The District Court of Maryland has a history of elevating magistrates to lifetime appointments, with Judges Stephanie Gallagher and Deborah Boardman elevated in the last few years. Two more have now been nominated, including Judge Matthew Maddox.

Background

Matthew James Maddox received a B.A. summa cum laude from Morgan State University in 1999, and subsequently was selected as a Fulbright Scholar, while also spending some time in the Teach for America program. Maddox subsequently obtained a J.D. from Yale Law School in 2011.

After graduation, Maddox clerked for Judge Gerald Bruce Lee on the U.S. District Court for the Eastern District of Virginia and then for Judge Andre Davis on the U.S. Court of Appeals for the Fourth Circuit. Maddox subsequently spent two years at Hollard & Knight LLP before becoming a federal prosecutor for the U.S. Attorney’s Office for the District of Maryland.

In 2022, Maddox was appointed to be a U.S. Magistrate Judge for the District of Maryland to replace Judge Thomas DiGirolamo, where he currently serves.

History of the Seat

Maddox has been nominated for a seat on the U.S. District Court for the District of Maryland to replace Judge Paul Grimm, who took senior status on December 11, 2022.

Legal Career

Maddox began his legal career as a law clerk on the Eastern District of Virginia and then on the Fourth Circuit. After his clerkships,she worked as an associate at Holland & Knight. During his tenure there, Maddox represented the video distribution service Sky Angel in a breach of contract action against Discovery Communications LLC. See Sky Angel U.S., LLC v. Discovery Communications, LLC. et al., 28 F. Supp. 3d 465 (D. Md. 2014).

From 2015 to 2022, Maddox worked as a federal prosecutor in Maryland. In his role, Maddox represented the United States in federal prosecutions before both the district and appellate courts. For example, Maddox argued before the Fourth Circuit where the Defendant challenged the seizure of his MacBook Pro, iPhone, and iPod at an airport, and the subsequent warrantless search of the devices. See United States v. Aigbekaen, 943 F.3d 713 (4th Cir. 2019). The Fourth Circuit found, contrary to Maddox’s arguments, that the searches were not justified under the “border search” exception to the Fourth Amendment’s warrant requirement. See id. at 723. However, the Court nonetheless ruled in the government’s favor under the “good faith” exception. See id. at 725. Judge Jay Richardson concurred, finding that he would have found the search justified under the “border search” exception. See id. at 726 (Richardson, J., concurring).

Jurisprudence

Maddox has served as a U.S. Magistrate judge in Maryland since his appointment in 2022. In this role, he handles settlement, discovery, and makes recommendations on dispositive motions, while presiding over cases where the parties consent.

Maddox’s short tenure as a magistrate has left him with few substantive decisions under his belt. In the context of reviewing administrative denials of social security benefits, Maddox affirmed an ALJ decision that a plaintiff’s seizure disorder was not of a seriousness that prevented him from working and caused him to be disabled. See James L. v. Comm’r, Civil No. MJM-21-1718 (D. Md. Sept. 30, 2022). Maddox also granted summary judgment to Walmart in a slip-and-fall case, noting that it was not disputed between the parties that the store lacked actual or constructive knowledge of the hazard that caused the plaintiff’s injury. See McLaughlin v. Walmart, Inc., Civil Action MJM-21-1305 (D. Md. Mar. 20, 2023).

Maddox also presided over a bench trial in a case alleging damages after an EKG technician allegedly walked in on a female patient’s medical examination without permission. See Neal v. United States, Civil Action No. MJM 19-1033 (D. Md. Jan. 23, 2023). Maddox found in favor of the plaintiff on claims of professional negligence and negligent supervision, awarding $5000 in compensatory damages. See id. (Memorandum of Decision). Maddox found in favor of the defendants on the other claims. See id.

Overall Assessment

Compared to fellow nominee Hurson, Maddox should have the easier path to confirmation. There is little in his background that should cause controversy, although, as other experienced nominees have learned, the Judiciary Committee hearing can snag even those otherwise poised for confirmation.

The District Court of Maryland has a history of elevating magistrates to lifetime appointments, with Judges Stephanie Gallagher and Deborah Boardman elevated in the last few years. Two more have now been nominated, including Judge Brendan Hurson.

Background

Hurson received a B.A. cum laude from Providence College in 2000, and subsequently obtained a J.D. from the University of Maryland School of Law in 2005.

After graduation, Hurson clerked for Judge Margaret Seymour on the U.S. District Court for the District of South Carolina. After a year at the firm of Schulman, Hershfield & Gilden, P.A. in Baltimore, Hurson became a federal public defender in Maryland, where he stayed until 2022, except for a year as a public defender in the Virgin Islands.

In 2022, Hurson was appointed to be a U.S. Magistrate Judge for the District of Maryland to replace Boardman, who was elevated to a lifetime appointment. Hurson currently serves in that capacity.

History of the Seat

Hurson has been nominated for a seat on the U.S. District Court for the District of Maryland to replace Judge George Hazel, who resigned from the bench on February 24, 2023.

Legal Career

Setting aside a short stint in private practice, Hurson has spent his pre-bench legal career as a federal public defender, representing indigent defendants in federal court. Among the defendants Hurson represented was Master Giddins, who was charged with bank robbery and conspiracy. See United States v. Giddins, 57 F. Supp. 3d 481 (D. Md. 2014). While in the Virgin Islands, Hurson was also able to represent Dequan Forde, who was charged with smuggling marijuana into the Virgin Islands. See United States v. Forde, Criminal Action No. 2018-0004 (D.V.I. Jan. 8, 2019). Hurson also had the opportunity to argue cases before the federal courts of appeal. See, e.g., United States v. James, No. 17-2536 (3d Cir. Apr. 23, 2018).

Jurisprudence

Hurson has served as a U.S. Magistrate judge in Maryland since his appointment in 2022. In this role, he handles settlement, discovery, and makes recommendations on dispositive motions as well as presiding over cases where the parties consent.

Given his short tenure as a magistrate, Hurson has not had an opportunity to create a firm jurisprudential record. A significant number of the cases that Hurson has handled consist of appeals of denials of social security benefits and discovery disputes. See, e.g., XL Specialty Insurance Co. v. Bighorn Construction & Reclamation LLC et al., Civil No. 21-3068-BAH (D. Md. Mar. 14, 2023) (Order Granting Plaintiff’s Motion to Compel DIscovery). In one exception, Hurson denied to dismiss a 1983 action and related claims against the Prince George’s Police Department and the owner of Largo Liquors as a sanction for failing to comply with the court’s orders, finding the grant of partial summary judgment on some claims and a remand of the remaining claims to state court to be a sufficient sanction. See Davis v. Kim, Civil No. 19-3605-BAH (D. Md. Sept. 16, 2022).

Overall Assessment

His two predecessors on the magistrate judge, Gallagher and Boardman, both had tortured paths to lifetime appointments but were ultimately able to be confirmed. While Hurson will likely face opposition for his experience in indigent defense, he is nonetheless favored to join the bench before the August recess.