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Jayson Master sought access to a lease between Calvert Tract, LLC and Whole Foods. Calvert Tract had earlier voluntarily provided a redacted version of the lease to Prince George’s County while its zoning application was pending. The County denied Master’s request seeking access to the lease, explaining that the lease was not subject to disclosure under the Maryland Public Information Act (MPIA). Master then filed a complaint seeking access to the lease. The trial court granted summary judgment to Calvert Tract and the County, concluding that the lease was confidential commercial information and therefore was exempt under the MPIA. The Court of Special Appeals affirmed. The Court of Appeals vacated the judgment of the Court of Special Appeals, holding that the trial court erred in granting summary judgment on the grounds that the lease was protected from disclosure under the MPIA’s confidential commercial information exemption. View "Amster v. Baker" on Justia Law

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Darrell Ellis filed criminal charges against Andrew Baker for an incident involving a shoot-out. Baker then filed criminal charges against Ellis for an alleged assault that occurred two days later. At Baker’s trial for allegedy assaulting Ellis, it was discovered that Ellis’ defense counsel for the charges related to the second incident was related to the assistant state’s attorney who was prosecuting Baker for the charges stemming from the first incident. Upon learning this information, the trial court declared a mistrial over Baker’s objection. Baker filed a motion to dismiss his indictments on grounds of double jeopardy. The trial court denied the motion. The Court of Special Appeals reversed and ordered the indictments be dismissed. The Court of Appeals affirmed, holding that retrial of Baker was barred by double jeopardy principles because the trial court’s declaration of a mistrial over Baker’s objection was not supported by manifest necessity. View "State v. Baker" on Justia Law

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The circuit court erred in dismissing the minor Appellant’s wrongful death claims as untimely and erred in failing to consider that the time limitation to file a wrongful death action is tolled when the defendant engages in fraudulent conduct that prevents the plaintiffs from bringing a wrongful death action within three years from the date of death, pursuant to Md. Code Cts. & Jud. Proc. 5-203. Cassandra Parker, Craig Parker’s mother, and Craig’s five-year-old child filed a complaint against William Hamilton alleging that Hamilton killed Craig and buried Craig’s remains in order to conceal his wrongdoing. The circuit court granted Hamilton’s motion to dismiss as to the wrongful death claims, concluding that they were time-barred under Md. Code Cts. & Jud. Proc. 3-904. The Court of Appeals reversed, holding that both Md. Code Cts. & Jud. Proc. 5-201, which operates to toll a minor plaintiff’s wrongful death claims during the period of his or her minority, and section 5-203. View "Parker v. Hamilton" on Justia Law

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Three of four siblings who were beneficiaries under an irrevocable trust attempted to remove the fourth sibling as a beneficiary by relying on a provision of the irrevocable trust that permitted seventy-five percent of the beneficiaries to amend the terms of the trust. The Court of Appeals held (1) the plain language of the modification provision granting the modification authority to the beneficiaries of the irrevocable trust does not grant authority for three beneficiaries of the trust to remove the fourth beneficiary; (2) the trust clearly manifests the settlor’s intent for the trust to benefit the four beneficiaries equally; and (3) therefore, the amendment in which the three beneficiaries purported to divest the fourth beneficiary was impermissible under the terms of the trust. View "Vito v. Grueff" on Justia Law

Posted in: Trusts & Estates

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After a jury trial, Petitioner was acquitted of murder in the first degree but convicted of murder in the second degree. The circuit court granted Petitioner’s motion for a new trial. After the State rested its case during the second trial, the trial judge declared a mistrial and discharged the jury. The case was rescheduled. Petitioner then filed a motion to dismiss the indictment on grounds of double jeopardy. After hearing arguments, the judge struck his previous grant of a mistrial and granted Petitioner’s previously-filed motion for judgment of acquittal, thus dismissing the second-degree murder charge against Petitioner based on insufficiency of the evidence. The State subsequently reindicted Petitioner for second-degree murder. Upon Petitioner’s motion, the trial judge dismissed the indictment. The Court of Appeals reversed, concluding that principles of double jeopardy did not bar Petitioner’s retrial because the trial court could not acquit Petitioner after declaring a mistrial and discharging the jury. The Court of Appeals affirmed, holding that the trial judge acted without authority in acquitting Petitioner weeks after he had declared a mistrial and discharged the jury. View "Johnson v. State" on Justia Law

Posted in: Criminal Law

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In 1993, Respondent was convicted of two counts of felony murder and other crimes. Respondent was sentenced to life without parole for the murders. Twenty-one years later, a trial witness alleged that he “lied” during Respondent’s trial when he identified Respondent as the individual who shot the victims. Thereafter, Respondent filed a pro se petition for writ of actual innocence under Md. Code Ann. Crim. Proc. 8-301, alleging that the recantation constituted “newly discovered evidence.” The circuit court denied the petition. The Court of Special Appeals reversed. The Court of Appeals vacated the judgment of the Court of Special Appeals and remanded the case to the circuit court for further proceedings, holding (1) a petition that fails to include an averment of innocence but otherwise complies with the pleading requirements contained in Maryland Rule 4-332(d) may be amended if the circuit court determines that allowing an amendment would do substantial justice; and (2) Petitioner alleged sufficient “newly discovered evidence” that could create a “substantial of significant possibility” that his original trial may have been different and was therefore entitled to a hearing under Md. Code Ann. Crim. Proc. 8-301(e)(1). View "State v. Ebb" on Justia Law

Posted in: Criminal Law

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Petitioner, a Colorado resident, entered Maryland pursuant to a summons to testify at a murder trial. Petitioner was subsequently arrested in Maryland, and the State charged him with crimes related to the murder. A jury found Petitioner guilty of first-degree murder and conspiracy to commit first-degree murder. Petitioner did not allege, either pretrial or during trial, that his arrest violated the Maryland Uniform Act to Secure the Attendance of Witnesses from Without State in Criminal Proceedings. For the first time on appeal, Petitioner argued that the State’s prosecution of him violated Md. Code Ann. Cts. & Jud. Proc. (CJ) 9-304(a), and therefore, the circuit court improperly exercised personal jurisdiction over him. The Court of Special Appeals affirmed, concluding that petitioner’s challenge to the exercise of personal jurisdiction was waived. The Court of Appeals affirmed, holding that Petitioner waived the issue of a violation of CJ 9-304(a) by failing to raise it pretrial as required by Maryland Rule 4-252. View "Lewis v. State" on Justia Law

Posted in: Criminal Law

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After a jury trial, Petitioner was convicted of armed robbery, robbery, and related offenses. The trial court sentenced Petitioner to twenty years’ imprisonment for armed robbery and merged the remaining offenses. Petitioner appealed, arguing that the trial judge abused his discretion in conducting the voir dire of the prospective jurors. The Court of Special Appeals affirmed the judgment of conviction. The Court of Appeals affirmed, holding that the voir dire process in this case reasonably assured that Petitioner was tried before an impartial jury. The Court, however, used the opportunity of this case to encourage trial judges to adopt certain best practices to help achieve the constitutionally requirement of an impartial jury. View "Collins v. State" on Justia Law

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After a jury trial in 2000, Appellant was convicted of first- and second-degree murder, first-degree assault, and the unlawful taking of a motor vehicle. In 2013, Appellant filed a Public Information Act request requesting the results of any testing performed on the hair fibers from the black t-shirt he was wearing when he was arrested in 1997. The State admitted that the black t-shirt was destroyed in 2003, after the appellate process was exhausted. In 2014, Appellant filed a petition in the circuit court requesting a hearing under Mc. Code Ann. Crim. Proc. 8-201(j)(3)(i) to determine whether the State’s failure to produce the requested evidence was the result of intentional and willful destruction. The circuit court denied the petition, concluding that the evidence did not constitute “scientific identification evidence” under the statute, and therefore, the State did not have a duty to preserve it. The Court of Appeals affirmed, holding that the circuit court did not err in denying appellant’s petition because the black t-shirt did not satisfy the statutory definition of “scientific identification evidence,” and therefore, the State did not have a duty to preserve it. View "Wallace v. State" on Justia Law

Posted in: Criminal Law

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These two cases concerned administrative hearings in cases where an individual suspected to have been driving (or attempting to drive) while impaired refuses to take a breath test for blood alcohol concentration. In each case, an administrative law judge (ALJ) overturned the suspension on the ground that it was not established by a preponderance of the evidence that the individual had actually been driving (or attempting to drive) at the time the individual was detained by a law enforcement officer. The Supreme Court vacated the judgment in one case and reversed the judgment in the other case, holding (1) in a test refusal case, there is no requirement that the Motor Vehicle Administration prove that the individual was actually driving (or attempting to drive) while under the influence of alcohol; rather, the relevant question is whether the officer had reasonable grounds to believe that the individual was driving (or attempting to drive) while under the influence of alcohol; (2) in one case, the ALJ found that the officer had reasonable grounds, and thus the suspension should have been upheld; and (3) in the other case, the ALJ’s finding on the issue of reasonable grounds was ambiguous, and the case is remanded for clarification. View "Motor Vehicle Administration v. Krafft" on Justia Law