Justia Maryland Supreme Court Opinion Summaries

Respondents manufactured steam pumps that were sold to the United States Navy. Although Respondents’ pumps contained asbestos gaskets and packing when they were delivered to the Navy, Respondents’ manuals did not contain any warnings regarding the danger of inhaling asbestos dust or directions to wear protective gear. Petitioner was the widow of a machinist mate who served on active duty in the Navy from 1956 until 1976. Petitioner’s husband was only exposed to asbestos after other Navy mechanics, who performed maintenance on Respondents’ pumps, replaced Respondents’ gaskets and packing with new components also containing asbestos that were acquired from third parties. Petitioner filed suit against Respondents, alleging negligence. The circuit court granted summary judgment in favor of Respondents, concluding that Respondents had no duty to warn of the dangers of the asbestos-containing replacement parts that they neither manufactured nor placed into the stream of commerce. The Court of Special Appeals affirmed. The Court of Appeals reversed, holding (1) summary judgment on Petitioner’s negligent failure to warn claims was inappropriate; and (2) Petitioner supplied sufficient evidence to survive Respondents’ motion for summary judgment on her strict liability claim. View "May v. Air & Liquid Systems Corp." on Justia Law

Petitioner, through his mother, filed this negligence suit against the landlord and owners (collectively, Respondents) of a rental dwelling where Petitioner had resided with his mother for alleged personal injuries resulting from lead-based paint poisoning. Petitioner identified two expert witnesses to testify both as to the source of his lead exposure, but only one of them as to the medical causation of the injuries suffered by Petitioner. Respondents filed a motion to exclude Petitioner’s experts and a companion motion for summary judgment. The circuit court granted Respondents’ motion for summary judgment, finding that Petitioner’s medical expert was not qualified to provide an expert opinion as to source of lead exposure or to medical causation, and that without the testimony of the medical expert, there was no dispute of material fact and Respondent was entitled to judgment as a matter of law. The Court of Special Appeals affirmed. The Court of Appeals reversed, holding (1) the medical expert was competent to testify as a medical causation expert; and (2) with the presence of the second expert to speak to the source of lead, it was improper for the circuit court to grant summary judgment when it did. View "Roy v. Dackman" on Justia Law

An inmate brutally murdered another inmate during a ride on a prison transport bus staffed by five correctional officers. At issue in this case was whether the correctional officer who was in charge of the bus was grossly negligent and, if so, whether he was entitled to common law public official immunity. The jury found that the officer at issue (“Cooper”) was grossly negligent and that his gross negligence was a proximate cause of the inmate’s death.The circuit court granted Cooper’s motion for judgment notwithstanding the verdict by striking the jury’s finding of gross negligence and determining that Cooper was immune from liability. The court of special appeals reversed as to Cooper, concluding that Cooper was grossly negligent and consequently not immune from liability. The Court of Appeals affirmed, holding (1) gross negligence is an exception to common law public official immunity; and (2) the court of special appeals was correct in ruling that Cooper was not entitled to common law public immunity because he acted with gross negligence. View "Cooper v. Rodriguez" on Justia Law

Respondents, three married couples, obtained home equity lines of credit from Petitioners, a bank and its loan officer. Approximately four years later, Petitioners filed a putative class action alleging that these transactions were part of an elaborate “buy-first-sell-later” mortgage fraud arrangement carried out by Petitioners and other defendants. Petitioners alleged numerous causes of action, including fraud, conspiracy, and violations of Maryland consumer protection statutes. The circuit court granted summary judgment for Petitioners, concluding that the statute of limitations barred several of Respondents’ claims and that no Petitioner violated the Maryland Secondary Mortgage Loan Law as a matter of law. The Court of Special Appeals reversed. The Court of Appeals reversed, holding that the Court of Special Appeals (1) erred in concluding that Respondents stated a claim upon which relief could be granted under the Maryland Secondary Mortgage Loan Law; and (2) erred in concluding that it was a question of fact to be decided by the jury as to whether Respondents’ claims against Petitioners were barred by the relevant statute of limitations. View "Windesheim v. Larocca" on Justia Law

Plaintiffs, husband and wife, were struck by a motor vehicle being driven by Adam Pond while they were on a walk. At the time of the accident, the Connors owned a vehicle insured by Government Employees Insurance Co. (GEICO). The terms of the policy included underinsured motorist (UIM) coverage of $300,000 per person/$300,000 per accident. Pond maintained automobile liability insurance with Allstate Insurance Co. limited to $100,000 per person/$300,000 per accident. Plaintiffs settled with Allstate. Pursuant to the settlement, Allstate paid $100,000 to each plaintiff. Plaintiffs then submitted claims for underinsured motorist coverage to GEICO under the terms of the policy, seeking $300,000 total from GEICO. GEICO paid Plaintiffs $100,000. Plaintiffs then filed a complaint for declaratory judgment against GEICO as to the $200,000 in dispute. The trial court granted summary judgment in favor of GEICO. The Court of Appeals affirmed, holding that under the unambiguous terms of the policy, the total damages due to Plaintiffs as a couple were capped at $300,000, and because Allstate already paid each Plaintiff $100,000, which amounts were deducted from the amount that GEICO would be required otherwise to pay Plaintiffs, GEICO was responsible for the remaining $100,000. View "Connors v. Gov't Employees Ins. Co." on Justia Law

This case arose out of the fatal shooting of Manuel Espina by Prince George’s County police officer Steven Jackson. Petitioners, Espina’s estate and family, filed suit against Respondents, Jackson and the County, alleging survival and wrongful death claims, as well as a claim on behalf of Espina’s son for a violation of his constitutional rights arising out of his treatment and arrest following Espina’s death. A jury returned a verdict against Respondents in the amount of $11,505,000. The trial court, looking to the Local Government Tort Claims Act’s (LGTCA) limits on liability, reduced the judgment entered against the County to $405,000 but left intact the full jury award as to Jackson. The Court of Special Appeals affirmed the judgment in part and reduced the award entered against the County to $400,000. The Court of Appeals affirmed, holding (1) the LGTCA, where applicable, limits the damages recoverable against a local government for violations of the state constitution; (2) applying the LGTCA damages cap to Petitioners’ constitutional tort claims violated neither Article 19 nor the supremacy of the state Constitution; and (3) the Court of Appeals correctly reduced Petitioners’ wrongful death and survivorship actions to an “individual claim” under the LGTCA. View "Espina v. Jackson" on Justia Law

Two security guards employed by SSA Security, Inc. and four of their confederates carried out a conspiracy to set fire to several homes. The resulting fires destroyed ten homes and damaged twelve others. Appellants asserted various civil claims against SSA and the five convicted arsonists, contending that the Maryland Security Guards Act (“Act”) section 19-501 established a basis for SSA’s strict liability for its employees’ intentional torts and civil rights violations. A federal district judge granted summary judgment in SSA’s favor as to the negligence claims and the claims premised on strict liability under section 19-501, concluding (1) section 19-501 was merely a codification of the common law and did not expand the doctrine of respondeat superior; and (2) any intentional acts of SSA’s employees were outside the scope of employment. Appellants appealed, arguing that the Act extends the vicarious liability of security guard agencies beyond the state common law doctrine of respondent superior. The federal appellate court certified a question of law to the Court of Appeals regarding the meaning of section 19-501. The Court answered that section 19-501 has the same meaning as Maryland’s common law doctrine of respondent superior. View "Antonio v. SSA Sec., Inc." on Justia Law

William Lovelace was a member of Amalgamated Transit Union, Local 1300 (Local 1300). For three years, Lovelace and David McClure (together with Local 1300, “the Union”) served together as officers on Local 1300’s executive board. When the men ran for reelection, Lovelace was defeated. Lovelace filed a defamation action against the Union, claiming that his defeat was due to allegedly false and defamatory statements McClure made during the campaign. Lovelace sought both compensatory and punitive damages. The Union filed motions to dismiss, asserting that Lovelace was required to exhaust Local 1300’s internal remedies before filing suit. The circuit court denied the motions. The jury ultimately rendered a verdict in Lovelace’s favor. The Union appealed, challenging the trial court’s denial of their motions to dismiss. The Court of Special Appeals affirmed, concluding that Local 1300’s internal remedies were inadequate because they could not provide the monetary damages that Lovelace sought. The Court of Appeals affirmed, holding that when a union member claims that his union and a fellow union member were liable for defamation and seeks monetary damages and the union's internal remedies do not provide monetary damages, the union’s internal remedies are inadequate and the union member is not required to exhaust them. View "Amalgamated Transit Union v. Lovelace" on Justia Law

In 2009, Charles Williams, who had been suffering with suicidal ideation and auditory and visual hallucinations, went to a hospital emergency room. Health care providers examined and evaluated Williams, decided not to admit him, and discharged him to the care of his mother. That same night, Williams broke into a residence and invited the responding law enforcement officers to shoot him. When Williams rushed the officers, they fired their weapons at him, killing him. Williams’ family (collectively, Plaintiffs) brought a wrongful death and survivorship action against the health care providers alleging negligence in their decision to release rather than involuntarily admit Williams to the hospital. The circuit court dismissed the complaint, concluding that the health care providers were protected from liability by statutory immunity. The Court of Appeals affirmed, holding that Maryland’s involuntary admission immunity statute applies to health care providers who evaluate an individual and decide in good faith not to involuntarily admit him. View "Williams v. Peninsula Reg’l Med. Ctr." on Justia Law

Plaintiff, the owner and operator of a used car business, filed an action against two Baltimore City police officers, claiming that the two officers, along with several other officers, had entered private property without a warrant or court order and towed Plaintiff’s vehicles. Plaintiff alleged that the warrantless towing of the vehicles without a prior hearing violated the Maryland Declaration of Rights as well as 42 U.S.C. 1983. The circuit court granted summary judgment for Defendants, concluding that the State constitutional claims were barred by the Local Government Tort Claims Act and that, in regard to the federal constitutional claims, the two officers had qualified immunity because they were acting pursuant to various provisions of the Baltimore City Code. The court of special appeals affirmed. The Court of Appeals affirmed, holding that Plaintiff’s state law claims were barred by the Local Government Tort Claims Act and that the two officers were entitled to qualified immunity on Plaintiff’s federal constitutional claims. View "Dehn Motor Sales v. Schultz" on Justia Law