduct in office, holding that the court did not abuse its discretion in excusing for cause four prospective jurors who indicated that they would be unable to use the stairs to the jury room. In this case, the courthouse in the circuit court contained a staircase with twenty-five steps that was the only way to reach the jury room that accompanied the courtroom used for the trial. The four prospective jurors said that they would have difficulty using or would be unable to use the stairs the trial court excused them. Defendant, a correctional officer, was convicted of second-degree assault and misconduct in office. The Court of Appeals affirmed, holding that, under the circumstances, the circuit court did not clearly err in finding that no other courtroom was available and excusing the prospective jurors for cause. View "Trotman v. State" on Justia Law

Posted in: Criminal Law
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The Court of Appeals affirmed the circuit court's grant of preliminary injunctive relief enjoining the State Board of Elections from certifying the 2018 general election ballot with April Ademiluyi's name listed as a candidate for circuit court judge, holding that the Libertarian Party's nomination of Ademiluyi did not comport with the requirements of Md. Code Ann. Elec. Law (EL) 5-701 and that the circuit court's grant of preliminary injunction was sufficiently supported by the appropriate factors. Ademiluyi was a registered Democrat. Upon learning of Ademiluyi's party affiliation, Appellees challenged her qualifications for nomination as a circuit court judge. The circuit court ordered that Ademiluyi's be removed from the ballot. The Court of Appeals affirmed the circuit court's grant of preliminary injunctive relief, holding that Ademiluyi's candidacy was impermissible under the relevant provisions that regulate judicial elections in Maryland because (1) Ademiluyi's candidacy was at odds with the Libertarian Party's Constitution, which requires that its candidates for office be registered Libertarians; and (2) a judicial candidate's route to access the ballot is dependent upon her party affiliation, and candidates registered with a principal party may only achieve this end through participation in primary elections. View "Ademiluyi v. Egbuono" on Justia Law

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The Court of Appeals affirmed the holding of the court of special appeals affirming the judgment of the juvenile court finding that sixteen-year-old S.K. was involved in distributing child pornography, holding that a minor may be adjudicated delinquent under Maryland's child pornography and obscenity statutes as the "person" who is a distributor of child pornography and a displayer of obscene matter when she is also the minor participant in the sex act. S.K. sent a video to her two best friends that showed herself performing fellatio in a male. When the video was later distributed to other students S.K. was charged under Md. Code Crim. Law (CR) 11-207(a)(4) and 11-203(b)(1)(ii). After an adjuratory hearing, the juvenile court found S.K. involved as to distributing child pornography and displaying an obscene item to a minor. The court of special appeals reversed in part, holding (1) a minor legally engaged in consensual sexual activity is not exempted from CR 11-207(a)(4); and (2) the cellphone video was not an "item" covered within CR 11-203(b)(1)(ii). The Court of Appeals reversed in part, holding (1) the plain language of CR 11-207(a)(4) subsumes situations where a minor produces and distributes pornographic material of himself or herself; and (2) S.K.'s conduct fell within that contemplated by CR 11-203. View "In re S.K." on Justia Law

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The Court of Appeals affirmed the judgment of the court of special appeals overturning Defendant's conviction based on a lack of independent evidence that would corroborate accomplice testimony, holding that Maryland's common law accomplice corroboration rule is hereby abrogated and that the jury, after proper instruction about the possible unreliability of accomplice testimony, is entitled to weigh the sufficiency of the evidence without the need for independent corroboration. Defendant was convicted of conspiracy to commit armed carjacking. The court of special appeals reversed, holding that the accomplices' testimony was not independently corroborated by other evidence, which left the remaining evidence legally insufficient to sustain Defendant's conviction. The Court of Appeals held (1) the common law accomplice corroboration rule, which requires that accomplice testimony be independently verified to sustain a conviction, is hereby abrogated and replaced with a modified common law rule; and (2) the new rule should not apply to Defendant. View "State v. Jones" on Justia Law

Posted in: Criminal Law
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In this case involving the claim of Petitioner, a veteran paramedic/firefighter regarding degenerative meniscal tears in his right knee the Court of Appeals affirmed the judgment of the trial court denying Baltimore County's motion for summary judgment and concluding that Petitioner's degenerative meniscal tears could be classified as an occupational disease, holding that there was ample evidence that Petitioner's employment actually caused the degenerative tears. The trial court determined that Petitioner met the statutory requirements set forth in Md. Code Ann. Lab. & Empl. (LE) 9-502(d)(1) that his alleged occupational disease was "due to the nature of an employment in which hazards of the occupational disease exist...." The County appealed. The Court of Appeals affirmed, holding that there was sufficient evidence for the jury reasonably to conclude that Petitioner's degenerative knee tears were "due to the nature of an employment in which hazards of the occupational disease exist." View "Baltimore County v. Quinlan" on Justia Law

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The Court of Appeals affirmed the decision of the court of special appeals affirming the judgment of the trial court granting Defendants' motion to dismiss this action brought by a former tenant of a public market in Baltimore City, holding that the tenant was not a "displaced person" as that term is defined in Md. Code Ann. Real Prop. (RP) 12-201(e)(1)(i), and therefore, the tenant was not wrongfully denied moving and relocation expenses and there was no unconstitutional taking. After a rental agent for the public market advised the tenant that its business did not fit in the redevelopment plans for the market and that it should pursue other options, the tenant vacated the market. The tenant sued seeking compensation for moving and relocation expenses as a displaced person and for an unconstitutional taking. The trial court dismissed the action, concluding that the tenant did not qualify as a "displaced person" because the exemption in RP 12-201(e)(2)(iii) applied. The court of special appeals affirmed. The Court of Appeals affirmed, holding that the tenant was both not a displaced person under RP 12-201(e)(1)(i) and exempt from qualifying as a displaced person under RP 12-201(e)(2)(iii). View "Wireless One, Inc. v. Mayor & City Council of Baltimore" on Justia Law

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The Court of Appeals affirmed the judgment of the court of special appeals vacating the circuit court's dismissal of Defendant's motion for modification of sentence without ruling on the merits, holding that where a defendant has been granted postconviction relief to file a belated motion for modification of sentence the circuit court abuses its discretion by not exercising its "fundamental jurisdiction" to revise a sentence. The postconviction court ruled that Defendant received ineffective assistance of counsel because his attorney failed timely to file a motion for modification. Accordingly, the postconviction court granted Defendant's permission to file a belated motion for modification. In compliance with the postconviction court's order, Defendant filed a motion for modification within ninety days of the postconviction court's order. The Supreme Court ruled that the trial court had revisory power over Defendant's sentence, and therefore, the court erred when it prematurely concluded that it lacked revisory power over Defendant's sentence and thereby failed to exercise its discretion to rule on the motion for modification of sentence. View "State v. Schlick" on Justia Law

Posted in: Criminal Law