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In re: K.B.
Court of Appeals of Maryland · 2026-06-23
In the CINA case In re: K.B., the Baltimore County Department of Social Services petitioned to have an infant declared a child in need of assistance after her mother was arrested for alleged physical abuse and mental health concerns, leading to the child’s out-of-home placement. At the adjudication and disposition hearing, the juvenile court declared K.B. a CINA, committed her to the Department’s custody, and noted a presumptive permanency plan of reunification, while scheduling a later permanency planning hearing; however, at the initial review hearing, the court adopted a magistrate’s recommendation to change the plan to concurrent reunification and adoption by a non-relative. The Supreme Court of Maryland held that the reunification plan arising automatically after disposition is not a permanency plan established under CJ § 3-823, so a formal permanency plan hearing complying with that statute and FL § 5-525 must occur within 11 months of out-of-home placement. The Court further ruled that all parties are entitled to advance notice of the specific date, time, and purpose of any hearing at which a permanency plan may be determined or changed, rather than general notice that the plan could be altered in the future. It therefore affirmed the Appellate Court’s reversal of the juvenile court’s order and remand for further proceedings.
family lawprocedure
Kopp v. State
Court of Appeals of Maryland · 2026-05-26
In Kopp v. State, the Supreme Court of Maryland addressed whether a police officer had reasonable suspicion to stop Xavier Kopp’s vehicle after receiving a direct cell-phone tip from a known acquaintance reporting an unfamiliar black sedan parked for an extended time in her neighborhood with cell phones in use and possible illegal activity, which the officer partially corroborated upon arrival in what he described as a high-crime area. After the stop yielded marijuana and a firearm, leading to charges and a conditional guilty plea, the Court held that the officer lacked reasonable suspicion, reversing the Appellate Court and circuit court rulings that had upheld the stop and denied suppression. The Court reasoned that the tip lacked indicia of reliability because it supplied no basis for the caller’s suspicion beyond innocent conduct, the officer’s limited observations added little, the high-crime-area testimony was insufficiently particularized as to location, specific crimes, and temporal proximity under Washington v. State, and the car’s brief forward movement did not amount to flight.
criminal lawprocedure
Robin B. Quinn, Prsnl. Rep. for Jo Ann Allen v. General Electric Co.
Court of Appeals of Maryland · 2026-04-27
The case involved a strict liability design defect claim brought by the wife of a worker who developed mesothelioma and lung cancer after exposure to asbestos dust carried home on her husband’s clothing from his job; she sued manufacturers including General Electric, alleging the products were defective when they left the seller. The District of Columbia Court of Appeals certified a question to the Supreme Court of Maryland asking whether a household member in her position, who was neither a user nor consumer, must prove an extra element of “duty” beyond the four standard elements of a strict liability action set out in Phipps v. General Motors Corp. The court answered no, holding that such a plaintiff need only show the product was defective when it left the seller’s control, was unreasonably dangerous, caused the injury, and reached the plaintiff without substantial change. It reasoned that the elements of a strict liability design defect claim are distinct from those of failure-to-warn or negligence claims, so precedents requiring proof of duty in those other contexts do not apply here.
torts & liability
Attorney Grievance Comm'n v. Hecht
Court of Appeals of Maryland · 2026-03-20
In this attorney discipline case, the Attorney Grievance Commission charged Maryland lawyer Spencer Michael Hecht with multiple violations of the Maryland Attorneys’ Rules of Professional Conduct arising from his handling of three clients’ family law and related matters. The misconduct included losing a client’s signed post-nuptial agreement and concealing the loss, misrepresenting to clients that he would file motions or obtain expert reports he never pursued, filing a false expert witness designation in court, signing an affidavit harmful to a former client, making an unauthorized credit-card charge on another client’s account, failing to refund unearned fees, and obstructing the disciplinary investigation with inconsistent statements. The Supreme Court of Maryland held that this conduct violated Rules 1.1, 1.3, 1.4, 1.5, 1.9, 1.15, 1.16, 8.1, and 8.4, and ordered Hecht’s immediate disbarment. Applying the Vanderlinde standard reaffirmed in Collins, the Court found that the intentional dishonesty, client harm, and absence of compelling extenuating circumstances required disbarment rather than a lesser sanction.
family lawprocedure
State v. Stone
Court of Appeals of Maryland · 2026-01-27
The case concerned whether a police officer had reasonable suspicion to conduct a traffic stop after observing a driver manipulating or pressing the screen of a mobile phone, which the State argued could indicate a violation of Maryland’s distracted-driving statutes (TR §§ 21-1124, 21-1124.1, and 21-1124.2). The Supreme Court of Maryland held that such observations alone do not justify a stop under the Fourth Amendment. The court reasoned that, because touching a phone screen is equally consistent with lawful activities such as using GPS navigation, initiating or ending a call, or other permitted functions, an officer must identify additional particularized facts—beyond conduct common to the general public—that reasonably indicate unlawful texting or handheld phone use. Without those specific facts, the limited observations fail to supply the objective basis required for reasonable suspicion under Terry v. Ohio and its progeny.
criminal lawprocedure
Goodrich v. State
Court of Appeals of Maryland · 2025-10-24
In Diandre Goodrich v. State of Maryland, the Supreme Court of Maryland considered whether a circuit court violated a defendant’s Sixth Amendment and Article 21 right to self-representation by failing to conduct a further inquiry after being told that Goodrich, who was represented by counsel, wished to represent himself during proceedings on a joint motion to postpone trial. The Court held that the trial court’s inquiry complied with Snead v. State and Maryland Rule 4-215(e), so it was not required to question Goodrich further or grant any relief. The Court reasoned that once a court makes a reasonable inquiry giving the defendant an opportunity to assert a clear and unequivocal desire for self-representation or to discharge counsel, and the defendant responds in a manner that does not reasonably indicate such a request (here, stating he would like an attorney), no additional obligation arises under case law or the Rule. The judgment of the Appellate Court of Maryland was affirmed.
criminal lawprocedure