Justia Maryland Court of Appeals Opinion Summaries

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

In this zoning dispute involving the interplay between the public's interest in the future of a private airport in Prince George's County and the financial interests of its owner, the Supreme Court held that the amended zoning ordinance allowing the airport to develop higher-density housing did not violate Maryland's uniformity requirement, Md. Code Ann., Land Use 22-201(b)(2)(i).When the airport's owners began experiencing financial difficulties they sought to redevelop the site, which had been limited by the zoning ordnance to low-density, single-family detached housing, for non-airport use. The County Council amended the zoning ordinance to allow for higher-density housing to incentivize the airport's redevelopment. Plaintiffs brought suit. The circuit court concluded that the ordinance did not violate uniformity, but the appellate court reversed, finding that the ordinance violated uniformity because it was tailored so narrowly as to afford favorable development opportunities to only the airport property. The Supreme Court reversed, holding that the ordinance was adopted to further a valid public purpose and did not discriminate against similarly situated properties, thus surviving the uniformity challenge. View "Prince George's County v. Concerned Citizens" on Justia Law

The Supreme Court reversed the decision of the appellate court reversing the judgment of the circuit court finding that a county ordinance did not violate Maryland's uniformity requirement requiring zoning laws to "be uniform for each class or kind of development throughout a district or zone," Md. Code Ann., Land Use 22-201(b)(2)(i), holding that the ordinance should have survived the uniformity challenge.While Prince George's County's zoning ordinance had historically limited development of housing at a private airport to low-density, single-family detached housing, the County Council amended the ordinance's text to allow the development of higher-density housing at the airport in order to incentivize redevelopment. Certain constituents brought suit, arguing that the ordinance violated uniformity because it was tailored so narrowly as to afford favorable development opportunities. The appellate court reversed. The Supreme Court reversed, holding that the plaintiffs failed to establish that the ordinance discriminated arbitrarily, and therefore, their uniformity challenge failed. View "Prince George's County v. Concerned Citizens" 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 held that the Baltimore Police Department (BPD) arbitrarily and capriciously denied Open Justice Baltimore's (OJB) request for a fee waiver in relation to the production of closed files relating to certain use of force investigations and remanded the case to BPD to reconsider OJB's requested fee waiver in light of the factors set forth in this opinion, as well as other relevant factors.OJB, an organization seeking to investigate and publicize reports of police misconduct, filed several requests under the Maryland Public Information Act (MPIA) for records relating to citizen and administrative complaints of police misconduct. OJB asked BPD to waive the approximately $245,000 in fees it would cost to produce the files, asserting that a fee waiver would be in the public interest. BPD denied the fee waiver request in its entirety. The circuit court upheld the fee waiver denial. The Supreme Court remanded the case, holding that BPD's fee waiver denial was arbitrary and capricious because BPD failed meaningfully to consider all relevant factors in deciding whether to grant the requested fee waiver. View "Baltimore Police Dep't v. Open Justice Baltimore" on Justia Law

The Supreme Court affirmed in part and reversed in part the decision of the appellate court reversing the judgment of the circuit court granting Defendants' motion to dismiss this case for failure to state a claim upon which relief may be granted, holding that the appellate court erred in finding that Plaintiff's complaint alleged sufficient facts to state a cause of each for counts two and three.Plaintiff, a minority stockholder in a family-owned corporation, brought this action alleging one count of stockholder oppression seeking equitable relief short of dissolution (count one) and compensatory damages for claims of breach of fiduciary duty (count two) and unjust enrichment (count three). The circuit court granted Defendants' motion to dismiss, thereby denying Plaintiff's request for leave to amend the complaint. The appellate court reversed the judgment in its entirety. The Supreme Court affirmed as to count one and reversed as to the remaining counts, holding that Plaintiff's proposed amended complaint set forth sufficient facts to state a claim for stockholder oppression but did not allege sufficient facts to support Plaintiff's direct causes of action for breach of fiduciary duty and unjust enrichment. View "Eastland Food Corp. v. Mekhaya" on Justia Law

The Supreme Court held that Maryland law allows spouse to allocate martial assets in a postnuptial agreement based on whether a spouse engaged in adultery, thereby causing the breakdown of the marriage, thus affirming the judgment of the lower courts.Plaintiff filed a complaint for absolute divorce on the grounds of adultery, requesting that the circuit court incorporate the parties' postnuptial agreement into the decree. The agreement included a $7 million lump sum provision that triggered if Defendant engaged in adultery. The circuit court determined that the lump sum provision was an enforceable penalty and issued a judgment of divorce that incorporated, but did not merge, the agreement. The appellate court affirmed. The Supreme Court affirmed, holding (1) the public policy in Maryland supports intefspousal distributions of marital assets based on adultery in postnuptial agreements; and (2) Plaintiff was entitled to no more than Defendant's "50% share of the Column B Assets." View "Lloyd v. Niceta" 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

In this professional malpractice action, the Supreme Court vacated the judgment of the appellate court reversing the summary judgment of the trial court in favor of Defendant because Plaintiff could not prove damages and remanded this case to the circuit court for further proceedings consistent with this opinion, holding that remand was required.Plaintiff, a medical and surgical practice, retained Defendant, an accounting firm, in 2013 and terminated Defendant's services in 2015. In 2018, Plaintiff sued Defendant to recover damages for lost profits. Plaintiff designated a certificated public accountant (CPA) as an expert witness, who used the "before-and-after" method to calculate Plaintiff's lost profits. In 2021, the CPA issued updated calculations reflecting "normalizing adjustments" that she had made. The trial court excluded the CPA's expert testimony based on its application of the Daubert-Rochkind factors. The appellate court reversed the trial court's exclusion of the CPA's testimony and remanded the case for further proceedings. The Supreme Court remanded the cause, holding that the trial court erred in its consideration of the normalizing adjustments as reflecting on the reliability of the CPA's methodology, as opposed to the credibility of the CPA herself. View "Katz, Abosch, Windesheim, Gersham & Freedman, P.A. v. Parkway Neuroscience & Spine Institute, LLC" on Justia Law

The Supreme Court affirmed the judgment of the post-conviction court denying Petitioner's pro se petition for post-conviction relief, holding that the post-conviction court did not err in denying the petition.Petitioner was convicted of distribution of heroin and sentencing him to eight years in prison. In his post-conviction motion, Petitioner argued that his trial counsel rendered ineffective assistance during trial and that the State had violated its Brady obligations. The post-conviction court denied relief. The appellate court certified questions of law to the Supreme Court. The Supreme Court answered (1) Defendant failed to establish that trial counsel rendered ineffective assistance by failing to move to compel production of Internal Affairs Division files; and (2) assuming, without deciding, that the State was required to disclose impeachment evidence prior to the suppression hearing, Petitioner failed to establish the Brady materiality standard. View "Blake v. State" on Justia Law