Justia Civil Rights Opinion Summaries

The district court convicted Petitioner of second-degree assault and reckless endangerment. Petitioner exercised his right to have his case tried do novo in the circuit court. After a jury-waived trial, the circuit court acquitted Petitioner of reckless endangerment and convicted him of second-degree assault. Petitioner filed a petition for certiorari in the Court of Appeals, which the Court issued. The Court then affirmed Petitioner's conviction, holding (1) Petitioner's right to a de novo appeal of his district court conviction was not violated when his testimony from the district court trial was admitted into evidence in his circuit court trial; and (2) Petitioner's Fifth Amendment privilege against self-incrimination was not violated when his testimony from the district court trial was admitted into evidence in his circuit court trial. View "Oku v. State" on Justia Law

After Petitioner pled and was found not criminally responsible for the murder of two people by reason of a mental disorder, Petitioner was committed to a state-run medical facility run by the Department of Health and Mental Hygiene (DHMH), where he spent seven years as a patient. Thereafter, Petitioner applied for conditional release. An ALJ recommended that Petitioner be released subject to specified conditions. On appeal, the circuit court judge ruled that the ALJ's finding that Petitioner would not be a danger to himself or others was not supported by substantial evidence and ordered Petitioner's continued confinement. The court of special appeals affirmed. The Supreme Court reversed, holding that the lower courts erred in considering only whether Petitioner posed any risk to himself or the community without taking into account the conditions of release. Remanded. View "Hawkes v. State" on Justia Law

Following a bench trial, Petitioner was convicted of sexual abuse of a minor and attempted sexual abuse of a minor. The convictions arose from messages thirty-eight-year-old Petitioner wrote to an eight-year-old student professing his love for her. The court of special appeals affirmed the convictions. The Court of Appeals upheld Petitioner's convictions, holding (1) the lower courts did not err in holding that Petitioner did not enjoy a reasonable expectation of privacy in his work desk for purposes of a Fourth Amendment challenge to a search of the desk; (2) sexual abuse of a minor can be committed by the exchange of non-sexually explicit letters and drawings; and (3) a rational trier of fact could have found the essential elements of child sexual abuse beyond a reasonable doubt. View "Walker v. State" on Justia Law

Defendants were tried jointly and convicted of numerous crimes arising from a shooting in Baltimore that left one man dead and two other individuals wounded. The court of special appeals reversed the judgments against both men. Defendants were retried jointly before a jury and were again convicted. The court of special appeals affirmed, for the most part, the judgments of conviction of both Defendants. Defendants appealed, contending, among other things, that where an internal affairs investigator for the police found "facts sustained" against officers, the trial court erred (1) in refusing to permit the defense to inspect internal investigation division files concerning misconduct by certain law enforcement officers, and (2) at trial, in refusing to allow the defense to cross-examine the officers about the misconduct. The Supreme Court reversed with instructions to vacate the judgments of conviction and remand the case for retrial, holding that the denial of access to potentially significant impeachment evidence and the subsequent denial of an opportunity to demonstrate a reasonable actual basis for cross-examination was not harmless beyond a reasonable doubt. View "Fields v. State" on Justia Law

After a jury trial, Petitioner, who had a prior non-violent felony conviction, was convicted of wearing and carrying a handgun and two counts of possession of a regulated firearm by a person with a prior conviction. The court of special appeals vacated as duplicitous Petitioner's conviction and sentence for one count of possession of a regulated firearm by a person previously convicted. The Supreme Court (1) vacated Petitioner's sentence for possession of a regulated firearm, holding that Petitioner was wrongful subjected to an enhanced penalty under Md. Code Ann. art. 27, 449(e), which requires that a predicate prior conviction be for a crime that is both violent and felonious; and (2) held that the rule of lenity required that Petitioner be sentenced in accordance with Md. Code Ann. Crim. Law 5-622(c) rather than section 449(e) because both penalty provisions proscribe the same conduct, but section 5-622(c) mandates a lesser penalty, and the legislature did not clearly express how the two statutes were intended to interface. Remanded for resentencing. View "Alston v. State" on Justia Law

After a re-trial, a jury found Defendant guilty of first degree murder, second degree murder, and related offenses. At issue on appeal was whether pre-trial statements made by and on behalf of Defendant on the morning of the commencement of his re-trial should have been construed by the trial court as requests to discharge his counsel under Maryland Rule 4-215(e) or merely as a request for a continuance. Defendant claimed the circuit court failed to comply with Rule 4-215(e) and violated his constitutional right to counsel when Defendant was denied permission to discharge his counsel after he made several purported requests to do so. The court of special appeals reversed. The Court of Appeals reversed, holding (1) even assuming that the statements made to the trial court were sufficient collectively to engage a Rule 4-215(e) inquiry into the putative merits of Defendant's purported request to discharge his counsel, the conduct of the judges who considered Defendant's request as such complied with the requirements of Rule 4-215(e); and (2) the trial court did not violate Defendant's constitutional right to counsel of choice by denying his request for a continuance. Remanded with directions to affirm the judgment of the circuit court. View "State v. Taylor" on Justia Law

Petitioners in this case were two residents of Howard County who filed a complaint seeking a declaratory judgment that a variety of County resolutions, ordinances, zoning decisions, and administrative actions violated the Howard County Charter. Specifically, Petitioners alleged that the County, by taking certain actions by resolution or administrative decision, rather than passing an original bill as the Charter requires for all legislative acts, denied Petitioners the opportunity to petition those acts to referendum, which, consequently, violated their interests in their constitutional rights to free speech and to vote. The circuit court dismissed the complaint, concluding that Petitioners lacked standing. The court of special appeals affirmed, holding that Petitioners failed to show a concrete injury to their voting rights and thereby lacked standing. The Court of Appeals affirmed, holding that Petitioners failed to establish standing because they alleged no specific and personal injuries stemming from the County's actions. View "Kendall v. Howard County" on Justia Law

The Maryland Transit Administration (MTA) fired Plaintiff, a bus operator that suffered from a heart condition. MTA terminated Plaintiff's employment for failing to meet the standard adopted by the State establishing that an individual is not qualified to drive a commercial motor vehicle if that individual suffers from certain cardiovascular diseases. The standard had previously been adopted by the United States Department of Transportation (DOT). Plaintiff brought this action in the circuit court, alleging that the MTA violated his rights under the Americans with Disabilities Act (ADA). After a jury trial, MTA was found guilty of discrimination. The court of special appeals reversed, holding that Plaintiff's inability, because of his heart condition, to meet the DOT standards rendered him unqualified as a matter of law for an MTA bus operator position. The Supreme Court affirmed, holding (1) as a matter of law, the MTA's use of the federally-created qualification standard governing drivers suffering from cardiovascular disease satisfied the ADA's requirements of being "job-related" and of "business necessity" and that "performance cannot be accomplished by reasonable accommodation"; and (2) because Plaintiff failed to meet this properly imposed qualification standard, he was not a "qualified individual" under the ADA. View "Zei v. Md. Transit Admin." on Justia Law

The two consolidated criminal cases before the Court of Appeals here involved Jeffrey Valonis, who was convicted of robbery and related criminal charges in a bench trial, and Anthony Tyler, who was convicted of burglary and malicious destruction of property in a bench trial. At issue before the court was whether the amendment to Maryland Rule 4-245(b), which added the language "the court determines and announces on the record" and requires a trial judge to make an explicit finding of jury trial waiver on the record is subject to strict compliance and whether the failure to make such a factual determination is reversible error. The Court remanded the cases for a new trial, holding that in these two cases, the trial judges committed reversible error in failing to comply with the determine and announce requirement of Rule 4-246(b) and thereby failed to demonstrate a valid waiver of Defendants' right to a trial by jury. View "Valonis v. State" on Justia Law

Defendant was charged with third-degree sex offense and sexual solicitation of a minor. To satisfy the age element of the charge for the third-degree sex offense, the State had to prove Defendant was at least twenty-one years old at the time he had the alleged inappropriate contact with a fourteen-year-old girl. To satisfy that element, the State presented the testimony of a police officer, who interviewed Defendant and had an opportunity to examine Defendant's driver's license. Defendant objected to that testimony on hearsay grounds. The State argued that, even if the date of birth was hearsay, it was admissible as an adoptive admission of a party-opponent under Md. R. Evid. 5-803(a)(2). The trial court allowed the detective to testify, and a jury convicted Defendant on both counts. The Court of Appeals affirmed, holding that the trial court did not clearly err in finding that Defendant's conduct of providing the driver's license to the detective constituted an adoptive admission under Rule 5-803(a)(2). View "Gordon v. State" on Justia Law