Justia Constitutional Law Opinion Summaries

Plaintiff, who had a latex allergy, asked her son's school to use non-powdered latex gloves so Plaintiff could enter the building safely. The school subsequently requested Plaintiff to withdraw her son from the school. Plaintiff filed a complaint against the school, alleging that the school had discriminated against her on the basis of a handicap and that the school had unlawfully retaliated against her request for accommodations. The jury returned a verdict in favor of Plaintiff. The court of special appeals reversed. The Supreme Court issued a writ of certiorari to consider whether discrimination because of a "handicap," within the meaning of the Maryland statutory provisions, should be construed strictly to create a demanding standard for qualifying as disabled, as certain federal cases had construed the term "disability" as used in the federal Americans with Disabilities Act. The Supreme Court reversed, holding (1) the court of special appeals erred in applying this standard to reverse the jury's verdict in this case; and (2) the jury was presented with sufficient evidence to determine that Plaintiff was the victim of discrimination because of a handicap under the Maryland statutory provisions.

Petitioner Elroy Matthews invoked Md. Rule 4-345(a) to challenge the legality of the sentence he received following his plea of guilty to certain charges as part of a plea agreement. Petitioner argued that the sentence was illegal because it exceeded the sentence to which the court had bound itself. The circuit court denied the motion without a hearing. The court of special appeals held that a challenge to the legality of a sentence on the ground that it violates a binding term of a plea agreement is not cognizable under Rule 4-345(a), and even if it were, the sentence Petitioner received was not illegal. The Court of Appeals reversed, holding (1) Rule 4-345(a) is an appropriate vehicle for challenging a sentence that is imposed in violation of a plea agreement to which the sentencing court bound itself; and (2) the sentence Petitioner was serving was illegal because it exceeded the sentencing cap to which the circuit court agreed to be bound. Remanded for resentencing.

A police officer was dispatched to investigate a two-car collision, where she determined that one of the cars involved in the collision was owned by Respondent, Dana Carpenter. After a post-crash investigation, the officer requested Carpenter to submit to a chemical breath test, and Carpenter refused. Following a hearing, an administrative law judge (ALJ) suspended Carpenter's license for refusal to submit to the breath test. The circuit court reversed the suspension, determining that the police officer did not possess reasonable grounds to detain Carpenter. The Court of Appeals reversed the district court, holding that, pursuant to Md. Code Ann. Transp. 16-205.1(b)(2), the ALJ's determination that the police officer had reasonable grounds to detain Carpenter was supported by substantial evidence and was not premised upon an erroneous conclusion of law. Remanded with directions to affirm the decision of the ALJ.

After three separate trials for several criminal offenses, Appellant Benoit Tshiwala was sentenced to an aggregate of seventy years in prison. Appellant subsequently filed an application for review of his sentences, and a three-judge review panel reduced the total period of imprisonment to thirty-nine years. Thereafter, Appellant filed a motion for reconsideration of sentence, which was denied. Appellant then instituted the present action by filing a motion to correct an illegal sentence pursuant to Md. R. Crim. P. 4-345(a), alleging that the three judges who denied reconsideration were not authorized to rule on the motion. The circuit court denied Appellant's motion to correct an illegal sentence. The Supreme Court affirmed, holding that Tshiwala's claim was not cognizable under a motion to correct an illegal sentence because Tshiwala's claim did not involve an "illegal sentence" within the meaning of Rule 4-345(a).

Employee filed a complaint against Employer, claiming (1) racial and sex discrimination after Employer required her to undergo an independent medical examination for a gynecological condition, and (2) retaliatory termination of her employment. A jury held for Employee on the issues of sex discrimination and retaliatory termination. Employee was awarded damages and attorney's fees. The court of special appeals reversed, holding that Employee's claims were preempted by the Labor-Management Relations Act, and even if they were not, Employee failed to adduce sufficient evidence of her claims. The Court of Appeals reversed, holding (1) the court of special appeals' erred in determining that Employee's retaliation claim was preempted where it was independent of a collective-bargaining agreement; (2) the court of special appeals erred in its analysis of the comparator evidence in the context of Employee's claim of disparate treatment; (3) Employee presented legally sufficient evidence that she was subject to retaliatory treatment.

Petitioner Gary Smith was convicted at a jury trial of depraved heart second-degree murder and use of a handgun in the commission of a felony. The principle issue at trial was whether the decedent was murdered or committed suicide. Smith appealed, contending, inter alia, that the trial court erroneously excluded certain defense evidence relating to the decedent's state of mind. The Court of Special Appeals affirmed, concluding that the excluded evidence was too remote and not reliable. The Court of Appeals granted certiorari and reversed, holding that the trial court abused its discretion in admitting prosecution evidence of the decedent's 'normal' state of mind but refusing to admit equally relevant defense evidence of the decedent's 'depressed' state of mind. Remanded for a new trial.

Petitioner Gerald Titus was convicted by a jury of obstructing and hindering a police officer in the performance of his duty, driving under the influence of alcohol per se, driving while impaired by alcohol, and giving a false or fictitious name to a uniformed police officer. The Court of Special Appeals affirmed Petitioner's conviction and sentence. The Court of Appeals reversed Petitioner's conviction for obstructing and hindering, holding that the evidence presented by the State at trial with regard to this offense was insufficient to prove the necessary elements beyond a reasonable doubt because there was no evidence at trial to show how Petitioner's conduct actually obstructed or hindered a law enforcement officer in performing his duties.

Defendant Mario Gutierrez was charged with first-degree murder, first-degree assault, and use of a handgun in the commission of a crime of violence following the shooting death of the victim. At trial, witnesses testified that the incident was related to Defendant's affiliation with a street gang. The trial court permitted testimony of a gang expert who generally described the violent customs of the gang. The Court of Appeals affirmed, holding (1) expert testimony about the history, hierarchy, and common practices of a street gang is permissible where fact evidence establishes that the crime charged was gang-related and the probative value of the testimony is not substantially outweighed by any unfair prejudice to the defendant; and (2) the circuit court in this case did not abuse its discretion in permitting the gang expert to testify because ample fact evidence established a connection between the victim's shooting death and the street gang, and although the unfair prejudice of one of expert's statements outweighed its probative value, the error was harmless.

Petitioner was convicted by a jury of third-degree sexual assault and second-degree sexual assault. The victim was not referred for a sexual assault forensics exam. Before closing arguments, the trial judge gave a scientific evidence instruction instructing the jury that there was no legal requirement that the State utilize any specific investigative technique or scientific test to prove its case. Petitioner challenged the jury instruction on appeal. The court of special appeals affirmed. After the Court of Appeals granted certiorari in this case, it decided Atkins v. State, which stated that the most important consideration in evaluating whether a trial judge abused her discretion in giving a scientific evidence jury instruction was whether the instruction would run afoul of the prohibition against relieving the State of its burden where the the instruction's relation to the reasonable doubt standard was unclear. The Supreme Court reversed, holding (1) based on Atkins, no duty instructions are not per se improper, but (2) in the context of the present case, the trial court abused its discretion in giving such a jury instruction. Remanded for a new trial.

Respondent Jeffrey Allen was twice tried and convicted on charges related to the robbery and murder of John Butler. Respondent was retried after the Court of Appeals affirmed the holding of the court of special appeals that Respondent was entitled to a new trial on the charge of felony murder. On retrial, the jury found Respondent guilty of first degree felony murder. Respondent argued on appeal that the trial court erred when it informed the jurors about his prior murder and robbery convictions, contending that the court's instructions amounted to the use of collateral estoppel against him. The court of special appeals agreed and reversed the felony murder conviction. The Court of Appeals affirmed, concluding that when the trial court informed the jury of Respondent's prior convictions, the court necessarily informed the jury that those two elements of felony murder were established as a murder of law, and thereby withdrew from the jury any consideration of them, which impermissibly estopped litigation on ultimate facts necessary to a finding that Respondent committed the crime charged, thereby impairing the function of the jury and depriving Respondent of his constitutional right to a trial by jury. Remanded for a new trial.