Justia Civil Procedure Opinion Summaries

In 2025, the Frederick County Council enacted legislation establishing a Critical Digital Infrastructure (CDI) Overlay Zone, enabling data centers and related infrastructure to be built on a limited portion of county land. The boundaries and zoning designations of the Overlay Zone were later set by Ordinance 26-01-001 (the CDI Ordinance), which included color maps as exhibits to indicate the precise locations and zoning designations. A group of residents, the Frederick County Data Center Referendum Committee, sought to challenge this ordinance by referendum and gathered sufficient signatures for a petition. However, the petition included only black-and-white reproductions of the ordinance’s maps, which did not clearly show the Overlay Zone boundaries or zoning distinctions.The sufficiency of the petition was initially upheld by the Director of the Frederick County Board of Elections, who found it met requirements as to form, though she did not decide whether the ordinance was a proper subject for referendum. Several parties opposed the referendum, arguing in the Circuit Court for Frederick County that the ordinance was not subject to referendum under the County Charter and that the petition was deficient because it did not include a full and accurate reproduction of the ordinance. The circuit court agreed, finding both that the CDI Ordinance was not a “law” subject to referendum under the Charter and that the petition’s reproduction of the ordinance was insufficient due to the lack of accurate color maps.On direct appeal, the Supreme Court of Maryland affirmed the circuit court’s judgment. The Court held that under the Frederick County Charter, zoning ordinances, such as the CDI Ordinance, are not subject to referendum because the Charter intended to maintain pre-Charter limitations on referenda for such ordinances. Additionally, the Court held that the petition was insufficient because it did not contain a full and accurate reproduction of the ordinance, as the black-and-white maps omitted essential information. View "In re: Frederick Cnty. Data Center Referendum" on Justia Law

After a homeowners association obtained a money judgment against a homeowner for unpaid assessments, it levied the homeowner’s interest in her property and proceeded with a sheriff’s sale. The homeowner did not satisfy the judgment or obtain release of the levy before the sale occurred. A third-party bidder purchased the homeowner’s interest in the property at auction. After the sale but before the court ratified it, the homeowner paid the judgment in full to the association. The association then notified the court of the satisfaction and requested that the sale be vacated, arguing the judgment had been satisfied prior to ratification.The District Court of Maryland, sitting in Prince George’s County, agreed with the association, concluding that the sale could be vacated since the homeowner satisfied the judgment before ratification. On appeal, the Circuit Court for Prince George’s County affirmed, holding a hearing and again ruling that the sale was not complete until ratification and thus could be undone by post-sale satisfaction of the judgment.The Supreme Court of Maryland reviewed the case. It held that a judgment-debtor’s satisfaction of the judgment after a sheriff’s sale, but before ratification, cannot be raised as an exception to the sale under Maryland Rule 14-305(e)(1). Post-sale satisfaction is not an irregularity in the sale and does not void the purchaser’s inchoate equitable interest in the property acquired at auction. The Court emphasized that the judgment-debtor may obtain release of the levy only before sale, and that post-sale options for release are not available. The Court reversed the Circuit Court’s judgment and remanded with instructions to allow the homeowner thirty days to file exceptions to the sale, beginning after remand to the District Court. View "Baltimore XV Props. v. Newsteps' Choice North Homeowners Association, Inc." on Justia Law

A homeowners association obtained a money judgment against a homeowner for unpaid assessments and placed a levy on the homeowner’s property. The homeowner did not satisfy the judgment prior to a sheriff’s auction, and the property was sold to a third-party purchaser. After the auction, but before the court ratified the sale, the homeowner satisfied the judgment by paying the full amount to the association. The association then asked the court to vacate the sale and return the purchase funds to the buyer, arguing that the post-sale satisfaction of the judgment should nullify the auction outcome.The District Court of Maryland sitting in Prince George’s County agreed with the association, finding it proper to vacate the sale since the judgment was satisfied before ratification. On appeal, the Circuit Court for Prince George’s County held a de novo hearing and affirmed the District Court’s decision, maintaining that the sale was not complete until ratified and thus could be undone by satisfaction of the judgment at that stage. The purchaser sought review from the Supreme Court of Maryland.The Supreme Court of Maryland held that a judgment-debtor’s post-sale satisfaction of the judgment cannot be raised as an exception to a sheriff’s sale under Maryland Rule 14-305(e)(1). The Court explained that such satisfaction is not an irregularity with respect to the sale, and that a purchaser acquires an inchoate equitable interest after the auction, with a right to the ratification process. Allowing satisfaction of the judgment after the sale to void the auction would undermine that right and negatively affect the sheriff’s sale system. Accordingly, the Supreme Court of Maryland reversed the Circuit Court’s judgment and remanded the case for further proceedings, permitting the homeowner thirty days to file exceptions to the sale under the proper rule. View "Baltimore XV Props. V. Newsteps' Choice N." on Justia Law

Two shareholders brought a derivative action on behalf of two Maryland closed-end investment funds against the funds’ investment adviser and members of the funds’ board of directors. The shareholders alleged that the board’s failure to control the funds’ use of leverage led to substantial losses during a downturn in the energy sector, and that the investment adviser benefited from the increased leverage through higher fees. The board consisted of five directors, four of whom were allegedly independent, and one who was the chief executive officer of the adviser. The board renewed the adviser’s contract and took defensive actions after the losses were realized. The shareholders did not make a pre-suit demand on the board before filing suit, claiming that such a demand would have been futile.The Circuit Court for Baltimore City dismissed the derivative claim with prejudice, finding that the shareholders had not pleaded sufficient facts to excuse the demand requirement under Maryland law. The court reviewed each allegation and concluded that none established demand futility. The Appellate Court of Maryland affirmed, holding that the allegations indicated only that a demand was unlikely to succeed, not that it was futile. The appellate court also rejected the shareholders’ argument that potential personal liability for directors constituted a disabling conflict sufficient to excuse demand.The Supreme Court of Maryland affirmed the lower courts’ decisions. It clarified that under Werbowsky v. Collomb, the futility exception is satisfied only if shareholders clearly and particularly allege that a majority of the board could not consider a litigation demand in accordance with the statutory standard of conduct for directors. The court held that futility depends on the board’s capacity to consider a demand, not on the likelihood of refusal, and that allegations of potential personal liability or hostility to litigation do not excuse the demand requirement. The judgment of the Appellate Court of Maryland was affirmed. View "Nathanson v. Tortoise Capital Advisors" on Justia Law

A group of homeowners and their associations opposed amendments to a planned unit development in Baltimore City, actively communicating their disapproval to the Planning Commission. After the Commission approved the amendments, the developer filed suit against the homeowners and associations, seeking damages and alleging breach of contract and tortious interference. The homeowners and associations, believing the suit to be a strategic lawsuit against public participation (SLAPP), moved to dismiss under Maryland’s anti-SLAPP statute, Md. Code Ann., Cts. & Jud. Proc. § 5-807. The Circuit Court for Baltimore City found the lawsuit was a SLAPP and dismissed it, and the Appellate Court of Maryland affirmed the dismissal, citing evidence that the suit was intended to deter the homeowners from exercising their rights.Two years after the Appellate Court affirmed the SLAPP dismissal, the homeowners and associations filed a class action for malicious use of process against the developer, its law firm, and its attorney. They alleged unique injuries, including emotional distress, intimidation, diminished property values, and burdensome discovery demands. The Circuit Court for Baltimore City dismissed the suit, concluding that the plaintiffs had not pleaded the “special injury” required for malicious use of process. The Appellate Court of Maryland affirmed, holding that the alleged injuries were typical of litigation and not “special” as required by Maryland law.The Supreme Court of Maryland reviewed the case and held that the plaintiffs failed to state a claim for malicious use of process because they did not plead a special injury. The Court clarified that litigation expenses, temporary property value diminution, emotional distress, and chilling of constitutional rights are not special injuries under Maryland law. The Court also declined to adopt a rule that victims of a SLAPP inherently satisfy the special-injury requirement. Accordingly, the Supreme Court of Maryland affirmed the judgment of the Appellate Court. View "Millrace Condo. v. Shapiro Sher etc., PA" on Justia Law

A lender initiated a foreclosure action against a church and a related entity concerning certain real property in Baltimore City. The church and the related entity, as borrowers, argued that the lender had previously forgiven the debt and that a recorded mortgage was maintained only to protect the church from other creditors, not to reflect a genuine obligation. The borrowers further alleged that the lender’s right to foreclose was based on fraud, claiming that the underlying note either was satisfied or never reflected a true loan. Before the scheduled foreclosure sale, they raised these defenses in a motion, and a merits hearing was scheduled; the court stayed the sale pending that hearing, provided the borrowers obtained property insurance and posted a bond.The borrowers failed to timely obtain the required insurance, resulting in dissolution of the stay. The lender rescheduled the sale, and the borrowers did not appeal the dissolution, move to reinstate the stay after allegedly securing insurance, or request a hearing before the sale. The sale proceeded, and the lender bought the property. In post-sale exceptions, the borrowers repeated their fraud-based defenses and added a new fraud allegation. The Circuit Court for Baltimore City overruled these exceptions, finding they could not be raised post-sale, and ratified the sale. On appeal, the Appellate Court of Maryland reversed, holding the borrowers could assert their fraud claim after the sale, particularly since the lender was the purchaser and the fraud concerned the validity of the lien.The Supreme Court of Maryland reversed the Appellate Court, holding that a borrower who knows or reasonably should know of a defense to foreclosure—such as fraud or lien invalidity—must raise it before the foreclosure sale under Maryland Rule 14-211. Such defenses cannot be raised as post-sale exceptions if they were or should have been raised earlier, regardless of the purchaser’s identity. The Court also clarified the borrower’s options when a stay is dissolved for failure to meet conditions but held the lower court was not required to reschedule the merits hearing on its own initiative. The case was remanded for further proceedings on other issues. View "Hallam v. New Life Evang. Baptist Church" on Justia Law

The case concerns an automobile accident in Prince George’s County, Maryland, involving George Bowens and a driver named Lisa Daniels, who was at fault. Bowens sustained injuries and held a $50,000 underinsured motorist (UIM) policy with State Farm. Daniels’ insurance had a $30,000 liability limit, which was offered to Bowens as a settlement for his injuries. Following established statutory procedures, Bowens notified State Farm of this offer, State Farm consented and waived subrogation rights, and Bowens accepted the $30,000. Bowens then sought to recover the remaining $20,000 available under his UIM policy from State Farm, which denied the claim.Bowens filed a breach of contract action in the District Court for Prince George’s County, seeking $20,000. State Farm moved to dismiss, arguing that the District Court lacked subject matter jurisdiction because Bowens would have to prove total damages of $50,000—exceeding the court’s $30,000 jurisdictional cap. The District Court agreed and dismissed the case. Bowens appealed to the Circuit Court for Prince George’s County, which affirmed the dismissal, reasoning that the District Court would need to find damages over $30,000 and thus could not grant relief.The Supreme Court of Maryland reviewed the case and held that the District Court’s jurisdiction is determined by the amount the plaintiff seeks from the defendant in the pending action, not by the total underlying damages or prior settlements received from the tortfeasor’s insurer. Since Bowens’ claim against State Farm was for $20,000, the District Court had jurisdiction. The Supreme Court of Maryland reversed the judgment of the circuit court and ordered the case remanded to the District Court for further proceedings. View "Bowens v. State Farm Mut. Auto. Ins." on Justia Law

After a car accident in Prince George’s County, Maryland, George Bowens, who was injured by the clear negligence of another driver, sought to recover compensation for his injuries. The at-fault driver had $30,000 in liability insurance, which was offered to Bowens in settlement. Bowens, however, had a $50,000 underinsured motorist (UIM) policy with his own insurer, State Farm. After accepting the $30,000 from the at-fault driver’s insurer (with State Farm’s consent and waiver of subrogation rights), Bowens sought the remaining $20,000 from State Farm under his UIM policy, claiming breach of contract when State Farm denied the claim.Bowens filed his action in the District Court of Maryland, which has jurisdiction over contract claims not exceeding $30,000. State Farm moved to dismiss, arguing that to recover the $20,000, Bowens would have to prove total damages of $50,000—an amount above the District Court’s jurisdictional cap. The District Court granted the motion to dismiss for lack of subject matter jurisdiction, and the Circuit Court for Prince George’s County affirmed, reasoning that the court would need to find Bowens’ damages exceeded $30,000, thus exceeding the District Court's authority.The Supreme Court of Maryland reviewed the case and reversed the lower courts. It held that, for purposes of determining the District Court’s jurisdiction under § 4-401(1) of the Courts and Judicial Proceedings Article, the relevant amount is the “debt or damages claimed” in the pleadings—that is, the net recovery sought from the defendant in the action—not the plaintiff’s total damages. Because Bowens sought only $20,000 from State Farm, the District Court had jurisdiction to hear the case. The Supreme Court of Maryland remanded the case for further proceedings consistent with this opinion. View "Bowens v. State Farm Mutual Automobile Insurance Co." on Justia Law

Everett Robinson was transferred to Canton Harbor Healthcare Center, a skilled nursing facility, for follow-up care after a stroke. During his stay, he developed pressure ulcers, which allegedly worsened after his transfer to other facilities, leading to his death. Felicia Robinson, his widow, and his surviving children filed a complaint against Canton Harbor, alleging negligence in allowing the pressure ulcers to develop and worsen, causing his wrongful death. They submitted a certificate of a qualified expert, signed by registered nurse Anjanette Jones-Singh, attesting that Canton Harbor breached the standard of care, causing the pressure ulcers.The Circuit Court for Baltimore City dismissed the complaint, ruling that as a registered nurse, Jones-Singh was not qualified to attest to the proximate cause of Robinson's pressure ulcers. The Robinsons appealed, and the Appellate Court of Maryland vacated the dismissal, holding that a registered nurse is not disqualified per se from attesting that a breach of nursing standards proximately caused pressure ulcers. The case was remanded for further proceedings.The Supreme Court of Maryland affirmed the Appellate Court's judgment. The court held that a registered nurse may attest in a certificate that a breach of nursing care standards at a skilled nursing facility proximately caused a pressure ulcer, provided the nurse relies on a pre-existing diagnosis and does not make a medical diagnosis. The court also held that a registered nurse meets the peer-to-peer requirement to attest to breaches of nursing care standards but not to the standards applicable to physicians. The case was allowed to proceed based on the certificate provided by Nurse Jones-Singh. View "Canton Harbor Healthcare v. Robinson" on Justia Law

In 2020, the Maryland General Assembly passed the Housing Opportunities Made Equal (HOME) Act, which added "source of income" to the list of prohibited considerations in housing rental or sale. The appellant, a housing voucher recipient, applied to rent an apartment in the appellee's complex. The appellee applied a minimum-income requirement, combining all sources of income to determine if the total exceeded 2.5 times the full gross rent. The appellant's combined income, including her voucher, did not meet this threshold, leading to the rejection of her application. The appellant sued, claiming the minimum-income requirement constituted source-of-income discrimination under § 20-705.The Circuit Court for Baltimore County granted summary judgment to the appellee, finding that the appellee's policy did not discriminate based on the source of income but rather on the amount of income. The court ruled that the appellee neutrally applied its income qualification criteria and rejected the appellant based on the amount of her income, not its source.The Supreme Court of Maryland reviewed the case and held that the appellee's counting of voucher income in the same manner as other income sources did not entitle it to summary judgment. The court found that this approach did not resolve the appellant's disparate impact claim, which asserts that a facially neutral policy has a disparate impact on a protected group without a legitimate, nondiscriminatory reason. The court vacated the judgment of the circuit court and remanded the case for further proceedings consistent with its opinion, emphasizing the need to address the disparate impact analysis. View "Hare v. David S. Brown Enterprises" on Justia Law