March 2025 Maryland Certiorari Grants
The Supreme Court of Maryland on Friday granted review in five different appeals. The grant in the sealed In re: Criminal Investigation matter is on four different petitions. The questions differ slightly among the four petitions; we have listed the questions presented on No. 7, which is the most comprehensive.
Mayor and City Council of Baltimore v. Sanjeev Varghese – Case No. 3, September Term, 2025 (Unreported ACM Opinion by Judge Wright)
Issues – Constitutional Law – 1) Did ACM err when it held that governmental immunity for negligent infrastructure design decisions can be overcome by prior notice to the government that the design decision created a danger? 2) Did ACM’s decision that Maryland courts can adjudicate what infrastructure designs local governments should use violate the prohibition against the judicial branch assuming any of the duties of the other branches found in Article 8 of the Maryland Declaration of Rights? 3) Did ACM err when it held that Petitioner enjoyed neither common law governmental immunity nor statutory immunity under the Maryland Recreational Use Statute (§§ 5-1101 through 5-1109 of the Natural Resources Article)?
In re: Criminal Investigation No. CID 18-2673 in the Circuit Court for Baltimore City – Case Nos. 4, 5, 6, 7 September Term, 2025 (ACM Opinion Unavailable)
Issues – Criminal Procedure – 1) Does Maryland’s attorney general have the constitutional authority to publish a report based on secret grand jury information that intentionally identifies uncharged individuals for the purpose of holding them to public account? 2) Does the state constitution authorize the governor to “direct” the attorney general to investigate and prosecute any “crimes of exploitation” for an unlimited time, and without accounting for the competing authority of the state’s attorneys and the General Assembly? 3) Did this Court’s creation in 1989 of a balancing test for release of secret grand jury information overrule its earlier authority categorically prohibiting a prosecutor from releasing information about uncharged individuals to hold them to public account? 4) Did ACM err by remanding the case to the trial court to conduct an individualized analysis when the undisputed record establishes as a matter of law that there is no particularized need to disclose Petitioners’ identities?
Diandre Goodrich v. State of Maryland – Case No. 8, September Term, 2025 (Unreported ACM Opinion by Judge Ripken)
Issue – Constitutional Law – Did the trial court err in denying Petitioner’s request for self-representation in violation of his constitutional rights and Maryland Rule 4-215?
Engage Armament LLC, et al. v. Montgomery County Maryland – Case No. 9, September Term, 2025 (Unreported ACM Opinion by Chief Judge Wells)
Issues – Public Safety – 1) Did the trial court correctly find that Maryland’s comprehensive system of firearms regulation preempted portions of Chapter 57 of the Montgomery County Code (to the extent that it regulates the possession, transport, sale, and transfer of firearms)? 2) Did the trial court correctly find that Chapter 57 of the County Code is not a “local law” within the meaning of Article XI-A, § 3 of the Maryland Constitution? 3) Did the trial court correctly find that Chapter 57 of the County Code affected a taking of “major components” of firearms and privately made firearms within the meaning of the Maryland Constitution, Article III, § 40, and Article 24 of the Maryland Declaration of Rights? 4) On Montgomery County’s cross-petition, did the trial court err in invalidating and prohibiting enforcement of portions of the county code that were not referenced in the operative complaint and that Petitioners placed at issue for the first time in their motion for summary judgment?
George Bowens v. State Farm Mutual Automobile Insurance Company – Case No. 10, September Term, 2025 (Certiorari to Circuit Court for Prince George’s County)
Issue – Insurance Law – Does the “debt or damages claimed” against an underinsured motorist carrier include amounts paid by the tortfeasor’s liability carrier?
Maryland Appellate Blog 
I appreciate the insights you provided in your article regarding the certiorari grants in Maryland for March 2025. The breakdown of the case law and its implications for future litigation was particularly enlightening. One aspect that could enhance the discussion is the potential impact of these grants on public policy. For instance, decisions made during this period may set precedents that resonate beyond the specific cases at hand. A notable example is the way the Maryland Court of Appeals’ rulings on criminal justice have influenced reforms across the state, prompting legislative changes to address systemic issues. Moreover, examining how the legal landscape in Maryland compares to other jurisdictions could provide readers with a more comprehensive understanding of the implications of these certiorari grants. For example, states like California have adopted different approaches that have led to varying outcomes in similar cases, highlighting how geographical context can affect legal interpretations and public sentiment toward the justice system. Given the evolving nature of case law, I’m curious about how you foresee these certiorari grants influencing the legal strategies of attorneys in Maryland?