It is tempting to assume that unreported pro se appeals do not deserve much attention. Oftentimes, the results are not the resolution of substantive legal questions but the recognition that the pro se parties do not know what they are doing. Yet this supposition is not universally true; usually because a pro se party doesn’t spot them, there can be sneaky interesting issues hidden just below the opinion’s surface.

One such recent Appellate Court case in the administrative-law context is In the Matter of Ngozika Nwaneri, No. 1451 (October 19, 2026). Shenandoah Life Insurance Company canceled two of petitioner’s policies and he challenged that to the Maryland Insurance Commissioner, who rendered a summary decision in favor of Shenandoah. The petitioner then sought judicial review in the Circuit Court for Prince George’s County.

The Circuit Court dismissed the petition as failing to satisfy the memorandum requirements of Md. Rule 7-207(a) — that’s in the section governing petitions for judicial review of agency decisions — because its content was unsupported, lacking legal authority, and failed to properly cite the record. The petitioner then appealed to the Appellate Court.

Limiting the Scope of Appellate Review

For the Appellate Court to hear an appeal of a petition for judicial review, there must be an independent grant of jurisdiction. Here, that came from § 2-215(j)(1) of the Insurance Article of the Maryland Code (we’ll abbreviate that as “IN”), which provides, “Any party, including the Commissioner, may appeal from the judgment of the circuit court to the Appellate Court of Maryland as in other civil cases.”

On its face, that would seem enough to permit the petitioner’s appeal of the circuit court’s judgment on his petition. But the Appellate Court looked back a step to determine whether the statute authorized the circuit court’s judgment that it was being asked to review. IN § 2-215(h) reads: “The court to which an appeal is taken may: (1) affirm the decision of the Commissioner; (2) remand for further proceedings; or (3) reverse or modify the decision of the Commissioner[.]”

October 23, 2026

October 2026 Maryland Certiorari Grants

The Supreme Court of Maryland today granted review in five civil appeals.

October 16, 2026

Fourth Circuit Arguments in Appeals from the District of Maryland, October 2026

Below is a list of appeals from the United States District Court for the District of Maryland being heard during the Fourth Circuit sitting that begins October 27. When available, we include the Clerk’s synopsis of the issues.

You can visit the Court’s argument calendar for more information on the appeals, including dates for each argument, PACER links to the briefs, and links for audio livestreams. On the morning of each argument day, the Clerk will update the argument calendar to disclose the composition of the three-judge panels.

To compile this list, we’re going only by the district judge’s name, which can be overinclusive (if a Maryland-based judge was sitting by designation elsewhere within the Circuit) or underinclusive (if an outside judge was sitting by designation in the District of Maryland). Feel free to leave a comment if we’ve missed anything.

October 6, 2026

ACM warns attorneys of invisible record materials

By Steve Klepper

The Appellate Court yesterday reported an opinion warning attorneys that the appellate record may contain items invisible to them. Judge Joseph Getty, writing for the Court in Curry v. State, rejected a criminal defendant’s challenge that the circuit court clerk failed to enter the relevant jury notes into the record.

The clerk jury notes were in the record, even though counsel could not see them because of MDEC security settings:

September 25, 2026

September 2026 Maryland Certiorari Grants

The Supreme Court of Maryland yesterday granted review in six appeals. Again this term, the grant list involves an unusually high proportion of unreported Appellate Court opinions under review (five unreported, no reported).

The other grant, Hunter v. State, involves a bypass petition that the State filed as appellee. That unusual posture explains why, although the case is captioned in the Supreme Court with the criminal defendant listed first, the “question presented” is drafted in a way that suggests the State should win as appellee. In that posture, the State’s framing of the question will not bind the appellant in his brief. See Md. Rule 8-131(b)(2) (“when the Supreme Court issues a writ of certiorari to review a case pending in the Appellate Court before a decision has been rendered by that Court, the Supreme Court will consider those issues that would have been cognizable by the Appellate Court”).

September 11, 2026

Event: Appellate Term Recap

On September 29, 2026, the MSBA Section of Litigation will be hosting a panel event, Appellate Term Recap, at the Robert C. Murphy Appellate Courts Building, 361 Rowe Boulevard, Annapolis.

There will be a reception from 6:00 to 6:30 p.m., followed by a panel discussion from 6:30 to 8:00 p.m.

The registration link is here, and the list of panelists and topics is below:

September 10, 2026

Fourth Circuit Arguments in Appeals from the District of Maryland, September 2026

Below is a list of appeals from the District of Maryland being heard during the Fourth Circuit sitting that begins September 14, 2026.

September 3, 2026

Maryland Constitutional Referendum to Appear on 2026 Ballot

The Supreme Court of Maryland, by a vote of five to two, today issued a per curiam order that Maryland’s 2026 ballot will include, in slightly modified form, a referendum that exempt Congressional districts from the requirement in the Maryland Constitution that legislative districts “consist of adjoining territory, be compact in form, and of substantially equal population,” with “due regard … to natural boundaries and the boundaries of political subdivisions.”

September 2, 2026

Judge Kendra Ausby Appointed to ACM

Governor Wes Moore, for his first at-large selection to the Appellate Court of Maryland, has selected Judge Kendra Ausby of the Circuit Court for Baltimore City. In a highly competitive field, Judge Ausby was among 23 applicants and seven nominees for the vacancy created by the retirement of Judge Donald Beachley.

August 20, 2026