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In the Matter of William Pughsley, No. 1489, Sept. Term 2023. Opinion by Beachley, J. Voting rights – disqualification under Election Law § 3-102(b)(2) – adults under guardianship for mental disability – erroneous legal standard. Maryland’s voter disqualification statute applies only when an otherwise qualified individual who “is under guardianship for mental disability and a court . . . has specifically found by clear and convincing evidence that the individual cannot communicate, with or without accommodations, a desire to participate in the voting process[.]” Md. Code (2003, 2022 Repl. Vol.), § 3-102(b)(2) of the Election Law Article (“EL”). Here, the circuit court erred in disqualifying the adult under guardianship from voting, by erroneously engrafting an additional, impermissible test requiring the prospective voter to demonstrate a “base level understanding of the political process, of why he’s voting for a particular person[.]” Voting rights – adults under guardianship for mental disability – accommodations. Compounding its error in applying the wrong legal standard for disqualification, the circuit court also improperly denied “accommodations” to assist the prospective voter in communicating his “desire to participate in the voting process[.]” See EL § 3-102(b)(2). To the extent the court misunderstood the statute to preclude such assistance, the court erred as a matter of law. To the extent the court applied the statute in refusing such assistance, the court abused its discretion in these circumstances. Supported Decision-Making Act, Estates & Trusts § 18-101 et seq. – adults under guardianship for mental disability – statutory requirements for valid agreement. The circuit court also erred by relying on the incorrect disqualification standard to deny a joint request for a supported decision-making agreement (“SDMA”) permitting guardians/parents to provide support in registering and voting, Yet the lack of any written proposal satisfying the specific statutory requirements for SDMAs hindered efforts by court and counsel to interpret and implement this new statutory tool. On remand for reconsideration of voting rights, any request for approval of an SDMA, whether limited to voting rights or extending to other matters, must comply with all statutory criteria and be approved by the court.

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In the Matter of William Pughsley

Judgment

Question Presented: Whether the circuit court erred in disqualifying William Pughsley from voting by applying an improper "base level understanding" standard—rather than the statutory standard of whether the individual can communicate, with or without accommodations, a desire to participate in the voting process—and whether the court erred in denying accommodations and the Supported Decision-Making Act petition.

Alleged Acts: William Pughsley is an adult with a mental disability who is under guardianship. His parents, Samuel and Juanita Pughsley, serve as his court-appointed guardians. The Parents sought to modify the guardianship order to allow them to assist William in voting and to be formally named as "supported decisionmakers" under Maryland's Supported Decision-Making Act (SDMA), codified at Md. Code, § 18-101 et seq. of the Estates and Trusts Article. The Parents sought to enable William to exercise his right to vote with their assistance through a supported decision-making agreement. The Circuit Court for Prince George's County held a hearing at which William testified. During the hearing, the court expressly prohibited the Parents from offering any assistance to William, including help that might have prevented errors—such as when William raised the wrong hand to take the oath, prompting correction by the judge. The circuit court disqualified William from voting, reasoning that he did not demonstrate a "base level understanding of the political process, of why he's voting for a particular person." The court also denied the Parents' SDMA petition on the same basis.

Procedural history: Petition filed in Circuit Court for Prince George's County, which was denied. William appealed to the Appellate Court of Maryland.

Summary: In the Matter of William Pughsley is a landmark Maryland appellate decision that reshaped how courts evaluate voting capacity for individuals under guardianship for mental disability. William Pughsley, an adult with a mental disability, was disqualified from voting by a trial court judge who ruled he lacked a "base level understanding" of the political process. The Appellate Court of Maryland reversed, holding that Maryland law requires only that a person be able to communicate a desire to participate in the voting process—not demonstrate an understanding of how the political system works. The court further held that the trial court erred in denying accommodations to assist William in communicating that desire, including prohibiting his parents from offering even basic assistance during his testimony. The decision vacated the disqualification order and the denial of the Supported Decision-Making Act petition, remanding for further proceedings.

Conclusion: The Appellate Court of Maryland vacated the circuit court's order and remanded for further proceedings. The circuit court erred by "engrafting an additional, impermissible test" requiring William to demonstrate a "base level understanding of the political process." The statutory standard is clear: disqualification requires a finding by clear and convincing evidence that the individual cannot communicate, with or without accommodations, a desire to participate in the voting process. The statute asks only whether the person can communicate a desire to participate—not whether the person understands how the political system works. The circuit court's "base level understanding" test was not the correct legal standard. The circuit court compounded its error by improperly denying William any "accommodations" to assist him in communicating his desire to participate in the voting process. The statute explicitly requires courts to consider whether the individual can communicate with or without accommodations. By prohibiting the Parents from offering any assistance during the hearing—even basic help like guiding William when he raised the wrong hand to take the oath—the court failed to account for the accommodations the statute mandates.

Legal Issue(s)

Accessibility
Voters' Rights

Applicable Law(s): Maryland Supported Decision-Making Act and Election Law § 3-102(b)(2)

Region: Americas

Country: United States of America

Language of Decision

English

Court: Appellate Court

Election Type: General

Geolocation

Latitude: 38.8163414001465

Longitude: -76.7514495849609

: Geolocation

Link: https://www.courts.state.md.us/data/opinions/cosa/2025/1489s23.pdf

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In the Matter of William Pughsley.pdf
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In the Matter of William Pughsley

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