Justia Maryland Court of Appeals Opinion Summaries

Articles Posted in Government & Administrative Law
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The Court of Appeals affirmed the judgment of the circuit court granting the motion for summary judgment brought by Calvert County, Maryland and dismissing the claims brought by Petitioners, four Calvert County residents, against the Board of County Commissioners of Calvert, holding that there was no error.Petitioners brought an action against the County Commissioners and County seeking a declaratory judgment that the Calvert County Comprehensive Plan was illegally passed because one of the Commissioners had a conflict of interest in the legislation and did not recuse himself and requesting that the circuit court void the plan in light of the conflict. The circuit court granted the County's motion for summary judgment. The Supreme Court affirmed, holding that the circuit court correctly entered summary judgment in favor of the County. View "Dzurec v. Bd. of County Commissioners Calvert County" on Justia Law

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The Court of Appeals affirmed the judgment of the court of special appeals affirming the circuit court's judgment affirming the decision of the Maryland Workers' Compensation Commission granting Respondent's request for compensation for his hernia, holding that the court of special appeals did not err.In granting Respondent's request for compensation, the Commission found that Respondent sustained an accidental injury during employment, that his current hernia was the result of the accidental injury, and that, as a result of the hernia, Respondent was totally disabled for several months. The circuit court and court of special appeals affirmed. The Court of Appeals affirmed, holding that the court of special appeals did not err when it (1) held that "definite proof" under L&E 9-504(a)(1) applies to the quality of evidence presented and not the standard of proof a claimant must meet; and (2) concluded that Respondent met his burden of persuasion when producing medical evidence to a preponderance of the evidence standard. View "United Parcel Service v. Strothers" on Justia Law

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The Court of Appeals agreed with the conclusions of the circuit court and the court of appeals that the record containing the "code key" assigning each judge a code for purposes of access to information about court proceedings and filings did not fall under the exception from public access in the Maryland Rules, holding that the code key was disclosable in response to the records request in this case.An online database Case Search, which is overseen by the Administrative Office of the Courts (AOC), provides public access to information regarding court proceedings. For cases in the District Court sitting in Baltimore City, the judge is identified by an alphanumeric code called the code key. The code key does not appear anywhere that is accessible to the public. Abell Foundation requested a copy of the code key from the AOC under the Maryland Public Information Act, but the AOC did not comply, citing the the exception for certain administrative records in Maryland Rule 16-905(f)(3), as it existed at the time. The circuit court granted summary judgment for Abell on judicial review, and the court of appeals affirmed. The Supreme Court affirmed, holding that the code key was disclosable in response to Abell's public records request and was not exempt from disclosure under the Maryland Rules. View "Administrative Office of the Courts v. Abell Foundation" on Justia Law

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The Court of Appeals held that the Forest Conservation Act of 1991 (the Act) and regulations promulgated by the Maryland Department of Natural Resources (DNR) required a right to appeal the approval of a forest conservation plan and that a county agency's approval of a forest conservation plan is a "final decision" for appeal purposes.At issue before the Court of Appeals was whether the approval of a forest conservation plan, as well as an associated waiver that authorizers a developer to remove trees that would otherwise be protected under the Act, is a final agency decision subject to independent judicial review under the Harford County Forest Conservation Program. The Court of Appeals reversed the decision of the court of special appeals with directions to remand the case for further proceedings in the circuit court, holding that the Act and regulations promulgated by DNR require a right to appeal the approval of a forest conservation plan and that a county agency's approval of a forest conservation plan is a "final decision" for appeal purposes. View "Chesapeake Bay Foundation, Inc. v. CREG Westport I, LLC" on Justia Law

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The Court of Appeals ruled that the Board of Appeals of Baltimore County erred in reversing an administrative law judge's determination that substantial changes existed between an original development plan and a later proposed development plan, holding that, contrary to the Board's conclusion, the doctrine of collateral estoppel did not bar approval of the later-proposed development plan.After a hearing, the Board issued an opinion concluding that the ALJ erred as a matter of law in ruling that the most recent development plan modification at issue was not barred by collateral estoppel. The circuit court reversed the Board's decision, concluding that the Board misapplied the law and misconstrued the facts in making its decision. The court of special appeals reversed. The Court of Appeals reversed, holding that the Board erred in concluding that collateral estoppel barred the approval of the most recent development plan. View "Becker v. Falls Road Community Ass'n" on Justia Law

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The Court of Appeals affirmed the judgment of the circuit court denying Petitioner's complaint seeking an injunction and declaratory relief to enjoin a student member on the Board of Education of Howard County from exercising any voting power and a declaration that the election process for the student member violates the Maryland Constitution, holding that there was no error.After relying on remote learning for schooling during the Covid-19 pandemic, at the end of 2020, the Board of Education of Howard County held votes on motions to resume in-person instruction. Each motion failed by a stalemate vote, with the student member causing the stalemate. After the Board decided to continue with remote learning Petitioners brought this action seeking an injunction and a declaration that the statute creating the student member on the Board is unconstitutional. The circuit court granted summary judgment for the Board, and the court of appeals affirmed. The Supreme Court affirmed, holding that the provisions of section 3-701 of the Education Article concerning the student member position on the Board do not violate the Maryland Constitution. View "Spiegel v. Board of Education of Howard County" on Justia Law

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The Court of Appeals affirmed the decision of the court of special appeals affirming the circuit court's grant of summary judgment in favor of Montgomery County in this workers' compensation case, holding that there was no error in the proceedings below.In 2007, Petitioner, a firefighter in Montgomery County, experienced a service-related back injury, which led to his retirement three years later. Petitioner subsequently developed a compensable degree of occupational hearing loss related to his employment and sought workers' compensation benefits. Although the Workers' Compensation Commission awarded Petitioner compensation for his hearing loss the Commission determined that the entirety fo the award be offset under Md. Code, Lab. & Empl. (LE) 9-610. The Court of Appeals affirmed, holding that Petitioner's service-connected total disability retirement benefits arising from his back injury were "similar" to his permanent partial disability benefits, and the benefits related to his occupational hearing were offset under LE 9-610. View "Spevak v. Montgomery County" on Justia Law

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In this action challenging a proposed amendment that would remove two schoolhouses from a county list of historically protected sites the Court of Appeals affirmed the decision of the court of special appeals affirming the judgment of the circuit court finding that the adoption of CR-72-2019 was not arbitrary and capricious and was supported by substantial evidence, holding that Prince George's County Council acted within its legal boundaries when it adopted the minor amendment CR-72-2019.Specifically, the Court of Appeals held (1) the arguments raised by the Town of Upper Marlboro had not been waived because CR 72-2019 was not a final appealable decision; (2) CR 98-2019 was a final agency action subject to judicial review, and the Town was permitted to challenge CR 98-2019 by alleging deficiencies in CR-72-2019; and (3) CR-72-2019 was not procedurally deficient because the resolution adequately provided the purpose and scope of the minor amendment pursuant to Prince George's County Code 2727-642. View "Town of Upper Marlboro v. Prince George's County Council" on Justia Law

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The Court of Appeals affirmed the conclusions of the circuit court and court of special appeals that the "code key that matches alphanumeric codes in Case Search to the judges on the District Court in Baltimore City" was disclosable to the public and was not exempt from disclosure under the Maryland Rules.At issue was Case Search, an online database overseen by The Administrative Office of the Courts (AOC) that provides public access to information about court proceedings and records that are open to the public. For cases in the District Court sitting in Baltimore City, the judge who presided over the particular proceeding is identified in Case Search but only by an alphanumeric code. Specifically in question was the whether the record containing the code key given to clerks who enter information from paper records into the digital database that assigns each judge a code falls under the exception from public access in the Maryland Rules. The lower courts concluded that the exception does not apply to the code key. The Court of Appeals affirmed, holding that the code key is disclosable in response to public records requests and is not exempt from disclosure under the Maryland Rules. View "Administrative Office of the Courts v. Abell Foundation" on Justia Law

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The Court of Appeals held that Baltimore City Council's enactment of a local law did not create a private right of action for Baltimore City tenants to recoup rent payments and related fees they paid in connection with their use and occupancy of rental dwellings during a period when the landlord did not have a valid rental license.Petitioners, tenants in a multi-unit apartment building, filed a putative class action alleging that Respondent did not hold an active rental license for the property, as required by the Baltimore City Code, and seeking to recoup paid rent and other fees paid to Respondent. The circuit court dismissed the case prior to a determination of issues relating to class certification. The court of special appeals largely agreed. The Court of Appeals affirmed, holding that section 5-4(a)(2) of Article 13 of the Baltimore City Code does not provide a private right of action to recover rent and related payments that a tenant made during a period in which the landlord was unlicensed. View "Aleti v. Metropolitan Baltimore, LLC" on Justia Law