Gen. 61] 61 WIRETAP AND ELECTRONIC SURVEILLANCE August

Gen. 61] 61

WIRETAP AND ELECTRONIC SURVEILLANCE

COURTS AND JUDGES – JURISDICTION AND PROCEDURE –

CELLPHONE WARRANTS

August 30, 2016

The Honorable Matthew A. Maciarello

State’s Attorney for Wicomico County

You have asked whether a judge of the Maryland District

Court may sign search warrants or other similar court orders

involving cellphones, or whether such warrants or orders may only

be signed by a circuit court judge. The answer to your question

depends on the type of search or other request for information that

is at issue. Five different types of warrants or court orders might

involve cellphones, each governed by its own statute: (1) a wiretap

under § 10-406 of the Courts & Judicial Proceedings (“CJP”)

Article; (2) a pen register or trap and trace device under CJP § 10-

4B-04; (3) a request for stored information from a

telecommunications provider under CJP § 10-4A-04; (4) the live

tracking of a cellphone’s location under § 1-203.1 of the Criminal

Procedure (“CP”) Article; and (5) the physical search of an actual

phone under the general warrant statute in CP § 1-203. As

explained further below, a warrant or court order under the first

three statutes must be signed by a circuit court judge, but a warrant

or order under the last two statutes may be signed by either a circuit

court judge or a district court judge.

Background

For as long as we have been using wires to transmit oral

communications, people have been devising ways to intercept

those communications. Although the earliest efforts at wiretapping

appear to have been forms of corporate espionage, law enforcement

officials first began using wiretaps as a crime-fighting tool in the

1890s. See Howard J. Kaplan, et al., The History and Law of

Wiretapping, ABA Section of Litigation, 2012 Section Annual

Conference, at 2-3 (April 18-20, 2012); William Lee Adams,

“Brief History: Wiretapping,” Time (Oct. 11, 2010). The Supreme

Court did not address the constitutionality of wiretapping until

1928, when it held that a wiretap was not a search under the Fourth

Amendment. Olmstead v. United States, 277 U.S. 438, 464-65

(1928).

62 [101 Op. Att’y

Six years after Olmstead, Congress enacted the

Communications Act of 1934, which made it unlawful for any

“person” to “intercept” and “divulge or publish” the contents of any

wire or radio communication without the authorization of the

sender. Pub. L. 73-426, Title VI, § 605, 48 Stat. 1103 (June 19,

1934), codified at 47 U.S.C. § 605. Soon thereafter, the Supreme

Court held that the statute, because it applied to any “person”

without exception, prohibited the use of wiretaps by law

enforcement personnel, and rendered inadmissible in federal court

any evidence obtained as a result of a wiretap. Nardone v. United

States, 302 U.S. 379, 382-83 (1937); see also Nardone v. United

States, 308 U.S. 338, 340-41 (1939).

Despite the prohibition on wiretapping in the Commun-

ications Act, many law enforcement officers continued to conduct

wiretaps, though it remained a “somewhat stigmatized”

investigative technique. Kaplan at 3; see also, e.g., Congressional

Wiretapping Policy Overdue, 2 Stan. L. Rev. 744, 748-50 (1950)

(explaining that wiretapping was common at the time and that the

U.S. Attorney General had interpreted the Communications Act to

prohibit only the divulging of information gleaned from the

wiretap, not the wiretapping itself). Then, by the 1950s and 1960s,

public attitudes became more accepting of the practice, in part

because the government found itself “struggling to enforce laws

against organized crime, drug trafficking, and other highly

dangerous criminal activities.” Kaplan at 3. Some states thus

began experimenting with their own wiretap statutes. Maryland,

for example, enacted a law in 1956 that authorized law enforcement

personnel to conduct wiretaps only if they received the functional

equivalent of a warrant based on probable cause from a circuit court

judge. 1956 Md. Laws, ch. 116, codified at Md. Ann. Code, art. 35

§§ 100-107 (1951, 1956 Cum. Supp.); see also Manger v. State,

214 Md. 71, 75 (1957) (discussing the enactment of the Maryland

law); 53 Opinions of the Attorney General 456, 458-59 (1968).

Meanwhile, the Supreme Court revisited Olmstead and

effectively overruled its holding that a wiretap is not a search

within the meaning of the Fourth Amendment. See Berger v. New

York, 388 U.S. 41, 51 (1967); Katz v. United States, 389 U.S. 347,

353 (1967). In Berger, the Court invalidated New York’s wiretap

statute, which had authorized wiretapping pursuant to a state court

order, but identified circumstances under which such a statute

would be constitutional. Berger, 388 U.S. at 54-63. Using Berger

as a guide, Congress passed Title III of the Omnibus Crime Control

and Safe Streets Act, which, as amended, continues to govern

wiretaps today. See Pub. L. 90-351, Title III, 82 Stat. 211 (June 19,

Gen. 61] 63

1968), codified at 18 U.S.C. §§ 2510 to 2520. Although Title III

generally made it a crime to intercept any oral or wire

communications or to divulge the contents of an intercepted

communication, 18 U.S.C. § 2511 (1968), the statute for the first

time explicitly authorized law enforcement personnel to intercept

oral and wire communications in connection with investigations

into a limited number of serious crimes so long as the government

complied with certain requirements, 18 U.S.C. §§ 2516, 2517

(1968).

Specifically, Title III required that a federal prosecutor

seeking a wiretap had to obtain an order from a federal “judge of

competent jurisdiction,” 18 U.S.C. § 2516(1) (1968), which the

statute defined as a judge of a United States district court or court

of appeals, 18 U.S.C. § 2510(9)(a) (1968). State prosecutors, if

permitted by state law, similarly could obtain an order from a state

court “judge of competent jurisdiction,” 18 U.S.C. § 2516(2)

(1968), defined as “a judge of any court of general criminal

jurisdiction of a State who is authorized by a statute of that State to

enter orders authorizing interceptions of wire or oral

communications,” 18 U.S.C. § 2510(9)(b) (1968). Title III also

provided that, before a federal or state court judge could authorize

a wiretap, the law enforcement agency making the request had to

demonstrate probable cause and satisfy other procedural and

substantive requirements that were stricter than those for obtaining

a warrant. See 18 U.S.C. § 2518 (1968). In essence, Title III

established a “uniform minimum national standard governing the

interception and use of [wire or oral] communications.” Ricks v.

State, 312 Md. 11, 13 (1988). Thus, while state laws authorizing

wiretaps could be more protective of privacy, they at least had to

meet the federal standards in Title III. Id. at 14.

To conform to the new federal standards, Maryland repealed

its 1956 wiretap statute and adopted the Maryland Wiretap and

Electronic Surveillance Act (the “Maryland Wiretap Act”). See

1977 Md. Laws, ch. 692, now codified at CJP §§ 10-401 to 10-414.

The Maryland Wiretap Act “was modeled upon and closely

tracked” Title III of the federal law, “although in some particulars

[the state law] was more restrictive.” Ricks, 312 Md. at 15; see also

85 Opinions of the Attorney General 225 (2000). The Maryland

statute—like the federal law—required law enforcement personnel

to obtain an order from a “judge of competent jurisdiction,” which

it defined as “a judge of a circuit court or the Supreme Bench of

Baltimore City.” 1977 Md. Laws, ch. 692, § 3, now codified at

CJP §§ 10-401(12), 10-406(a).

64 [101 Op. Att’y

In the 1980s, the federal government and the states revisited

the issue of communication privacy in light of the increasing use of

computers and other emerging technologies. In response to these

new challenges, Congress enacted a series of reforms as part of the

Electronic Communications Privacy Act of 1986. Pub. L. 99-508,

100 Stat. 1848 (Oct. 21, 1986). First, Congress updated Title III of

the Crime Control and Safe Streets Act by prohibiting anyone from

intercepting “electronic communications” without a valid court

order that met the same heightened standards as those for the

interception of wire and oral communications. Id. (Title I).

Second, Congress added the Stored Wire and Electronic

Communications and Transactional Records Access Act. Id., 100

Stat. 1860 (Title II), codified at 18 U.S.C. §§ 2701 to 2710 (“Stored

Communications Act”). This new legislation covered two separate

types of information: (1) the contents of communications stored in

the service provider’s electronic storage system; and (2) non-

content records pertaining to subscribers. See 18 U.S.C. § 2703

(1986). The statute required service providers to disclose both

types of information to a state or federal governmental entity if the

government complied with certain requirements laid out in the

statute, though the requirements varied with the type of information

sought. Id. With respect to the contents of stored communications,

law enforcement personnel were generally required to obtain a

warrant under the Federal Rules of Criminal Procedure or an

“equivalent State warrant.” 18 U.S.C. § 2703(a) (1986). For non-

content information, however, the government could require the

service provider to disclose the information based on a subpoena

or a special court order based on less than probable cause. 18

U.S.C. § 2703(c), (d) (1986) (government must show that there is

“reason to believe” that the information is “relevant to a legitimate

law enforcement inquiry”).

Third, Congress enacted new provisions governing pen

registers and trap and trace devices.

Pub. L. 99-508, 100 Stat.

1868 (Title III), codified at 18 U.S.C. §§ 3121 to 3126. These

provisions required law enforcement personnel to obtain an order

based on less than probable cause from a “court of competent

jurisdiction,” 18 U.S.C. §§ 3122, 3123 (1986), and defined “court

of competent jurisdiction” to mean either (1) “a district court of the

United States (including a magistrate of such a court) or a United

States Court of Appeals,” or (2) “a court of general criminal

A pen register is an electronic device that records every outgoing

phone number called from a particular telephone line in real time, while

a trap and trace device records every incoming number that dials a

particular phone. See 18 U.S.C. § 3126(3), (4) (1986).

Gen. 61] 65

jurisdiction of a State authorized by the law of that State to enter

orders authorizing the use of a pen register or a trap and trace

device,” 18 U.S.C. § 3126(2) (1986). Congress gave the states two

years to amend their wiretap and pen register statutes to meet the

new federal minimum standards under Title I and Title III of the

1986 Act. Pub. L. 99-508, Title I, § 111; Title III, § 302.

In 1988, the General Assembly enacted legislation intended

largely to bring Maryland into compliance with the new federal

law. See 1988 Md. Laws, ch. 607. In a single piece of legislation,

the Legislature amended the Maryland Wiretap Act to cover

“electronic” communications, added a new subtitle governing

access to the stored communications and transactional records of

service providers, id. (codified at CJP Title 10, Subt. 3A), and

added a second new subtitle governing pen registers and trap and

trace devices, id. (codified at CJP Title 10, Subt. 3B). The new

Maryland laws were again modeled closely on federal law,

sometimes using the same language of the federal act. See id.; 75

Opinions of the Attorney General 382, 384-85 (1990). We will

discuss the requirements of these Maryland laws in more detail

below.

Finally, in more recent years, further technological

advances—particularly those involving cellphones—have raised

new questions about access to, and the privacy of, wire and

electronic communications. The Supreme Court resolved one such

question in Riley v. California, 134 S. Ct. 2473 (2014), holding that

the police must generally secure a warrant before searching the

digital data on a cellphone seized from an arrestee. Other questions

remain, however, including whether the government needs a

warrant to track a person’s location using information obtained

from his or her cellphone. See generally, e.g., R. Craig Curtis, et

al., Using Technology the Founders Never Dreamed of: Cell

Phones As Tracking Devices and the Fourth Amendment, 4 U.

Denv. Crim. L. Rev. 61 (2014). Some lower courts have drawn a

distinction between historical location information obtained after-

the-fact from a service provider and prospective information that

allows the police to track cellphone location in real time,

concluding that the latter requires a warrant but the former requires

only an order under the Stored Communications Act. See United

States v. Jones, 908 F. Supp. 2d 203, 208-09 nn. 5 & 6 (D.D.C. 2012)

(collecting cases); see also, e.g., United States v. Graham, 824 F.3d

421, 426-27 (4th Cir. 2016) (en banc) (holding that the Fourth

Amendment does not require police to obtain a warrant for

66 [101 Op. Att’y

historical cell location information but suggesting that the opposite

may be true for prospective location information).

Maryland law specifically addresses the availability of

prospective location information. In 2014, the General Assembly

enacted a statute under which a court may issue an order permitting

law enforcement personnel to obtain real time “location

information from an electronic device” if there is “probable cause

to believe” that a crime “has been, is being, or will be committed

by” the user of the device and the location information will lead to

evidence of the crime or an arrest on an active warrant. See 2014

Md. Laws, ch. 191, codified at CP § 1-203.1(b)(1). In addition, the

Court of Special Appeals recently held that tracking a cellphone’s

location in real time using a cell-site simulator is a search under the

Fourth Amendment and requires a warrant based on probable

cause. State v. Andrews, 227 Md. App. 350, 395 (2016).

With

this background in mind, we turn to your question.

Analysis

You have asked whether a judge of the Maryland District

Court may sign warrants or other similar court orders involving

cellphones. As described above, no single statute governs the

respective authority of district court and circuit court judges over

cellphone warrants. Instead, the answer to your question depends

on the type of search or request for information at issue and the

specific statutory provision under which the warrant or court order

is authorized.

A. The Maryland Wiretap Act

The first type of order authorizing a search that might involve

a cellphone is a wiretap order under the Maryland Wiretap Act. See

CJP §§ 10-401 to 10-414. Generally speaking, under the Wiretap

Act “it is unlawful for any person to . . . [w]illfully intercept,

endeavor to intercept, or procure any other person to intercept or

endeavor to intercept, any wire, oral, or electronic

Because Andrews involved the use of a cell-site simulator—a

device that forces a suspect’s cell phone to transmit signals and thus

enables the police, on their own, to track the suspect—the court did not

decide whether the government needs a warrant to obtain location

information from a service provider. 227 Md. App. at 358 n.3. The court

also did not decide whether the new type of court order provided for

under CP § 1-203.1 for the real-time tracking of cellphones would suffice

to meet the Fourth Amendment warrant requirement. Id. at 408.

Gen. 61] 67

communication.” CJP § 10-402(a)(1). However, a “judge of

competent jurisdiction” may “grant an order authorizing the

interception of wire, oral, or electronic communications by

investigative or law enforcement officers” when there is probable

cause to believe that the interception will yield evidence of one of

a series of specified crimes. CJP § 10-406(a); see also CJP § 10-

408 (outlining the probable cause requirement and other

requirements for wiretap orders). The statute specifically defines a

“judge of competent jurisdiction” as a “judge of any circuit court

within the State having jurisdiction over the offense under

investigation.” CJP § 10-401(12) (emphasis added). Thus, a

wiretap order may be issued only by a circuit court judge.

In fact, allowing a district court judge to issue such an order

would likely conflict with federal law. As explained above, the

federal counterpart to Maryland’s wiretap statute prohibits the

intercept of a telephone communication without authorization from

either a federal judge or “a State court judge of competent

jurisdiction.” 18 U.S.C. § 2516(2); see also 18 U.S.C. § 2511. The

federal statute in turn defines “judge of competent jurisdiction” to

mean “a judge of any court of general criminal jurisdiction of a

State who is authorized by a statute of that State to enter orders

authorizing interceptions of wire, oral, or electronic

communications.” 18 U.S.C. § 2510(9)(b) (emphasis added).

Because the Maryland District Court is a court of “limited

jurisdiction,” not of general jurisdiction, CJP § 1-601, the federal

statute effectively prevents Maryland from authorizing a district

court judge to grant wiretap orders.

B. Pen Registers and Trap and Trace Devices

A second type of order potentially involving cellphones is an

order under Maryland’s statute governing pen registers and trap

and trace devices. See CJP §§ 10-4B-01 to 10-4B-05. Although

State law generally makes it a crime to use a pen register, CJP

§ 10-4B-02(a), a law enforcement officer may apply to “a court of

competent jurisdiction” for an order authorizing a pen register. CJP

§ 10-4B-03(a). The court may issue such an order if it “finds that

the information likely to be obtained by the installation and use is

relevant to an ongoing criminal investigation.” CJP § 10-4B-04(a).

Under the plain terms of this statute, “court of competent

jurisdiction” means “any circuit court having jurisdiction over the

crime being investigated regardless of the location of the

instrument or process from which a wire or electronic

68 [101 Op. Att’y

communication is transmitted or received.” CJP § 10-4B-01(b)

(emphasis added). As with the Wiretap Act, this definition was

likely informed by federal law, under which a pen register or trap

and trace device may only be authorized by “a court of general

criminal jurisdiction of a State authorized by the law of that State to

enter orders authorizing the use of a pen register or a trap and

trace device.” 18 U.S.C. § 3127(2)(B). Thus, a court order issued

under subtitle 4B must be issued by a circuit court judge.

C. Stored Communications and Transactional Records

A different statute governs transactional records and historical

information stored by a service provider in that provider’s

electronic storage system. See CJP §§ 10-4A-01 to 10-4A-08. If

the stored information will reveal the content of a communication,

law enforcement officials may compel the service provider to

disclose that content “only in accordance with a search warrant

issued by a court of competent jurisdiction.” CJP § 10-4A-04(a).

Alternatively, if the information will not reveal any content, the

police do not need a search warrant based on probable cause.

Instead, a “court of competent jurisdiction” may “issue an order

requiring disclosure” of that non-content information “if the

investigative or law enforcement officer shows that there is reason

to believe the records or other information sought are relevant to a

legitimate law enforcement inquiry.” CJP § 10-4A-04(c).

Thus, as under subtitle 4B governing pen registers and trap

and trace devices, a warrant or court order seeking stored

communications under subtitle 4A must be signed by a “court of

competent jurisdiction.” Unlike subtitle 4B, however, subtitle 4A

does not explicitly define that term. Although a “judge of

competent jurisdiction” in subtitle 4A has the same meaning as

under the Maryland Wiretap Act, CJP § 10-4A-01(b)(12)

(emphasis added)—namely, “a judge of any circuit court within the

State having jurisdiction over the offense under investigation,” CJP

§ 10-401(12)—the operative provisions of subtitle 4A never

actually use the term “judge of competent jurisdiction.”

Despite this ambiguity, we conclude that a court of competent

jurisdiction under Maryland’s stored communications statute

means a circuit court. The General Assembly enacted this statute

in subtitle 4A at the same time and as part of the same piece of

legislation as the pen register statute in subtitle 4B, which expressly

defined “court of competent jurisdiction” to mean “a circuit court.”

1988 Md. Laws, ch. 607, codified at CJP § 10-4B-01(c) (1984

Repl. Vol, 1988 Supp.). When, as here, a provision is part of a

larger statutory scheme, “the legislative intention must be gathered

Gen. 61] 69

from the entire statute, rather than from only one part.” Bridges v.

Nicely, 304 Md. 1, 10 (1985). Thus, courts generally presume that

a term used in one part of a statute has the same meaning when

used elsewhere in the same statute. See, e.g., Lockett v. Blue Ocean

Bristol, 446 Md. 397, 422 (2016); Baltimore & Annap. R. Co. v.

Lichtenberg, 176 Md. 383, 391-92 (1939); Edmonds v. Cytology

Servs. of Md., Inc., 111 Md. App. 233, 251 n.19 (1996), aff’d sub

nom. Rivera v. Edmonds, 347 Md. 208 (1997); cf. Whack v. State,

338 Md. 665, 673 (1995) (noting that the presumption may be

overcome if “apparent” that the Legislature intended the words to

have different meanings). Applying that longstanding rule here,

we conclude that the General Assembly likely intended the term

“court of competent jurisdiction” in subtitle 4A to have the same

meaning as in subtitle 4B: a circuit court.

We recognize that the interpretive rule we apply here has its

limits, and that the use of different terms in different parts of a

statutory scheme usually indicates that the terms should have

different meanings, see, e.g., Toler v. Motor Vehicle Admin., 373

Md. 214, 223 (2003), but here the use of “judge” rather than “court”

in § 10-4A-01 appears to have been a historical accident. The

federal laws on which the General Assembly closely modeled its

own legislation happened to use “judge of competent jurisdiction”

in the wiretap act, 18 U.S.C. § 2516(2), and “court of competent

jurisdiction” in the pen register statute, 18 U.S.C. § 3122(a)(2), and

these two terms seem to have been carried over into the analogous

Maryland laws. There is no evidence that Congress intended those

two terms to have different meanings. To the contrary, in both

contexts Congress granted authority to issue orders only to State

courts of “general criminal jurisdiction.” 18 U.S.C. §§ 2510(9)(b),

3127(2)(b). We thus see no indication that the General Assembly

intended to ascribe different meaning to those terms by

incorporating them into the analogous Maryland laws.

Furthermore, as discussed above with respect to the Maryland

Wiretap Act and the pen register statute, allowing a district court

The pen register statute in subtitle 4B has since been amended to

define “court of competent jurisdiction” as “any circuit court having

jurisdiction over the crime being investigated regardless of the location

of the instrument or process from which a wire or electronic

communication is transmitted or received.” CJP § 10-4B-01(b). We

express no opinion on whether the new aspects of that definition should

also be read into the definition of “court of competent jurisdiction” in

subtitle 4A.

70 [101 Op. Att’y

judge to sign a warrant or order under subtitle 4A would likely

conflict with federal law. Under the analogous federal Stored

Communications Act, the government may only require a

communications provider to turn over stored communications or

records with a warrant or court order from “a court of general

criminal jurisdiction of a State.”

18 U.S.C. § 2711(3)(B)

(emphasis added); see also 18 U.S.C. § 2703. Because the

Maryland District Court is not a court of general criminal

jurisdiction, the definition of court of competent jurisdiction in

subtitle 4A should be read to exclude district court judges.

In our

view, therefore, only a circuit court judge may sign a warrant or

court order under CJP § 10-4A-04.

D. Live-Tracking of Phone Location

As noted above, in 2014, the General Assembly enacted a

statute authorizing law enforcement personnel to track a cellphone

user’s location in real time. See 2014 Md. Laws, ch. 191 (codified

at CP § 1-203.1). Under the statute, the police must obtain an order

from a “court,” CP § 1-203.1(b)(1), and “court” is defined to

include “the District Court or a circuit court having jurisdiction

over the crime being investigated.” CP § 1-203.1(a)(2) (emphasis

added). An order under this section thus may signed by a judge of

the District Court.

However, this new statute’s grant of power to the District

Court does not mean that a district court judge may now sign any

and all orders involving cellphones. The other statutes discussed

Whether a warrant or some type of lesser court order is required

depends on the type of information at issue. A warrant is usually

required for content information, but a lesser court order will suffice for

non-content records. See 18 U.S.C. § 2703(a), (b)(1)(A), (d).

As originally enacted, the federal Stored Communications Act did

not expressly require the warrant or order to be issued by a “court of

competent jurisdiction.” The statute instead required a “warrant issued

under the Federal Rules of Criminal Procedure or equivalent State

warrant” in some circumstances and, in other circumstances, a “court

order for disclosure” from an unspecified court. Pub. L. 99-508,

100 Stat. 1862, codified at 18 U.S.C. § 2703(a), (d) (1986). But

Congress later amended the statute to clarify that a state court warrant

or order had to be from “court of general criminal jurisdiction.”

Pub. L. 100-690, Title VII, § 7039, 102 Stat. 4399 (Nov. 18, 1988);

Pub. L. 111-79, 123 Stat. 2086 (Oct. 19, 2009). Given that the

General Assembly saw no need to amend its own law to bring it

into compliance with the new federal language, the Legislature

presumably thought that the authority to grant such orders in Maryland

was already limited to the circuit court.

Gen. 61] 71

above define “court” differently, and there is no requirement that

the term be defined the same way in every statute. It also makes

sense that the General Assembly would allow the District Court to

sign court orders here but withhold that authority in other contexts.

Unlike the other statutes discussed above, federal law does not

expressly limit the power to grant warrants or court orders of this

type to a court of general jurisdiction.

E. Physical Inspection of Actual Phone

Finally, if a police officer merely wants to turn on a cellphone

and physically examine its contents—perhaps after making an

arrest of a suspect who was in possession of the phone—that search

would be governed by the general warrant statute in CP § 1-203.

See Riley, 134 S. Ct. at 2495 (holding that a warrant is generally

required to search the contents of a cellphone, even as part of a

search incident to an arrest). Because such a search does not

involve a wiretap, pen register, the live tracking of a phone’s

location, or the compelled disclosure of stored information from a

service provider, none of the specialized statutes applicable to

those circumstances would apply. Under Maryland’s general

warrant statute, a search warrant may be issued by either “[a] circuit

court judge or District Court judge.” CP § 1-203(a)(1). Thus, a

judge of the District Court may legally sign a search warrant for

this type of search.

III

Conclusion

A district court judge may sign a warrant or court order for

the physical inspection of a cellphone under CP § 1-203 and for

real time cellphone location information under CP § 1-203.1. A

district court judge may not, however, sign a warrant or court

order under Title 10 of the Courts & Judicial Proceedings

Article for a wiretap, for stored electronic or wire

communications or transactional records from a service provider,

or for a pen register or trap and trace device.

Brian E. Frosh

Attorney General of Maryland

Patrick B. Hughes

Assistant Attorney General

Adam D. Snyder

Chief Counsel, Opinions & Advice