6
opinion that questions the virtues of African American women or suggests that African
American women are sexually promiscuous, lazy, and have loose personal morals as
described in the articles cited by the Majority. See Maj. Op. 28 n.15. The implication that
the Appellate Court’s opinion fuels such narratives is unwarranted.
Finally, the Majority asserts that the opinion’s use of the defined terms of “Son” and
“Mother” could be taken “as a sign of disrespect,” and again raises the possibility of racial
bias by linking the use of those terms with the Beowulf reference at the beginning of the
opinion. Maj. Op. 30. However, the use of defined terms such as “Son,” “Father,” and
“Mother” is an oft-used convention in opinions from both of Maryland’s appellate courts.
See, e.g., In re T.K.,480 Md. 122 (2022) (Fader, C.J., used “Mother” and “Father);
Westley v. State, 251 Md. App. 365 (2021) (Fader, C.J., used “Mother” and “Brother”);
Wagner v. State, 445 Md. 404 (2015) (Watts, J., used “Father”); Junek v. St. Mary’s Cnty.
Dep’t of Soc. Servs., 464 Md. 350 (2019) (Hotten, J., used “Mother” and “Father”); In re
Adoption/Guardianship of C.E., 464 Md. 26 (2019) (Getty, J., used “Mother” and
“Father”); In re X.R., 254 Md. App. 608 (2022) (Wells, C.J., used “Mother” and “Child”);
Caldwell v. Sutton, 256 Md. App. 230 (2022) (Graeff, J. used “Mother,” “Father,” “Child,”
and “Grandmother”); Meyer v. Meyer, 193 Md. App. 640 (2010) (Kehoe, J., used
“Mother,” “Father,” “Son,” and “Daughter”); J.A.B. v. J.E.D.B., 250 Md. App. 234 (2021)
(Berger, J., used “Mother” and “Father”); In re M.C., 245 Md. App. 215 (2020) (Nazarian,
J., used “Mother”); Gizzo v. Gerstman, 245 Md. App. 168 (2020) (Arthur, J., used
“Mother,” “Father,” and “Grandfather”); Basciano v. Foster, 256 Md. App. 107 (2022)
(Leahy, J., used “Mother” and “Father”); In re B.C., 234 Md. App. 698 (2017) (Reed, J.,
used “Mother”); In re R.S., 242 Md. App. 338 (2019) (Friedman, J., used “mother” and
“father”); Matter of Sulerzyski, 257 Md. App. 215 (2023) (Beachley, J., used “Mother”);
In re K.H., 253 Md. App. 134 (2021) (Ripken, J., used “Mother” and “Grandmother”); Best
v. Fraser, 252 Md. App. 427 (2021) (Wright, J., used “Mother” and “Father”); Jose v. Jose,
237 Md. App. 588 (2018) (Kenney, J., used “Mother,” “Father,” and “Daughter”); In re
K.L., 252 Md. App. 148 (2021) (Eyler, D., J., used “Mother”); Poole v. Bureau of Support
Enforcement, 238 Md. App. 281 (2018) (Battaglia, J., used “Mother” and “Father”); In re
Adoption/Guardianship of H.W., 460 Md. 201 (2018) (Adkins, J., used “Mother,” “Father,”
“Sister,” and “Brother”); Goicochea v. Goicochea, 256 Md. App. 329 (2022) (Moylan, J.,