Justia Civil Rights Opinion Summaries

In 2000, Adnan Syed was convicted of the murder of Hae Min Lee and sentenced to life in prison plus 30 years. In 2022, the State’s Attorney for Baltimore City moved to vacate Syed’s conviction, citing new evidence and alleged Brady violations. Young Lee, the victim’s brother, was given less than one business day’s notice of the vacatur hearing, which he attended remotely. The court granted the motion to vacate and ordered the State to either retry Syed or enter a nolle prosequi (nol pros) within 30 days. The State later entered a nol pros, effectively dismissing the charges against Syed.Young Lee appealed the vacatur order, arguing that his rights as a victim’s representative were violated due to insufficient notice and the inability to attend the hearing in person. The Appellate Court of Maryland vacated the circuit court’s order, reinstated Syed’s convictions, and remanded for a new hearing, holding that the nol pros did not moot Lee’s appeal and that Lee had the right to reasonable notice and to attend the hearing in person.The Supreme Court of Maryland affirmed the Appellate Court’s decision, holding that the entry of the nol pros did not moot Lee’s appeal. The court ruled that a victim has the right to be heard at a vacatur hearing under CP § 11-403, which includes hearings where the alteration of a sentence is considered. The court also held that Lee’s rights were violated due to insufficient notice and the inability to attend the hearing in person. The case was remanded to the Circuit Court for Baltimore City for further proceedings, starting from the point immediately after the State’s Attorney filed the motion to vacate. View "Syed v. Lee" on Justia Law

The petitioner was arrested under a warrant for allegedly violating Maryland's juror intimidation statute. After a bench trial, the circuit court acquitted her based on its interpretation of the statute. Subsequently, the petitioner filed a civil suit against a sheriff’s deputy, claiming false arrest, false imprisonment, malicious prosecution, and violations of her rights under the Maryland Declaration of Rights. The deputy had filed the application for charges after consulting with the State’s Attorney’s Office, which determined that the petitioner’s conduct violated the statute.The Circuit Court for Wicomico County granted summary judgment in favor of the State, ruling that the deputy could not be held civilly liable for the petitioner’s arrest pursuant to a warrant issued by a judicial officer. The Appellate Court of Maryland affirmed this decision, concluding that the warrant provided legal justification for the arrest and that the officers’ interpretation of the statute was objectively reasonable.The Supreme Court of Maryland reviewed the case and upheld the lower courts' decisions. The Court held that the circuit court did not err in granting summary judgment in favor of the State on the common law claims of malicious prosecution, false arrest, and false imprisonment, as well as on the constitutional claims under Articles 24 and 26 of the Maryland Declaration of Rights. The Court emphasized that when an arrest is made pursuant to a warrant, probable cause is predetermined by a judicial officer, creating a strong presumption of objective reasonableness. The petitioner failed to overcome this presumption.Additionally, the Court held that the circuit court did not err in granting summary judgment on the petitioner’s claim that her arrest and imprisonment violated her free speech rights under Article 40. The Court found that the judicial officer had probable cause to believe that the petitioner’s speech constituted a “true threat” and thus fell outside the protections of Article 40. Finally, the Court upheld the circuit court’s ruling that the juror intimidation statute was not unconstitutionally vague. View "Rovin v. State" on Justia Law

This case involves a minor, Kodi Gaines, who was injured during a police standoff that resulted in the death of his mother, Korryn Gaines. The standoff occurred when Baltimore County police officers attempted to serve arrest warrants on Ms. Gaines and her boyfriend at her apartment. When officers entered the apartment, they found Ms. Gaines seated on the floor with a shotgun. A six-hour standoff ensued, during which Ms. Gaines acted erratically, sometimes negotiating with officers, at other times threatening them. Corporal Royce Ruby, a member of the SWAT team, fired a shot at Ms. Gaines when he observed her raise her shotgun into a firing position. The shot passed through Ms. Gaines, ricocheted off a refrigerator, and hit Kodi.The case was initially heard in the Circuit Court for Baltimore County, which found in favor of the defendants, Baltimore County and Corporal Ruby. The court ruled that the evidence at trial could not sustain a verdict on Kodi’s claim of violation of his right to substantive due process under the Fourteenth Amendment. The Appellate Court affirmed the lower court's decision on two grounds: that Kodi had waived his claim by not pursuing it during the first round of appellate proceedings, and that qualified immunity barred Kodi’s claim.The case was then heard by the Supreme Court of Maryland. The court disagreed with the Appellate Court’s decision on waiver but agreed that under the standard established by the United States Supreme Court, qualified immunity precludes Kodi’s claim. Therefore, the court affirmed the decision of the Appellate Court. View "Cunningham v. Baltimore County" on Justia Law

In the Matter of Antavis Chavis, the Supreme Court of Maryland ruled that a bar applicant diagnosed with Attention Deficit Hyperactivity Disorder (ADHD) had met his burden to prove that he had a "disability" under the Americans with Disabilities Act of 1990 (ADA) and that the testing accommodation he requested—50% additional time to take the Uniform Bar Examination (UBE)—was warranted. The court adopted a two-step test to determine whether a bar examination test accommodation request should be granted. First, the court must determine if the applicant meets the ADA definition of "disability." Second, the court must determine if the test accommodation requested by the applicant is "reasonable, consistent with the nature and purpose of the examination and necessitated by the applicant’s disability." The court observed that under the ADA and related federal regulations, the definition of disability should be broadly construed and that evidence of past test accommodations must be given considerable weight. The court sustained the applicant’s exceptions to the denial of his test accommodation request by the State Board of Law Examiners (SBLE), reversed the denial, and remanded the matter to the SBLE with instruction to grant the applicant’s test accommodation request. View "In the Matter of Antavis Chavis" on Justia Law

The Supreme Court reversed the judgment of the appellate court reversing the judgment of the circuit court concluding that Defendant could not show that he was prejudiced by his counsel's assistance under Strickland v. Washington, 466 U.S. 668 (1984), holding that the circuit court correctly concluded that trial counsel's performance was deficient.At issue was whether trial counsel's failure to object to an order prohibiting any consultation regarding the case between Petitioner and trial counsel during Petitioner's murder trial resulted in the actual denial of the Sixth Amendment's guarantee of assistance of counsel. The Supreme Court held (1) prejudice was presumed under the circumstances of this case; and (2) the circuit court correctly concluded that trial counsel's failure to object was objectively unreasonable. View "Clark v. State" on Justia Law

The Supreme Court upheld the judgment of the circuit court on postconviction review ordering a new trial for Petitioner, holding that Petitioner was provided ineffective assistance of counsel due to trial counsel's failure to object to the trial court's order prohibiting any consultation about the case (a no-communication order) between Petitioner and trial counsel under the circumstances of this case.At issue was a no-communication order entered into between Petitioner and trial counsel during an overnight recess prior to the final day of testimony in Petitioner's murder trial and trial counsel's failure to object to the order. The circuit court ruled that the no-communication order, and trial counsel's failure to object, deprived Petitioner of the assistance of counsel, in violation of the Sixth Amendment, and presumed prejudice, thus ordering a new trial. The appellate court reversed, concluding that Petitioner could not show prejudice. The Supreme Court reversed, holding (1) trial counsel's conduct in this case resulted in the actual denial of the assistance of counsel, and prejudice was presumed; and (2) therefore, the circuit court properly ordered a new trial for Petitioner. View "Clark v. State" on Justia Law

The Supreme Court affirmed the decision of the appellate court affirming the circuit court's grant of summary judgment in favor of Defendant in this action brought under the Maryland Health Care Worker Whistleblower Protection Act (the Act), Md. Code Ann., Health Occ. (HO) 1-501 through 1-506, holding that Plaintiff was not entitled to relief on her allegations of error.Specifically, the Supreme Court held (1) the lower court did not err by requiring Plaintiff to show that the protected conduct was the but-for cause of the challenged personnel action; (2) a plaintiff may avail herself of the burden-shifting framework established by McDonnell Douglas to prove but-for causation; (3) Plaintiff failed to genuinely dispute Defendant's evidence that she was terminated for reasons unrelated to her alleged protected disclosure; and (4) the circuit court did not err by granting judgment to Defendant as a matter of law. View "Romeka v. RadAmerica II, LLC" on Justia Law

The Supreme Court affirmed the decision of the post-conviction court denying Defendant's petition for post-conviction relief, holding that the post-conviction court did not err in ruling that trial counsel had not rendered ineffective assistance and that the State had not violated its Brady obligations during the underlying proceedings, holding that there was no error.After a jury trial, Defendant was convicted of distribution of heroin and sentenced to eight years' imprisonment. The appellate court affirmed. Defendant later filed a pro se petition for post-conviction relief, which the post-conviction court denied. On appeal, the appellate court certified questions of law to the Supreme Court. The Supreme Court answered (1) the post-conviction court did not err in ruling that trial counsel had not rendered ineffective assistance by failing to move production of certain evidence; and (2) assuming, without deciding, that the State was required to disclose challenged impeachment evidence prior to the hearing on Defendant's motion to suppress, Defendant failed to establish the Brady materiality standard. View "Blake v. State" on Justia Law