vehicle challenge (Maryland) · Go Syfert
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vehicle challenge in Maryland

19 Maryland opinions name it 3 courts 1971–2025 3 in the last five years

The cases below were cited by Maryland courts in a sentence that names this issue. Sides come from how each citing opinion treated the case (Syfertize flag on that citation), so a case can appear on both: that is where the law is contested. A red or yellow chip is the case's own overall treatment.

Followed or applied (13)

CaseFollowedCited
California v. Carneygreen
scotus · 1985 · cited in 2 Maryland opinions naming this issue, 2020–2022
2 sentences

2022But “the scope of the automobile exception extends no further than the automobile itself,” Collins, 138 S. Ct. at 1671 , and probable cause to search a vehicle does not automatically provide probable cause to search an occupant of the vehicle, State v. Wallace, 372 Md. 137, 144 (2002). 18 “Although typically described as the automobile exception to the Fourth Amendment warrant requirement, the Carroll exception also applies to searches of other vehicles.” Lewis v. State, 470 Md. 1 , 20 n.6 (2020); see also Carroll, 267 U.S. at 153 (characterizing “ship[s], motor boat[s], wagon[s], [and] automo

2020California v. Carney, 471 U.S. 386 , 393 n.2 (1985) (“With few exceptions, the courts have not hesitated to apply the vehicle exception to vehicles other than automobiles.”). 13 committing a felony or misdemeanor in the presence of the police.

22
Carroll v. United Statesgreen
scotus · 1925 · cited in 3 Maryland opinions naming this issue, 2004–2022
2 sentences

2022But “the scope of the automobile exception extends no further than the automobile itself,” Collins, 138 S. Ct. at 1671 , and probable cause to search a vehicle does not automatically provide probable cause to search an occupant of the vehicle, State v. Wallace, 372 Md. 137, 144 (2002). 18 “Although typically described as the automobile exception to the Fourth Amendment warrant requirement, the Carroll exception also applies to searches of other vehicles.” Lewis v. State, 470 Md. 1 , 20 n.6 (2020); see also Carroll, 267 U.S. at 153 (characterizing “ship[s], motor boat[s], wagon[s], [and] automo

2009Carroll v. United States, 267 U.S. 132 , 45 S.Ct. 280 , 69 L.Ed. 543 (1925) (announcing a vehicle exception to the warrant requirement). 5 .

13
State v. Wallacegreen
md · 2002 · cited in 1 Maryland opinions naming this issue, 2022–2022
1 sentence

2022But “the scope of the automobile exception extends no further than the automobile itself,” Collins, 138 S. Ct. at 1671 , and probable cause to search a vehicle does not automatically provide probable cause to search an occupant of the vehicle, State v. Wallace, 372 Md. 137, 144 (2002). 18 “Although typically described as the automobile exception to the Fourth Amendment warrant requirement, the Carroll exception also applies to searches of other vehicles.” Lewis v. State, 470 Md. 1 , 20 n.6 (2020); see also Carroll, 267 U.S. at 153 (characterizing “ship[s], motor boat[s], wagon[s], [and] automo

11
Colvin v. Stategreen
md · 2016 · cited in 1 Maryland opinions naming this issue, 2022–2022
1 sentence

2022See Colvin, 450 Md. at 728 .

11
Ray v. Mayor of Baltimoregreen
md · 2013 · cited in 1 Maryland opinions naming this issue, 2015–2015
2 sentences

2015See Maryland Rule 2-322(c); see also Ray, 430 Md. at 91 , 59 A.3d at 555 (treating a motion to dismiss as a motion for summary judgment because the trial court considered materials outside of the pleadings); Converge Services Group, LLC v. Curran, 383 Md. 462, 475 , 860 A.2d 871, 879 (2004) (noting that the “universe of ‘facts’ pertinent to the 5 It is well-established that a judicial review action is not available as a vehicle to challenge a comprehensive zoning legislative action.

2015See Maryland Rule 2-322(c); see also Ray, 430 Md. at 91 , 59 A.3d at 555 (treating a motion to dismiss as a motion for summary judgment because the trial court considered materials outside of the pleadings); Converge Services Group, LLC v. Curran, 383 Md. 462, 475 , 860 A.2d 871, 879 (2004) (noting that the “universe of ‘facts’ pertinent to the 5 It is well-established that a judicial review action is not available as a vehicle to challenge a comprehensive zoning legislative action.

11
Attorney Grievance Commission of Maryland v. Pagegreen
md · 2008 · cited in 1 Maryland opinions naming this issue, 2015–2015
2 sentences

2015See MBC Realty, LLC v. Mayor and City Council of Baltimore, 403 Md. 216 , 240–42, 941 A.2d 1052 , 1066–67 (2008); Anderson House, LLC v. Mayor and City of Rockville, 402 Md. 689, 707 , 939 A.2d 116 , 126–27 (2008); Maryland Overpak Corp. v. Mayor and City Council of Baltimore, 395 Md. 16, 50 , 909 A.2d 235, 255 (2006).

2015See MBC Realty, LLC v. Mayor and City Council of Baltimore, 403 Md. 216, 240-42 , 941 A.2d 1052, 1066-67 (2008); Anderson House, LLC v. Mayor and City of Rockville, 402 Md. 689, 707 , 939 A.2d 116, 126-27 (2008); Maryland Overpak Corp. v. Mayor and City Council of Baltimore, 395 Md. 16, 50 , 909 A.2d 235, 255 (2006).

11
Converge Services Group, LLC v. Currangreen
md · 2004 · cited in 1 Maryland opinions naming this issue, 2015–2015
2 sentences

2015See Maryland Rule 2-322(c); see also Ray, 430 Md. at 91 , 59 A.3d at 555 (treating a motion to dismiss as a motion for summary judgment because the trial court considered materials outside of the pleadings); Converge Services Group, LLC v. Curran, 383 Md. 462, 475 , 860 A.2d 871, 879 (2004) (noting that the “universe of ‘facts’ pertinent to the 5 It is well-established that a judicial review action is not available as a vehicle to challenge a comprehensive zoning legislative action.

2015See Maryland Rule 2-322(c); see also Ray, 430 Md. at 91 , 59 A.3d at 555 (treating a motion to dismiss as a motion for summary judgment because the trial court considered materials outside of the pleadings); Converge Services Group, LLC v. Curran, 383 Md. 462, 475 , 860 A.2d 871, 879 (2004) (noting that the “universe of ‘facts’ pertinent to the 5 It is well-established that a judicial review action is not available as a vehicle to challenge a comprehensive zoning legislative action.

11
Maryland Overpak Corporation v. Mayor of Baltimoregreen
md · 2006 · cited in 1 Maryland opinions naming this issue, 2015–2015
2 sentences

2015See MBC Realty, LLC v. Mayor and City Council of Baltimore, 403 Md. 216, 240-42 , 941 A.2d 1052, 1066-67 (2008); Anderson House, LLC v. Mayor and City of Rockville, 402 Md. 689, 707 , 939 A.2d 116, 126-27 (2008); Maryland Overpak Corp. v. Mayor and City Council of Baltimore, 395 Md. 16, 50 , 909 A.2d 235, 255 (2006).

2015See MBC Realty, LLC v. Mayor and City Council of Baltimore, 403 Md. 216, 240-42 , 941 A.2d 1052, 1066-67 (2008); Anderson House, LLC v. Mayor and City of Rockville, 402 Md. 689, 707 , 939 A.2d 116, 126-27 (2008); Maryland Overpak Corp. v. Mayor and City Council of Baltimore, 395 Md. 16, 50 , 909 A.2d 235, 255 (2006).

11
MBC Realty, LLC v. Mayor & City Councilgreen
md · 2008 · cited in 1 Maryland opinions naming this issue, 2015–2015
2 sentences

2015See MBC Realty, LLC v. Mayor and City Council of Baltimore, 403 Md. 216, 240-42 , 941 A.2d 1052, 1066-67 (2008); Anderson House, LLC v. Mayor and City of Rockville, 402 Md. 689, 707 , 939 A.2d 116, 126-27 (2008); Maryland Overpak Corp. v. Mayor and City Council of Baltimore, 395 Md. 16, 50 , 909 A.2d 235, 255 (2006).

2015See MBC Realty, LLC v. Mayor and City Council of Baltimore, 403 Md. 216, 240-42 , 941 A.2d 1052, 1066-67 (2008); Anderson House, LLC v. Mayor and City of Rockville, 402 Md. 689, 707 , 939 A.2d 116, 126-27 (2008); Maryland Overpak Corp. v. Mayor and City Council of Baltimore, 395 Md. 16, 50 , 909 A.2d 235, 255 (2006).

11
Ogonowski v. Stategreen
mdctspecapp · 1991 · cited in 1 Maryland opinions naming this issue, 2011–2011
2 sentences

2011Acknowledging there are no “rules governing conditions attached to such a waiver,” the Court of Special Appeals declined nonetheless “to declare that these agreements are void” and, instead, “conclude[d] that the most appropriate vehicle for analysis is that of a contract.” Ogonowski, 87 Md.App. at 183 , 589 A.2d at 518 .

2011Acknowledging there are no “rules governing conditions attached to such a waiver,” the Court of Special Appeals declined nonetheless “to declare that these agreements are void” and, instead, “conclude[d] that the most appropriate vehicle for analysis is that of a contract.” Ogonowski, 87 Md.App. at 183 , 589 A.2d at 518 .

11
Evans v. Stategreen
md · 2004 · cited in 1 Maryland opinions naming this issue, 2009–2009
2 sentences

2009Baker, 389 Md. at 134 , 883 A.2d at 920 ; Evans v. State, 382 Md. 248, 279 , 855 A.2d 291, 309 (2004).

2009Baker, 389 Md. at 134 , 883 A.2d at 920 ; Evans v. State, 382 Md. 248, 279 , 855 A.2d 291, 309 (2004).

11
BGE Home Products & Services, Inc. v. Owensgreen
md · 2003 · cited in 1 Maryland opinions naming this issue, 2007–2007
2 sentences

2007See BGE Home, 377 Md. at 248 , 833 A.2d 8 ("If we were to construct a clause excluding persons driving without permission, but not excluding permissive drivers who may exceed the scope of permission, such a clause would not help BGE’s argument in this case.”).

2007See BGE Home, 377 Md. at 248 , 833 A.2d 8 ("If we were to construct a clause excluding persons driving without permission, but not excluding permissive drivers who may exceed the scope of permission, such a clause would not help BGE’s argument in this case.”).

11
Borbon v. Motor Vehicle Administrationgreen
md · 1997 · cited in 1 Maryland opinions naming this issue, 2001–2001
2 sentences

2001See § 10-302 of the Courts Article, which provides: “In a prosecution for a violation of a law concerning a person who is driving or attempting to drive a vehicle in violation of § 16-113, § 16-813, or § 21-902 of the Transportation Article, or in violation of Article 27, § 388, § 388A, or § 388B of the Code, a test of the person’s breath or blood may be administered for the purpose of determining alcohol concentration and a test or tests of 1 specimen of the person’s blood may be administered for the purpose of determining the drug or controlled dangerous substance content of the person’s blo

2001See § 10-302 of the Courts Article, which provides: “In a prosecution for a violation of a law concerning a person who is driving or attempting to drive a vehicle in violation of § 16-113, § 16-813, or § 21-902 of the Transportation Article, or in violation of Article 27, § 388, § 388A, or § 388B of the Code, a test of the person’s breath or blood may be administered for the purpose of determining alcohol concentration and a test or tests of 1 specimen of the person’s blood may be administered for the purpose of determining the drug or controlled dangerous substance content of the person’s blo

11

Distinguished, questioned or overruled (0)

CaseNegativeCited
No negative-treatment citations attached to this issue in Maryland. Read the followed side critically anyway.

Also cited on this issue (15)

CaseCitedYears
United States v. United States Coin & Currency green
scotus · 1971
2 sentences

1973Prince George’s County v. Blue Bird, supra. But see *498 United States v. U. S. Coin and Currency, 401 U. S. 715 , 91 S. Ct. 1041 , 28 L.Ed.2d 434 (1971). * * * “. . .

1973Prince George’s County v. Blue Bird, supra. But see *498 United States v. U. S. Coin and Currency, 401 U. S. 715 , 91 S. Ct. 1041 , 28 L.Ed.2d 434 (1971). * * * “. . .

21971–1973
Lomax v. Warden green
md · 1999
1 sentence

2025The Supreme Court held that a habeas corpus proceeding was an appropriate vehicle to challenge the Governor’s action because the relief available was a parole hearing, which may have led to the inmate’s release. 11 356 Md. at 575 .

12025–2025
Collins v. Virginia green
scotus · 2018
1 sentence

2022But “the scope of the automobile exception extends no further than the automobile itself,” Collins, 138 S. Ct. at 1671 , and probable cause to search a vehicle does not automatically provide probable cause to search an occupant of the vehicle, State v. Wallace, 372 Md. 137, 144 (2002). 18 “Although typically described as the automobile exception to the Fourth Amendment warrant requirement, the Carroll exception also applies to searches of other vehicles.” Lewis v. State, 470 Md. 1 , 20 n.6 (2020); see also Carroll, 267 U.S. at 153 (characterizing “ship[s], motor boat[s], wagon[s], [and] automo

12022–2022
Lewis v. State green
md · 2020
1 sentence

2022But “the scope of the automobile exception extends no further than the automobile itself,” Collins, 138 S. Ct. at 1671 , and probable cause to search a vehicle does not automatically provide probable cause to search an occupant of the vehicle, State v. Wallace, 372 Md. 137, 144 (2002). 18 “Although typically described as the automobile exception to the Fourth Amendment warrant requirement, the Carroll exception also applies to searches of other vehicles.” Lewis v. State, 470 Md. 1 , 20 n.6 (2020); see also Carroll, 267 U.S. at 153 (characterizing “ship[s], motor boat[s], wagon[s], [and] automo

12022–2022
Maryland v. Pringle green
scotus · 2003
1 sentence

2020Pacheco, 465 Md. at 323 (citing Maryland v. Pringle, 540 U.S. 366 , 369–70 (2003)).

12020–2020
Pacheco v. State green
md · 2019
1 sentence

2020Pacheco, 465 Md. at 323 (citing Maryland v. Pringle, 540 U.S. 366 , 369–70 (2003)).

12020–2020
Anderson House, LLC v. Mayor of Rockville green
md · 2008
2 sentences

2015See MBC Realty, LLC v. Mayor and City Council of Baltimore, 403 Md. 216 , 240–42, 941 A.2d 1052 , 1066–67 (2008); Anderson House, LLC v. Mayor and City of Rockville, 402 Md. 689, 707 , 939 A.2d 116 , 126–27 (2008); Maryland Overpak Corp. v. Mayor and City Council of Baltimore, 395 Md. 16, 50 , 909 A.2d 235, 255 (2006).

2015See MBC Realty, LLC v. Mayor and City Council of Baltimore, 403 Md. 216, 240-42 , 941 A.2d 1052, 1066-67 (2008); Anderson House, LLC v. Mayor and City of Rockville, 402 Md. 689, 707 , 939 A.2d 116, 126-27 (2008); Maryland Overpak Corp. v. Mayor and City Council of Baltimore, 395 Md. 16, 50 , 909 A.2d 235, 255 (2006).

12015–2015
Harlow v. Fitzgerald green
scotus · 1982
2 sentences

2014The qualified immunity doctrine, as described by the United States Supreme Court, provides that, "government officials performing discretionary functions generally are shielded from liability for civil damages insofar as their conduct does not violate clearly established statutory or constitutional rights of which a reasonable person would have known.” *475 Harlow v. Fitzgerald, 457 U.S. 800, 818 , 102 S.Ct. 2727 , 73 L.Ed.2d 396 (1982). 19 .

2014The qualified immunity doctrine, as described by the United States Supreme Court, provides that, "government officials performing discretionary functions generally are shielded from liability for civil damages insofar as their conduct does not violate clearly established statutory or constitutional rights of which a reasonable person would have known.” *475 Harlow v. Fitzgerald, 457 U.S. 800, 818 , 102 S.Ct. 2727 , 73 L.Ed.2d 396 (1982). 19 .

12014–2014
State v. Williams green
md · 2007
2 sentences

2011State v. Williams, 401 Md. 676 , 934 A.2d 38 (2007).

2011State v. Williams, 401 Md. 676 , 934 A.2d 38 (2007).

12011–2011
Baker v. State green
md · 2005
2 sentences

2009Baker, 389 Md. at 134 , 883 A.2d at 920 ; Evans v. State, 382 Md. 248, 279 , 855 A.2d 291, 309 (2004).

2009Baker, 389 Md. at 134 , 883 A.2d at 920 ; Evans v. State, 382 Md. 248, 279 , 855 A.2d 291, 309 (2004).

12009–2009
Thomas v. State green
md · 1976
2 sentences

2008Indeed, the Thomas Court noted that “[t]he State devoted a considerable portion of its brief to argument that under the facts and circumstances here Thomas was ‘in actual physical control’ of the vehicle and thus in violation of the statute.” Thomas, 277 Md. at 316 , 353 A.2d 256 .

2008Indeed, the Thomas Court noted that “[t]he State devoted a considerable portion of its brief to argument that under the facts and circumstances here Thomas was ‘in actual physical control’ of the vehicle and thus in violation of the statute.” Thomas, 277 Md. at 316 , 353 A.2d 256 .

12008–2008
National Indemnity Co. v. Ewing green
md · 1964
2 sentences

2006We determined that “it has generally been held that, while the words import and require a showing of causal relationship, recovery is not limited by the strict rules developed in relation to direct and proximate cause.” Id. at 149 , 200 A.2d at 682 .

2006We determined that “it has generally been held that, while the words import and require a showing of causal relationship, recovery is not limited by the strict rules developed in relation to direct and proximate cause.” Id. at 149 , 200 A.2d at 682 .

12006–2006
State v. One 1967 Ford Mustang green
md · 1972
2 sentences

1994In Prince George’s County v. Blue Bird Cab Co., 263 Md. 655 , 284 A.2d 203 (1971), the Court of Appeals held that the innocence of the title owner of the vehicle was no defense, and in State v. One 1967 Ford Mustang, 266 Md. 275 , 292 A.2d 64 (1972), the Court held that within the scheme of Art. 27, § 297 the judiciary had virtually no discretion to deny forfeiture.

1994In Prince George’s County v. Blue Bird Cab Co., 263 Md. 655 , 284 A.2d 203 (1971), the Court of Appeals held that the innocence of the title owner of the vehicle was no defense, and in State v. One 1967 Ford Mustang, 266 Md. 275 , 292 A.2d 64 (1972), the Court held that within the scheme of Art. 27, § 297 the judiciary had virtually no discretion to deny forfeiture.

11994–1994
Prince George's County v. Blue Bird Cab Co. green
md · 1971
2 sentences

1994In Prince George’s County v. Blue Bird Cab Co., 263 Md. 655 , 284 A.2d 203 (1971), the Court of Appeals held that the innocence of the title owner of the vehicle was no defense, and in State v. One 1967 Ford Mustang, 266 Md. 275 , 292 A.2d 64 (1972), the Court held that within the scheme of Art. 27, § 297 the judiciary had virtually no discretion to deny forfeiture.

1994In Prince George’s County v. Blue Bird Cab Co., 263 Md. 655 , 284 A.2d 203 (1971), the Court of Appeals held that the innocence of the title owner of the vehicle was no defense, and in State v. One 1967 Ford Mustang, 266 Md. 275 , 292 A.2d 64 (1972), the Court held that within the scheme of Art. 27, § 297 the judiciary had virtually no discretion to deny forfeiture.

11994–1994
State v. Greer green
md · 1971
1 sentence

1986In reversing on three separate grounds the trial judge’s decision to release the automobile to the mother, the Court of Appeals pointed out, at 263 Md. 694 , 284 A.2d 233 , that “it is of little significance whether there is a criminal conviction” and that “[i]n the same vein the innocence of the owner of the vehicle is no defense.” In Prince George’s County v. One 1969 Opel, supra, a trial judge in Prince George’s County had declared a predecessor forfeiture law to be unconstitutional because it failed to provide adequate criteria or guidelines for the police and for the State’s Attorneys in

11986–1986

Statutes the citing opinions construe

MD § Md. Code Ann., Transp. § 21-902 (3)

Counted by distinct opinions that both name this issue and are annotated to the section; sections every opinion cites regardless of issue are not filtered here, so read the counts against the total above.

Where else courts name it

PA 170 (1947–2026) NY 141 (1962–2026) CA 117 (1963–2026) TX 104 (1973–2026) CT 100 (1987–2022) OH 91 (1947–2026) FL 67 (1954–2026) MI 45 (1894–2026) IL 34 (1975–2026) IN 27 (1980–2025) GA 27 (1979–2025) ND 22 (1984–2020) IA 22 (1986–2023) MD 19 (1971–2025) KS 19 (1984–2026) TN 15 (1978–2019) LA 14 (1927–2019) ID 12 (1991–2025) CO 12 (1989–2018) WI 12 (1970–2025) MS 11 (1988–2020) AZ 11 (1941–2025) NJ 10 (1985–2021) VA 10 (1995–2017) AL 10 (1985–2006) OR 10 (2006–2026) MA 9 (1946–2025) UT 9 (1988–2023) MO 9 (1980–2025) NV 8 (1975–2024) OK 7 (1997–2016) WA 7 (1980–2025) MT 6 (1980–2024) RI 6 (1976–2022) AR 6 (1973–2021) NC 5 (1952–2018) NM 5 (1938–2017) NE 5 (1977–2008) DE 5 (1993–2026) KY 5 (1977–2026) DC 4 (1985–2017) VT 4 (1997–2007) MN 4 (1993–2016) HI 3 (1994–2020) WY 3 (1988–2019) AK 3 (1979–1993) SC 3 (1986–2001) SD 3 (1982–1998) ME 2 (2003–2022) WV 2 (2019–2024)

Opinions by the citing court's state. A doctrine retained in one state and abandoned in another shows up here as a year span that stalls.

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