Articles Posted in Maryland Court of Appeals

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Petitioner made several public records requests under the Maryland Public Information Act (PIA) to the police department of Anne Arundel County, ultimately seeking “any and all” records related to one of the County’s police officers. Dissatisfied with the handling of his requests, Petitioner filed at least two lawsuits under the PIA against the County that resulted in numerous rulings in the circuit court. As a result of the circuit court’s rulings, Petitioner obtained several records that the County had not found in its initial searches in response to Petitioner’s request or had initially withheld as privileged. The circuit court concluded that the circuit court had committed “knowing and willful” violations of the PIA but declined to grant Petitioner the injunctive relief or damages he sought. The Court of Special Appeals affirmed. The Court of Appeals affirmed, holding that there was not clear and convincing evidence of any knowing and willful violations of the PIA, and therefore, Petitioner was not entitled to the relief he sought. View "Glass v. Anne Arundel County" on Justia Law

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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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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, Defendant was convicted of four counts of first-degree murder, among other crimes. Defendant was sentenced to four consecutive sentences of life imprisonment without the possibility of parole, one for each conviction of first-degree murder. The Court of Special Appeals affirmed the murder convictions and sentences, holding that CR 2-304 does not give a defendant the right to have a jury determine whether the defendant should be sentenced to life imprisonment with the possibility of parole or life imprisonment without the possibility of parole. The Court of Appeals affirmed, holding (1) under CR 2-304(a), where a defendant is convicted of first-degree murder and the State has given notice of an intent to seek life imprisonment without the possibility of parole, the trial court, not the jury, determines whether to sentence the defendant to life imprisonment or life imprisonment without the possibility of parole; and (2) both the United States Constitution and the Maryland Declaration of Rights permit a sentence of life imprisonment without the possibility of parole to be imposed in the same manner as every other sentence except the death penalty, which has been abolished in Maryland. View "Bellard v. State" on Justia Law

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At issue in this case was whether a law enforcement officer who detects an odor of marijuana emanating from a vehicle with multiple occupants has reasonable articulable suspicion that the vehicle’s occupants are armed and dangerous and thus may frisk the vehicle’s occupants for weapons. The circuit court denied Defendant’s motion to suppress in this case, concluding that the police officer that searched the vehicle in which Defendant was a passenger had reasonable articulable suspicion that Defendant was armed and dangerous. The Court of Special Appeals affirmed. The Court of Appeals reversed, holding (1) an odor of marijuana alone emanating from a vehicle with multiple occupants does not give rise to a reasonable articulable suspicion that the vehicle’s occupants are armed and dangerous and subject to frisk; and (2) at the time of the frisk in this case, there were insufficient circumstances giving rise to reasonable articulable suspicion that Defendant was armed and dangerous to justify the frisk. View "Norman v. State" on Justia Law

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Defendant was charged with two counts of first-degree murder and related charges. Defendant filed a motion to suppress statements he made to police during an interrogation at the police department. The circuit court granted Defendant’s motion to suppress statements Defendant made to a police officer before the officer advised Defendant of his Miranda rights. The Court of Special Appeals reversed, concluding that the suppression court had incorrectly determined that, from the outset of the interrogation, Defendant was in custody for purposes of Miranda. The Court of Appeals reversed, holding that Defendant was in custody for purposes of Miranda for the entirety of the interrogation that preceded Miranda warnings, and therefore, the circuit court properly suppressed Defendant’s statements made to the police. View "Brown v. State" on Justia Law

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After a jury trial, Petitioner was convicted of first-degree murder and sentenced to life imprisonment. The Court of Special Appeals affirmed. Petitioner appealed, inter alia, the denial of his motion to suppress the statements he made to police officers during his interrogation, arguing that they were obtained in violation of his Miranda right to counsel. The Court of Appeals affirmed, holding (1) the trial judge violated Maryland Rule 4-326(D)(2) by communicating an ex parte answer to a juror’s question without disclosing it to the defendant or any lawyer, but the error was harmless beyond a reasonable doubt; and (2) Petitioner did not invoke his Miranda right to counsel by demanding to see a lawyer from his holding cell before being interrogated, and therefore, the circuit court did not err in denying Petitioner’s motion to suppress the statements he made to detectives during his interrogation. View "Gupta v. State" on Justia Law

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Ian Schlakman and Frank Richardson (Appellees) filed suit challenging the decisions of the Baltimore City Board of Elections to certify Dan Sparaco as an eligible candidate and the State Board of Elections to include him as a candidate for the District Twelve seat on the 2016 General Election ballot. The court held that the temporary restraining order the Circuit Court granted was in error because Appellees’ state court challenges to the Boards’ actions were untimely and are barred by laches; Appellees have not explained this delay, or explained why they did not institute a parallel action in the Circuit Court within the statutorily-mandated time limits; where the federal court dismissed Appellees’ action because Appellee’s counsel was not admitted to practice before that court, the savings provision under Maryland Rule 2-101(b) did not apply to toll Appellees’ obligation to file in the appropriate circuit court, as instructed by ELEC. LAW 12-202(b)(1); and Appellees have not demonstrated any basis for relief on the merits under any theory of action or avenue for relief. The court explained that the plain language of ELEC. LAW 5-703(d)(1) does not require candidates to submit the required filings until the first Monday in August preceding the General Election. In this case, the City Board’s certification of Mr. Sparaco as a qualified candidate, and the State Board’s listing of his candidacy, complied with the provisions of the Election Law Article. Accordingly, the court vacated the temporary restraining order and remanded. View "Lamone v. Schlakman" on Justia Law

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Through Chapter 35 of the 2016 Laws of Maryland, the General Assembly amended Md. Code Ann., Educ. 3-110(b), which governs the School Board Nominating Commission of Anne Arundel County, to eliminate the ability of the Governor to appoint members to the Nominating Commission. The amendment changed the Nominating Commission to a body that is comprised of members who are appointed by various specific entities other than the Governor. Four of the five gubernatorial appointees filed suit contending that the General Assembly unconstitutionally removed them from their positions as members of the Nominating Commission. The circuit court agreed and issued a preliminary injunction against implementation and enforcement of Chapter 35, concluding that Chapter 35 violates Article II, Section 15 of the Maryland Constitution and Article 8 of the Declaration of Rights. The Court of Appeals reversed, holding that the circuit court erred in issuing the preliminary injunction because Chapter 35 is not unconstitutional but, rather, restructures or reconstitutes the Nominating Commission. View "State v. Falcon" on Justia Law