Articles Posted in Maryland Court of Appeals

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Petitioner owned land in the Town of Goldsboro in Caroline County. Lake Bonnie provided the water source for the property, on which Petitioner operated a campground. In the mid-1990s, the Maryland Department of Environment (MDE) reported water quality impacts on Lake Bonnie due to failing septic systems in the Town and ordered the Town to take action regarding the septic systems. As of 2010, however, the Town had failed to comply with the order, and MDE had failed to enforce the order. Consequently, Lake Bonnie was polluted, the campground was destroyed, and the bank foreclosed on Petitioner's property. Petitioner sued the Town, County, MDE, and State, alleging several causes of action. All counts were dismissed against the Town, County, and State. The court of appeals affirmed. The Supreme Court affirmed in part and reversed in part, holding (1) because it was not clear from the face of her complaint that Petitioner's causes of action for negligence, trespass, and inverse condemnation were barred by limitations, the court of special appeals erred in affirming the motion to dismiss on those counts; and (2) Petitioner's causes of action for nuisance were barred by limitations, and the court of appeals correctly affirmed the motion to dismiss. View "Litz v. Md. Dep't of Env't" on Justia Law

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Ryan W. entered the care of the Department of Social Services at age nine as a child in need of services (CINA) and was placed in foster care. After Ryan's parents died, the Department was appointed by the Social Security Administration (SSA) as Ryan's representative payee for Old Age and Survivor's Disability Insurance (OASDI) benefits to which Ryan was entitled. The Department received Ryan's benefit payments and applied them to partially reimburse itself for the current cost of Ryan's foster care. The circuit court determined that the Department violated Ryan's due process and equal protection rights by failing to notify him before applying his OASDI benefits toward the current costs incurred by the Department on his behalf. The court of special appeals reversed. The Court of Appeals affirmed in part and reversed in part, holding (1) a local department of social services, acting in the capacity as an institutional representative payee appointed by the SSA, has discretion to apply a CINA foster child's OASDI benefits to reimburse the Department for its costs incurred for the child's current maintenance; but (2) the department must provide notice to the child that the department applied to the SSA and received such benefits on the child's behalf. View "In re Ryan W." on Justia Law

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Defendant was charged with murder and expressed a desire to have a bench trial. During the jury trial waiver colloquy, the trial judge provided Defendant with advice that the judge was not required to give Defendant and that was also erroneous. After a jury-waived trial, Defendant was convicted of first degree murder and sentenced to life imprisonment. Defendant appealed, arguing that his waiver of the right to a jury trial was not knowing and voluntary. The Court of Appeals reversed and remanded for a new trial, holding (1) the trial judge's erroneous advisement may have misled Defendant to believe a jury trial was a less attractive option than it actually was, thereby influencing Defendant's decision to waive his jury trial right; and (2) accordingly, the trial judge did not ensure that Defendant's waiver was knowing. View "Winters v. State" on Justia Law

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In 2011, the La Plata Town Council passed four resolutions, including an annexation resolution acquiring a tract of land. Several citizens of La Plata subsequently published a petition to refer the Council's annexation resolution to referendum. The town manager declared that sufficient signatures had been submitted. As such, the annexation resolution was suspended and all four resolutions were referred to referendum. Several referendum opponents filed a petition for judicial review of the manager's report validating the signatures and advancing the referendum to a vote. The circuit court judge ruled in favor of the referendum opponents, holding, inter alia, that although the petition for referendum presented foremost a land annexation resolution, the inclusion of the additional resolutions invalidated the petition. The Court of Appeals vacated the opinion and remanded, holding (1) where the petition for referendum contained legislative enactments that were collateral to the land annexation resolution but did not obfuscate the subject matter of the petition for referendum, the additions do not invalidate the petition; and (2) the town manager acted within his authority when he published Town policies for the validation and verification of signatures for referendum. View "Town of La Plata v. Faison-Rosewick LLC" on Justia Law

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In 1999, Petitioner pled guilty to a drug offense. Petitioner subsequently filed a petition for a writ of error coram nobis, asserting that his guilty plea was not voluntarily made due to his counsel's failure to advise him of the possible immigration consequences of his plea. The circuit court denied the petition. While Petitioner's appeal was pending, the U.S. Supreme Court decided Padilla v. Kentucky. On appeal, the court of special appeals determined that Padilla did not retroactively apply to vacate Petitioner's conviction. The Court of Appeals reversed. On remand, the court of special appeals again affirmed the denial of Petitioner's petition because Petitioner had not raised the issue of ineffective assistance of counsel in his plea. The Court of Appeals granted certiorari, but prior to oral argument, the U.S. Supreme Court held that Padilla did not apply retroactively. The Court of Appeals affirmed the denial of Petitioner's petition for coram nobis relief, holding that Petitioner's claims of involuntariness or ineffective assistance of counsel did not have independent state bases in Maryland in 1999. View "Miller v. State" on Justia Law

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In 2003, Appellant was convicted of rape. The Court of Appeals reversed, holding that the Maryland DNA Collection Act, which permits law enforcement authorities to collect DNA samples from individuals arrested for certain crimes, violated the Fourth Amendment as applied to Appellant. The U.S. Supreme Court reversed, holding that the DNA search of Appellant did not violate his Fourth Amendment rights. On remand, Appellant asked the Court to consider the issues left unresolved by King I. The Court of Appeals held (1) the Maryland DNA Collection Act does not violate Article 26 of the Maryland Declaration of Rights; and (2) the trial judge did not improperly shift the burden of proof to the defense to demonstrate how the State failed to comply with the Act, and even if a statutory violation were proven, there was no reversible error. View "King v. State" on Justia Law

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Plaintiffs, each of whom was arrested for a crime and brought before a District Court Commissioner for an initial appearance, filed a complaint against the District Court of Maryland and several court officials alleging that they were denied public defender representation during their initial appearance proceedings. Plaintiffs contended that the initial appearance proceeding is a critical stage of the criminal proceeding requiring state-furnished counsel pursuant to the Public Defender Act (Act) and that the failure to provide counsel violated their due process rights. The Court of Appeals held that the Act required the public defender to represent indigent criminal defendants at the initial appearance proceedings. While motions for reconsideration of the Court's opinion were pending, the General Assembly passed statutes amending the Act to provide that representation was not required to be furnished to an indigent individual at an initial appearance before a district court commissioner. The Court proceeded to hold that, under the due process component of the Maryland Declaration of Rights, an indigent defendant has a right to state-furnished counsel at an initial appearance before a district court commissioner. Remanded. View "DeWolfe v. Richmond " on Justia Law

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After Respondent resigned as executive director of the Chamber of Commerce, he filed a complaint against the Chamber, alleging violations of the Wage Payment and Collection Law, among other claims. After a jury trial, the court entered judgment against the Chamber. Respondent subsequently filed a motion for an award of attorneys' fees under the Wage Payment and Collection Law. The circuit court denied Respondent's motion on remand after applying a fee-shifting analysis from ERISA cases. The court of special appeals reversed the denial of the motion, holding that the circuit court erred in applying the ERISA factors. The Court of Appeals affirmed, holding that because ERISA and the Wage Payment and Collection Law serve distinct purposes and because their fee-shifting provisions are based on different principles, a trial court should not employ the ERISA fee-shifting test in deciding whether to award attorneys' fees. View "Ocean City Chamber of Commerce v. Barufaldi" on Justia Law

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After a jury trial, Petitioner was convicted of first degree murder and conspiracy to commit first degree murder. Petitioner unsuccessfully filed a petition for post-conviction relief, alleging ineffective assistance of counsel, after which he unsuccessfully filed an application for leave to appeal. Thereafter, Petitioner filed a motion for reconsideration, which the intermediate appellate court granted. The appellate court then determined that the application lacked merit because Petitioner was not prejudiced by the alleged errors of his counsel. The Court of Appeals reversed, holding that Petitioner received ineffective assistance of counsel when his trial counsel failed to object to approximately thirty instances during trial when the State admitted evidence that Petitioner had remained silent in the face of custodial police questioning after Petitioner had been issued Miranda warnings. Remanded. View "Coleman v. State" on Justia Law

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This case arose when six employees of the Baltimore Washington Conference of the United Methodist Church filed workers' compensation claims, claiming they had sustained physical injury as a result of exposure to mold in the Conference's office. The employees profferred Dr. Ritchie Shoemaker as their expert to prove causation. Defendant moved to exclude Shoemaker under Frye-Reed on the grounds that his methodology to determine causation was not generally accepted in the relevant scientific community. On remand, after a Frye-Reed hearing, the circuit court determined that Shoemaker's methodology was generally accepted by the relevant scientific community and satisfied the Frye-Reed test. The court of special appeals reversed. The Court of Appeals affirmed, holding that Shoemaker's technique and theory were not shown to be generally accepted in the relevant scientific community. View "Chesson v. Montgomery Mut. Ins. Co." on Justia Law