Clarke v. Gibson

Court of Appeals of Maryland·Decided November 24, 2025·No. 1/25·Published

Opinion

Philip Clarke v. Chinyere Gibson, No. 1, September Term, 2025. Opinion by Eaves, J.

APPELLATE PROCEDURE – FAILURE TO PRESERVE ISSUE FOR APPEAL

The Supreme Court of Maryland held that a respondent in a domestic violence protective order matter did not preserve for appellate review the issue of whether the circuit court erred by not stating on the record whether good cause existed to set a hearing on a final protective order for a date beyond seven days from the date the respondent was served with the temporary protective order.

PROCEDURAL DUE PROCESS – PROCESS UNDER MD. CODE ANN., FAMILY LAW §§ 4-504–4-506

The Supreme Court of Maryland held that, generally, service of a temporary protective order on a respondent will satisfy a respondent’s right to procedural due process under the United States Constitution and Article 24 of the Maryland Declaration of Rights. Thus, the Court rejected the protective order respondent’s argument that procedural due process requires that he also be served with the petition at the time he is served with the temporary protective order because the petition would afford him nothing that was not already provided by the temporary protective order, and he did not challenge that the temporary protective order did not afford adequate procedural due process.

MD. CODE ANN., FAMILY LAW § 4-506(c)(1)(ii) – SUFFICIENCY OF THE EVIDENCE – CREDIBILITY DETERMINATIONS – EFFECT ON BURDEN OF PROOF

The Supreme Court of Maryland held that the Appellate Court erred in determining whether there was sufficient evidence before the circuit court to grant a final protective order. The Appellate Court’s reliance on the circuit court’s negative credibility determination of the protective order respondent’s testimony at the final protective order hearing—alone—was not enough to satisfy the protective order petitioner’s burden to prove, by a preponderance of the evidence, that the alleged abuse occurred. Circuit Court for Anne Arundel County Case No. C-02-FM-24-807342 Argued: September 4, 2025

IN THE SUPREME COURT

OF MARYLAND

No. 1

September Term, 2025

PHILIP CLARKE

v.

CHINYERE GIBSON

Fader, C.J., Watts, Booth, Biran, Gould, Eaves, Killough,

JJ.

Opinion by Eaves, J.

Filed: November 24, 2025

Pursuant to the Maryland Uniform Electronic Legal Materials Act (§§ 10-1601 et seq. of the State Government Article) this document is authentic.

2025.11.24 13:52:59 -05'00' Gregory Hilton, Clerk I INTRODUCTION

Chinyere Gibson and Philip Clarke were married but divorced in 2017; they have

two minor children together: A.C. and O.C. 1 On February 7, 2024, Ms. Gibson filed 0F

against Mr. Clarke in the Circuit Court for Anne Arundel County a petition for protection

from child abuse on behalf of A.C. (then 11 years old) and O.C. (then 9 years old). That

same day, the circuit court conducted an ex parte hearing, determined that there were

reasonable grounds to believe that Mr. Clarke committed child abuse, and granted Ms.

Gibson a temporary protective order for the children. Because the court found that there

were reasonable grounds to believe that child abuse occurred, the court was required to

forward the case to Anne Arundel County’s Department of Social Services (“DSS”) to

conduct an investigation and complete a report for the court in time for the final

protective order hearing. 2 To give DSS time to conduct its investigation and write its 1F

report, the court scheduled the final hearing for February 23.

At the final hearing, Ms. Gibson proceeded unrepresented, and Mr. Clarke

appeared represented by counsel. At the conclusion of the hearing, the circuit court

granted Ms. Gibson a final protective order, and the Appellate Court of Maryland

1 Prior to initiating the proceedings underlying this case, the parties’ custody of the children was governed by an October 2022 order from the Circuit Court for Baltimore City. Pursuant to that order, Mr. Clarke was awarded primary physical custody of the children, and Ms. Gibson was awarded visitation with the children “every other weekend from Friday at 6:00 p.m. until Sunday at 6:00 p.m.” 2 Md. Code Ann., Fam. Law (“FL”) (2019 Repl. Vol.) § 4-505(e). affirmed that decision. 3 We issued a writ of certiorari in this case 4 to answer three 2F 3F

questions, which we have rephrased:

1. Did the circuit court err when, without articulating on the record whether good

cause existed, it scheduled the hearing for a final protective order more than seven

days after Mr. Clarke was served with the temporary protective order?

2. Did the circuit court violate Mr. Clarke’s procedural due process when it granted

Ms. Gibson a final protective order based on findings of physical abuse of a child

where the underlying petition otherwise did not allege acts of physical abuse?

3. In assessing the sufficiency of the evidence, did the Appellate Court err in

affirming the circuit court’s decision to grant the final protective order solely on

the basis that the circuit court did not find credible Mr. Clarke’s testimony?

Because Ms. Gibson did not participate in this case after the circuit court granted

her a final protective order, we appointed an amicus curiae after granting the writ to

defend the judgment of the Appellate Court. 5 4F

3 Clarke v. Gibson, No. 143, 2024 WL 4490368, at *5–8 (Md. App. Ct. Oct. 15, 2024). 4 Clarke v. Gibson, 490 Md. 81 (2025).

Ms. Gibson did not file a brief in the Appellate Court of Maryland. Nor did she 5

respond to this Court’s January 2025 letter requesting an answer to Mr. Clarke’s petition for a writ of certiorari. Even after this Court issued the writ, Ms. Gibson did not participate in briefing. Thus, this Court asked, and subsequently appointed, Christopher J. Mincher, Esq., and Todd W. Hesel, Esq., to file a brief as amicus curiae to defend the judgment of the Appellate Court. See Md. R. 8-511(a)(3). Mr. Mincher and Mr. Hesel have ably discharged that duty for which this Court is grateful. 2 As to the first question, we hold that Mr. Clarke did not preserve that issue for

appellate review, and we decline to exercise our discretion to address it. For the second

question, we hold that Mr. Clarke’s right to procedural due process was not violated and

affirm the Appellate Court’s judgment in that regard. Concerning the third question, we

hold that, in assessing the sufficiency of the evidence, the Appellate Court erred in

affirming the circuit court’s decision to grant the final protective order solely on the basis

that the circuit court did not find credible Mr. Clarke’s testimony. Thus, as to that specific

issue, we vacate the Appellate Court’s opinion and remand the matter to that court for

further action consistent with this opinion.

II BACKGROUND

A. Domestic Violence Protective Orders

A parent of a minor child may seek on the minor child’s behalf an order of

protection against the other parent for the alleged abuse of the minor child. Md. Code

Ann., Fam. Law (“FL”) (2019 Repl. Vol.) §§ 4-501(n)(6), 4-504(a)(1). In the protective

order context, abuse means, among other things, “abuse of a child, as defined in Title 5,

Subtitle 7 of this article.” Id. § 4-501(b)(2)(i). 6 5F

Petitions for protection typically follow a two-step process. If the courts are open

for business, then a petition for protection begins with the filing of the petition in either

6 That provision defines abuse of a child as, among other actions, physical or mental injury of a child by, among other people, a parent.

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