Maryland
Maryland Supreme Court: Attorney disbarment; self-representation
Criminal; self-representation
BOTTOM LINE: Where a man did not express a desire that the trial court could reasonably conclude was a request for self-representation or to discharge counsel, it did not have an obligation to question him further to determine whether the he wanted to invoke the right to self-representation.
CASE: Goodrich v. State, No. 8, Sept. Term, 2025 (filed Oct. 24, 2025) (Justices Fader, WATTS, Booth, Biran, Gould, Eaves, Killough).
FACTS: After a trial by jury at which he was represented by counsel, Mr. Goodrich was found guilty of attempted second-degree murder, armed robbery and use of a firearm in the commission of a felony or crime of violence and sentenced to imprisonment. The Appellate Court of Maryland affirmed the conviction.
Mr. Goodrich contends that he made a request to represent himself and the judge denied the request in violation of his constitutional rights and Maryland Rule 4-215. According to Mr. Goodrich, his responses to the administrative judge’s inquiry required the judge to ask additional questions of him to ascertain whether he truly wanted to represent himself, and to make a ruling under Maryland Rule 4-215(e) as to whether a request to discharge counsel was meritorious.
LAW: Under the circumstances of this case, the circuit court complied with the requirements set forth in case law concerning the constitutional right to self- representation and Maryland Rule 4-215(e).
Where a trial court has been advised by defense counsel that a defendant wants to represent himself at trial, the court is required under case law concerning the constitutional right to self-representation to conduct an inquiry to determine whether the defendant clearly and unequivocally invoked the right to self-representation and under Maryland Rule 4-215(e) to permit the defendant to explain the reasons for the request to discharge counsel.
Here, in response to a court’s reasonable inquiry, a defendant does not express a desire that the court could reasonably conclude is a request for self-representation or to discharge counsel, the court does not have an obligation under case law or Maryland Rule 4-215(e) to question the defendant further to determine whether the defendant wants to invoke the right to self-representation.
In this case, where, in response to the court’s inquiry, Mr. Goodrich advised the court that he wanted an attorney and did not reasonably apprise the court of a desire for self-representation or to discharge counsel. Neither the Supreme Court’s holding in Faretta v. California, 422 U.S. 806 (1975), nor this court’s holding in Snead v. State, 286 Md. 122 (1979) or the provisions of Maryland Rule 4-215(e) required the court to question him further. Under the circumstances of the case, the court’s inquiry was reasonable and complied with case law governing assertion of the right to self-representation and Maryland Rule 4-215(e).
Judgement of the Appellate Court of Maryland affirmed.
BOTTOM LINE: Where an attorney violated multiple Maryland Attorneys’ Rules of Professional Conduct arising out of his representation of 14 clients in the bankruptcy court, as well as conduct in connection with his own bankruptcy filings and tax matters, he was disbarred.
CASE: Attorney Grievance Commission of Maryland v. Mintz, AG No. 21, Sept. Term, 2025 (filed Oct. 24, 2025) (Justices Fader, Watts, BOOTH, Biran, Gould, Eaves, Killough).
FACTS: The Attorney Grievance Commission of Maryland, acting through bar counsel, filed a petition for disciplinary or remedial action against David B. Mintz, arising out of his representation of 14 clients in the bankruptcy court, as well as conduct in connection with his own bankruptcy filings and tax matters.
The hearing judge assigned to this matter found by clear and convincing evidence that Mr. Mintz committed all but one of the violations alleged by the Commission. The hearing judge also determined the presence of eight aggravating factors and one mitigating factor. Neither party filed exceptions. Bar counsel recommended the sanction of disbarment, which this court imposed by per curiam order on Sept. 4, 2025, following oral argument, which Mr. Mintz did not attend. The court now explains the reasons for its order.
LAW: The hearing judge concluded that there was clear and convincing evidence that Mr. Mintz had committed all but one of the violations charged by the Commission. Neither Mr. Mintz nor the Commission filed any exceptions.
Based on this court’s independent review of the record and the hearing judge’s conclusions, it agrees with the hearing judge and concludes that clear and convincing evidence demonstrates that Mr. Mintz violated Rules 1.1 (competence), 1.3 (diligence), 1.4 (a) and (b) (communication), 1.5(a) (fees), 1.16(a) (declining or terminating representation), 3.2 (expediting litigation), 3.4(c) (fairness to opposing party and attorney), 8.1(b) (bar admission and disciplinary matters) and 8.4(a), (c) and (d) (misconduct).
In accordance with Maryland Rule 19-727(e)(3), the hearing judge made findings as to aggravating and mitigating circumstances. The hearing judge found one mitigating factor present, which was that Mr. Mintz had no prior disciplinary history. The court concludes that the record supports the hearing judge’s finding of the single mitigating factor by a preponderance of the evidence.
With respect to aggravating factors, the hearing judge found by clear and convincing evidence the following: a pattern of misconduct; multiple offenses; bad faith obstruction of the disciplinary proceeding by intentionally failing to comply with rules or orders of the disciplinary agency; substantial experience in the practice of law; refusal to acknowledge the wrongful nature of the misconduct; victim’s vulnerability; indifference to making restitution or rectifying the misconduct’s consequences; and likelihood of repetition. The court agrees with the hearing judge that these aggravating factors are present.
The Commission recommended disbarment as the appropriate sanction given Mr. Mintz’s numerous violations of the Maryland Attorneys’ Rules of Professional Conduct, asserting that Mr. Mintz “completely and utterly abandoned fourteen separate clients, causing them considerable financial and emotional distress.” The Commission pointed to Mr. Mintz’s repeated failure to obey orders from the bankruptcy court, his failure to appear for hearings and complete required filings and his litigation tactics, which the Commission described as “‘gaming’ the bankruptcy system for his personal gain.”
The court agrees with the Commission that the totality of Mr. Mintz’s misconduct “demonstrates a complete indifference” to the duty owed to his clients, to the court and to the legal profession. Mr. Mintz’s neglect of clients’ cases, and his failure to communicate with his clients—all of whom were in the vulnerable and stressful process of filing for bankruptcy—and his continued failure to fully respond and participate in bar counsel’s investigation seriously undermine the integrity of the legal profession.
Mr. Mintz’s wholesale abandonment of his clients and his flagrant disregard for court orders is troubling, to say the least. Mr. Mintz’s misconduct not only harmed his clients, but also erodes basic public confidence in the legal system and the rule of law.
So ordered.
Maryland
Baltimore leaders tout law limiting ICE cooperation, cite new claims of overreach
BALTIMORE (WBFF) — As Baltimore leaders celebrated a new law limiting city cooperation with U.S. Immigration and Customs Enforcement (ICE) on Thursday, they also shared new accounts alleging federal agents have gone too far.
At a news conference the same day the mayor signed legislation restricting the city’s cooperation with ICE, City Councilman Zeke Cohen described what he said was a troubling incident outside his children’s school.
“ICE was behaving in ways that were unsafe, that caused stress, and trauma, and harm to our communities, so as a result we asked for increase school police presence,” Cohen said.
He added, “I think it’s incredibly ironic we need our own local school police to protect our kids and our families from the federal government.”
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From the floor of the council chambers last month, Councilwoman Odette Ramos described what she said was fear in the community and accused ICE of targeting people based on race.
“Let us call it what it is it’s racism and white supremacy,” Ramos said.
She added, “They wait in parking lots for anyone who is brown. They do not care if you’re a citizen or not, so I’m waiting for my turn obviously.”
Critics have questioned the stories from politicians.
Dr. Richard Vatz, a retired professor of rhetoric, called the city’s approach “utterly irresponsible leadership,” saying, “They ought to think, ‘Who am I helping, who am I hurting?’”
When FOX45 News pressed council members last month on whether they’d witnessed ICE breaking the law in Baltimore, Ramos said, “I have not personally, however, I know that we are now seeing an escalation.”
After Cohen’s account about what happened outside his children’s school, an email was sent to the council president seeking clarification, including: “Did you see the ICE activity yourself and, if so, what was taking place?”
Clarification had not yet been provided.
Sgt. Betsy Branford-Smith, with the National Police Association, said stories of fear put officers at risk too.
“These agents have now been additionally endangered. It’s already dangerous enough,” Smith said.
Maryland
Maryland students react to Canvas data breach
An online learning management system is back online after a cyberattack created chaos for local school districts and colleges in Maryland.
Canvas, an online portal used by students and teachers, and parent company Infrastructure were attacked by hacking group ShinyHunters. The group is tied to several other notable attacks, including the Live Nation hack.
In a statement to CBS News on Friday, Instructure said the company took Canvas offline after learning that hackers had “made changes to the pages that appeared when some students and teachers were logged in.”
The hackers exploited an issue linked to its Free-For-Teacher accounts, the company said.
“As a result, we have made the difficult decision to temporarily shut down our Free-For-Teacher accounts,” the company said. “This gives us the confidence to restore access to Canvas, which is now fully back online and available for use. We regret the inconvenience and concern this may have caused.”
Canvas was also removed from a dark web leak site created by the ransomware group to publish stolen data.
Several school districts in Maryland avoided using Canvas altogether on Friday, including Anne Arundel County Public Schools, Harford County Public Schools, and Howard County Public School System. Baltimore City Public Schools uses the site, but said it had minimal impacts and does not believe the district’s data was stolen.
Baltimore County Public Schools does not use Canvas, and it was not impacted.
Local colleges and universities halted to a standstill in the middle of finals because of the breach. The University of Maryland urged faculty and students not to access the site on Friday morning. By midday, Canvas was fully restored.
Student reaction
Students at Johns Hopkins University say the website was down for about four hours Thursday night. This breach occurred during the middle of finals at the university, and students say that without the site, they didn’t have access to study materials.
“I don’t think I can manage without Canvas,” Aseel Adam, a first-year student at Hopkins, said. “I had a final today, so I was like, ‘Oh no’. I had to email my teacher about the slides final practice. It was bad.”
Students called it a major inconvenience and said they had a late-night studying after Canvas came back online.
“5 pm hits, Canvas is shut down,” Alveena Nasir, a first-year student at Hopkins, said. “I am screwed. I have a final tomorrow. I have no access to any my files. I have no downloads…For that to shut down, I feel like the whole school shuts down.”
Canvas is used by students to review materials, submit assignments, and view their grades. Teachers are also able to communicate with students on the platform.
Students say they also don’t know what data may have been leaked and if it’s their personal information.
“They can get a lot of my information, fake it for someone else, or some bad, heinous crime. It did kind of worry me,” Adam explained.
Preventing future attacks
The Johns Hopkins University Information Security Institute has been testing websites and platforms like Canvas, trying to find vulnerabilities to help prevent these types of attacks. Now, AI is making it easier than ever to take down this kind of system.
“In the old days, usually [it would] take an expert maybe a month to really come up with those complicated attacks. Recently, with the help of AI, [it takes] sometimes maybe one or two days, they can really come up with those complicated attacks,” Yinzhi Cao, technical director of the institute and associate professor of computer science, tells WJZ.
Cao says everyone needs to be more cyber-aware. To protect yourself, don’t give out deeply personal information to online platforms, use two-factor authentication, and even watch out for phishing emails.
Now, students are questioning the school’s reliance on Canvas and how they can be more prepared if there’s an attack in the future.
“The idea that we depend so much on Canvas for a lot of things is also an issue. I think there should be a balance,” Adam said.
“For having a website so fundamental to our education and not being able to protect it, I think there should be some considerations on improving it,” Nasir concluded.
Maryland
How mighty megalodon rose from extinction to be Maryland state shark
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As paleontologist Stephen Godfrey walked into the Calvert Marine Museum one morning in April, staff members congratulated him. In a way, he brought an extinct species back to life.
Two days earlier, in the final hours of Maryland’s legislative session, lawmakers passed a bill that made megalodon — the largest shark that ever lived — the state shark.
Godfrey, the marine museum’s curator of paleontology, helped come up with the idea and testified at the State House in support of it. Now, Maryland is the first to have a state shark, he said.
“As long as people have been here in Maryland, they have been noticing and collecting megalodon teeth,” he said.
Fossils of the prehistoric shark can be found throughout the Chesapeake Bay region.
“It was a prime place for early paleontologists in American history to come to collect fossils, to document the succession of life,” said Godfrey, who grew up in Quebec, Canada. He has been interested in natural history since he was young and turned his childhood bedroom into a museum.
“Hey, why don’t we try to make it the state shark?” Godfrey recalled asking.
Students join in effort to honor the mighty megalodon
He checked whether any other state had beat them to the idea. He found that North Carolina designated the megalodon tooth as its state fossil — but not its state shark.
“It was like, ‘Wow, this is like a golden opportunity,’ ” he said. “I’m surprised that nobody has thought of this.”
So he reached out to Marianne Harms, a former member of the marine museum’s board who had helped get it recognized as the state’s paleontology center. She connected him with Sen. Jack Bailey, R-Calvert and St. Mary’s.
“We just started working on it last summer when I took Stephen in to meet Sen. Bailey, and it is a difficult process to have something named as a state entity,” Harms said.
Bailey introduced the bill in the Senate, and Del. Todd Morgan, R-Calvert and St. Mary’s, introduced it in the House.
Godfrey testified in support of the bill twice, bringing along his daughter, Zoey, who is in third grade.
Calvert County officials and members of the public also wrote letters of support. Representatives of the Natural History Society of Maryland and the Chesapeake Bay Foundation sent in written testimony favoring the bill.
Fourth-grade teacher Anna Shay also shared letters and pictures from her students.
“The megalodon shark is strong and brave so people will think we are also strong and brave,” one student wrote.
Megalodon encounters resistence in Maryland legislature
It faced some pushback from AMndy Ellis, a Green Party candidate for governor, who wanted to designate megalodon as the state historic shark to leave room for a living one to have that designation.
At one point, the bill stalled in the General Assembly. But on the last day of the session, it was tacked on as an amendment to a bill recognizing a state natural sciences museum and Oct. 1 as a day to honor victims and survivors of domestic violence. It passed through both chambers and is on its way to the governor’s desk.
“I can’t believe this actually happened,” said Godfrey, adding that he thought the bill had died.
“To me, it’s like, just one of the super fun things that I’ve been a part of.”
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