abuse of discretion standard in Maryland

2020As we review his exercise of discretion, we bear in mind the words of Chief Judge Wilner for this Court in North v. North, 102 Md.App. 1, 14 , 648 A.2d 1025 (1994): There is a certain commonality in all of these definitions, to the extent that they express the notion that a ruling reviewed under an abuse of discretion standard will not be reversed simply because the appellate court would not have made the same ruling.

2016Further: “ ‘[A] ruling reviewed under an abuse of discretion standard will not be reversed simply because the appellate court would not have made the same ruling.’ ” Alexis v. State, 437 Md. 457, 478 , 87 A.3d 1243 (2014) (emphasis omitted) (quoting North v. North, 102 Md.App. 1, 14 , 648 A.2d 1025 (1994)).

2023See, e.g., Devincentz, 460 Md. at 539, 550 (applying the abuse of discretion standard to the review of a trial court’s decision to admit or exclude a character witness’s opinion); Williams, 457 Md. at 562–63 (applying the abuse of discretion standard to the review of a trial court’s decision to admit relevant evidence); Jenkins, 375 Md. at 295–96 (applying the abuse of discretion standard to the review of a trial court’s decision to deny a motion for a new trial).

2023See, e.g., Devincentz, 460 Md. at 539, 550 (applying the abuse of discretion standard to the review of a trial court’s decision to admit or exclude a character witness’s opinion); Williams, 457 Md. at 562–63 (applying the abuse of discretion standard to the review of a trial court’s decision to admit relevant evidence); Jenkins, 375 Md. at 295–96 (applying the abuse of discretion standard to the review of a trial court’s decision to deny a motion for a new trial).

2023Under the abuse-of-discretion standard, we must refrain from reversing a lower court “simply because th[is] . . . [C]ourt would not have made the same ruling.” State v. Matthews, 479 Md. 278, 305 (2022) (second alteration in original) (quoting Devincentz v. State, 460 Md. 518, 550 (2018)).

2023Under the abuse-of-discretion standard, we must refrain from reversing a lower court “simply because th[is] . . . [C]ourt would not have made the same ruling.” State v. Matthews, 479 Md. 278, 305 (2022) (second alteration in original) (quoting Devincentz v. State, 460 Md. 518, 550 (2018)).

2022App. 1, 13-14 (1994). “[A] ruling reviewed under an abuse of discretion standard will not be reversed simply because the appellate court would not have made the same ruling.” Id. at 14 .

2020As we review his exercise of discretion, we bear in mind the words of Chief Judge Wilner for this Court in North v. North, 102 Md.App. 1, 14 , 648 A.2d 1025 (1994): There is a certain commonality in all of these definitions, to the extent that they express the notion that a ruling reviewed under an abuse of discretion standard will not be reversed simply because the appellate court would not have made the same ruling.

2015We, thus, review the circuit court’s denial of Johnson’s pure bill of discovery under an abuse of discretion standard. 7 We have said that “abuse may be found when the court acts without reference to any guiding rules or principles!.]” Wilson-X v. Dep’t of Human Res., 403 Md. 667, 677 , 944 A.2d 509 (2008) (quoting Touzeau v. Deffinbaugh, 394 Md. 654, 669 , 907 A.2d 807 (2006)); see also In re Adoption/Guardianship No. 3598, 347 Md. 295, 312 , 701 A.2d 110 (1997); Nace v. Miller, 201 Md.App. 54, 77 , 28 A.3d 737 (2011); Cobrand v. Adventist Healthcare, Inc., 149 Md.App. 431, 437 , 816 A.2d 117

2015We, thus, review the circuit court’s denial of Johnson’s pure bill of discovery under an abuse of discretion standard. 7 We have said that “abuse may be found when the court acts without reference to any guiding rules or principles!.]” Wilson-X v. Dep’t of Human Res., 403 Md. 667, 677 , 944 A.2d 509 (2008) (quoting Touzeau v. Deffinbaugh, 394 Md. 654, 669 , 907 A.2d 807 (2006)); see also In re Adoption/Guardianship No. 3598, 347 Md. 295, 312 , 701 A.2d 110 (1997); Nace v. Miller, 201 Md.App. 54, 77 , 28 A.3d 737 (2011); Cobrand v. Adventist Healthcare, Inc., 149 Md.App. 431, 437 , 816 A.2d 117

2012Notably, "[a] ruling reviewed under an abuse of discretion standard will not be reversed simply because the appellate court would not have made the same ruling." Gray v. State, 388 Md. 366, 383 , 879 A.2d 1064, 1073 (2005) (quoting Dehn v. Edgecombe, 384 Md. 606, 628 , 865 A.2d 603, 616 (2005)).

2012Notably, "[a] ruling reviewed under an abuse of discretion standard will not be reversed simply because the appellate court would not have made the same ruling." Gray v. State, 388 Md. 366, 383 , 879 A.2d 1064, 1073 (2005) (quoting Dehn v. Edgecombe, 384 Md. 606, 628 , 865 A.2d 603, 616 (2005)).

2025Standard of Review “We review rulings on the admissibility of evidence ordinarily on an abuse of discretion standard.” Bernadyn v. State, 390 Md. 1, 7 (2005).

2018See, e.g. , Curtis Maurice Lopez v. State , 458 Md. 164 , 180-81, 181 A.3d 810 (2018) ("Typically a trial judge's decision to admit certain evidence is reviewed for abuse of discretion." (Citation omitted) ); Bernadyn v. State , 390 Md. 1 , 7, 887 A.2d 602 , 606 (2005) ("We review rulings on the admissibility of evidence ordinarily on an abuse of discretion standard." (Citation omitted) ).

2020Pursuant to Maryland Rule 4-325(c), a trial “court may, and at the request of any party shall, instruct the jury as to the applicable law[.]” We review “a trial court’s refusal or giving of a jury instruction under the abuse of discretion standard.” Stabb v. State, 423 Md. 454, 465 (2011).

2020When applying the abuse of discretion standard in this context, we look to the following factors: “(1) whether the requested instruction was a correct statement of the law; (2) whether it was applicable under the facts of the case; and (3) whether it was fairly covered in the instructions actually given.” Id. (citations omitted) (internal quotations omitted).

2014We “review rulings on the admissibility of evidence ordinarily on an abuse of discretion standard.” Bernadyn v. State, 390 Md. 1, 7 , 887 A.2d 602 (2005) (citing Hopkins v. State, 352 Md. 146, 158 , 721 A.2d 231 (1998)).

2014We “review rulings on the admissibility of evidence ordinarily on an abuse of discretion standard.” Bernadyn v. State, 390 Md. 1, 7 , 887 A.2d 602 (2005) (citing Hopkins v. State, 352 Md. 146, 158 , 721 A.2d 231 (1998)).

2019In Wilson, we explained the abuse of discretion standard as follows: “There is an abuse of discretion ‘where no reasonable person would take the view adopted by the [trial] court[]’. . . or when the court acts ‘without reference to any guiding principles.’ An abuse of discretion may also be found where the ruling under consideration is ‘clearly against the logic and effect of facts and inferences before the court[]’. . . or when the ruling is ‘violative of fact and logic.’ Questions within the discretion of the trial court are ‘much better decided by the trial judges than by appellate courts,

2019In Wilson, we explained the abuse of discretion standard as follows: “There is an abuse of discretion ‘where no reasonable person would take the view adopted by the [trial] court[]’. . . or when the court acts ‘without reference to any guiding principles.’ An abuse of discretion may also be found where the ruling under consideration is ‘clearly against the logic and effect of facts and inferences before the court[]’. . . or when the ruling is ‘violative of fact and logic.’ Questions within the discretion of the trial court are ‘much better decided by the trial judges than by appellate courts,

2011We review the trial court’s decision under an abuse of discretion standard, and “[t]he court’s failure to fulfill this function can amount to error, that ordinarily requires reversal.” Gunning v. State, 347 Md. at 351 , 701 A.2d at 383 (internal quotation omitted); see also Cost, 417 Md. at 368-69 , 10 A.3d at 189 (“we will reverse the decision if we find that the defendant’s rights were not adequately protected”).

2011We review the trial court’s decision under an abuse of discretion standard, and “[t]he court’s failure to fulfill this function can amount to error, that ordinarily requires reversal.” Gunning v. State, 347 Md. at 351 , 701 A.2d at 383 (internal quotation omitted); see also Cost, 417 Md. at 368-69 , 10 A.3d at 189 (“we will reverse the decision if we find that the defendant’s rights were not adequately protected”).

2023See, e.g., Devincentz, 460 Md. at 539, 550 (applying the abuse of discretion standard to the review of a trial court’s decision to admit or exclude a character witness’s opinion); Williams, 457 Md. at 562–63 (applying the abuse of discretion standard to the review of a trial court’s decision to admit relevant evidence); Jenkins, 375 Md. at 295–96 (applying the abuse of discretion standard to the review of a trial court’s decision to deny a motion for a new trial).

2023See, e.g., Devincentz, 460 Md. at 539, 550 (applying the abuse of discretion standard to the review of a trial court’s decision to admit or exclude a character witness’s opinion); Williams, 457 Md. at 562–63 (applying the abuse of discretion standard to the review of a trial court’s decision to admit relevant evidence); Jenkins, 375 Md. at 295–96 (applying the abuse of discretion standard to the review of a trial court’s decision to deny a motion for a new trial).

2017See also Garg v. Garg, 393 Md. 225, 238 , 900 A.2d 739 (2006) (“The abuse of discretion standard requires a trial judge to use his or her discretion soundly and the record must reflect the exercise of that discretion.

2017See also Garg v. Garg, 393 Md. 225, 238 , 900 A.2d 739 (2006) (“The abuse of discretion standard requires a trial judge to use his or her discretion soundly and the record must reflect the exercise of that discretion.

2016We review the circuit court’s jury instructions under an abuse of discretion standard, and reverse only where the instructions do not, “taken as a whole, sufficiently protect the defendant’s rights and adequately covert ] the theory of the defense.” Thompson v. State, 393 Md. 291, 311 , 901 A.2d 208 (2006).

2016We review the circuit court’s jury instructions under an abuse of discretion standard, and reverse only where the instructions do not, “taken as a whole, sufficiently protect the defendant’s rights and adequately covert ] the theory of the defense.” Thompson v. State, 393 Md. 291, 311 , 901 A.2d 208 (2006).

2014Because we give such deference to a trial court’s decision under the abuse of discretion standard of review, it is well established that “[t]he exercise of discretion ordinarily will not be disturbed by an appellate court.” Gatewood, 388 Md. at 540-41 , 880 A.2d at *479 330 (citing Tierco Maryland, Inc. v. Williams, 381 Md. 378, 413 , 849 A.2d 504, 525 (2004)).

2014Because we give such deference to a trial court's decision under the abuse of discretion standard of review, it is well established that “[t]he exercise of discretion ordinarily will not be disturbed by an appellate court.” Gatewood, 388 Md. at 540–41, 880 A.2d at 330 (citing Tierco Maryland, Inc. v. Williams, 381 Md. 378, 413 , 849 A.2d 504, 525 (2004)).

2016Thus, "a ruling reviewed under an abuse of discretion standard will not be reversed simply because the appellate court would not have made the same ruling." Id. (internal quotation marks and citation omitted).

2016Thus, “a ruling reviewed under an abuse of discretion standard will not be reversed simply because the appellate court would not have made the same ruling.” Id. (internal quotation marks and citation omitted).

2021Accordingly, we review a trial court’s Rule 5–609 evidentiary decisions under an abuse of discretion standard, “reversing only when the court exercise[d] discretion in an arbitrary or capricious manner or . . . act[ed] beyond the letter or reason of the law.” Id. (internal quotation marks omitted) (quoting Kelly v. State, 392 Md. 511, 530-31 (2006)).

2016The Court of Appeals began its analysis of Kelly’s assertions by announcing that it would review the trial court’s “decision not to allow the witnesses to testify under the abuse of discretion standard applicable to exclusion of evidence in general.” Id. at 532 , 898 A.2d 419 .

2022In Joiner, 522 U.S. at 146 , the Supreme Court held that a trial court’s decision to admit “scientific evidence” is reviewed under an abuse of discretion standard of review, and that in a trial court’s discretion, it “may conclude that there is simply too great an analytical gap between the data and the opinion proffered[]” and refuse to admit the testimony on that basis.

2022In Joiner, 522 U.S. at 146 , the Supreme Court held that a trial court’s decision to admit “scientific evidence” is reviewed under an abuse of discretion standard of review, and that in a trial court’s discretion, it “may conclude that there is simply too great an analytical gap between the data and the opinion proffered[]” and refuse to admit the testimony on that basis.

2010This abuse of discretion standard “ ‘requires a trial judge to use his or her discretion soundly and the record must reflect the exercise of that discretion.’ ” Cooley v. State, 385 Md. 165, 175 , 867 A.2d 1065 (2005) (quoting Jenkins v. State, 375 Md. 284, 295 , 825 A.2d 1008 (2003)).

2010This abuse of discretion standard “ ‘requires a trial judge to use his or her discretion soundly and the record must reflect the exercise of that discretion.’ ” Cooley v. State, 385 Md. 165, 175 , 867 A.2d 1065 (2005) (quoting Jenkins v. State, 375 Md. 284, 295 , 825 A.2d 1008 (2003)).

2019To reverse the denial of a new trial on appeal, when utilizing the abuse of discretion standard, the reviewing court *320 must find that the "degree of probable prejudice [was] so great that it was an abuse of discretion to deny a new trial." Merritt , 367 Md. at 29 , 785 A.2d at 763 (quoting Wernsing v. General Motors Corp. , 298 Md. 406 , 420, 470 A.2d 802 , 809 (1984) ).

2019To reverse the denial of a new trial on appeal, when utilizing the abuse of discretion standard, the reviewing court *320 must find that the "degree of probable prejudice [was] so great that it was an abuse of discretion to deny a new trial." Merritt , 367 Md. at 29 , 785 A.2d at 763 (quoting Wernsing v. General Motors Corp. , 298 Md. 406 , 420, 470 A.2d 802 , 809 (1984) ).

2019This decision is ordinarily reviewed under the abuse of discretion standard, which this Court made clear in Buck v. Cam's Broadloom Rugs, Inc. , 328 Md. 51 , 57, 612 A.2d 1294 , 1297 (1992) ("[A] trial court's order denying a motion for a new trial will be reviewed on appeal if it is claimed that the trial court abused its discretion.

2019This decision is ordinarily reviewed under the abuse of discretion standard, which this Court made clear in Buck v. Cam's Broadloom Rugs, Inc. , 328 Md. 51 , 57, 612 A.2d 1294 , 1297 (1992) ("[A] trial court's order denying a motion for a new trial will be reviewed on appeal if it is claimed that the trial court abused its discretion.

2021Critically, the Court of Appeals in Wernsing v. General Motors Corp., 298 Md. 406 (1984) first recognized that discretionary rulings on motions under Maryland Rule 2- 533 are subject to reversal pursuant to an abuse of discretion standard.

2019To reverse the denial of a new trial on appeal, when utilizing the abuse of discretion standard, the reviewing court *320 must find that the "degree of probable prejudice [was] so great that it was an abuse of discretion to deny a new trial." Merritt , 367 Md. at 29 , 785 A.2d at 763 (quoting Wernsing v. General Motors Corp. , 298 Md. 406 , 420, 470 A.2d 802 , 809 (1984) ).

2020“Under the abuse of discretion standard,” however, we will “overturn a trial judge’s decision to use a particular verdict sheet if we find both that the trial judge committed legal error and that the error prejudiced the party objecting to the error.” S & S Oil, 428 Md. at 629 (citations omitted) (cleaned up).

2019"Under the abuse of discretion standard," however, "this Court will overturn a trial judge's decision to use a particular verdict sheet if we find both that the trial judge committed an error and that the error prejudiced [the appellant's] case." S & S Oil, Inc. v. Jackson , 428 Md. at 629 , 53 A.3d 1125 .