reckless disregard standard in Maryland

2016In Jacron, id. at 600 , 350 A.2d at 699-700 , we observed that Maryland law did not recognize negligence as a legitimate ground upon which to defeat a common law conditional privilege, and, thus, we retained the Stevenson definition of malice, ie., “the reckless disregard standard[,]” as applied to common law conditional privileges, explaining: We repeated the Stevenson definition [in another case], and thus the reckless disregard standard now appears to be firmly established in Maryland as a test, albeit not the exclusive test, for abuse of a conditional privilege.

2016In Jacron, id. at 600 , 350 A.2d at 699-700 , we observed that Maryland law did not recognize negligence as a legitimate ground upon which to defeat a common law conditional privilege, and, thus, we retained the Stevenson definition of malice, ie., “the reckless disregard standard[,]” as applied to common law conditional privileges, explaining: We repeated the Stevenson definition [in another case], and thus the reckless disregard standard now appears to be firmly established in Maryland as a test, albeit not the exclusive test, for abuse of a conditional privilege.

1977“The Maryland cases on abuse of conditional privilege are couched in terms of ‘express malice’ or ‘actual malice.’ ” “Express or actual malice represents something-more than conduct that is merely negligent.” Referring to its definition of malice found in Stevenson v. Baltimore Club, 250 Md. 482 , 243 A. 2d 533 (1968), and Orrison v. Vance, 262 Md. 285 , 277 A. 2d 573 (1971), the Court said, in Jacron, at 600: “* * * thus the reckless disregard standard now appears to be firmly established in Maryland as a test, albeit not the exclusive test, for abuse of a conditional privilege.

1977“The Maryland cases on abuse of conditional privilege are couched in terms of ‘express malice’ or ‘actual malice.’ ” “Express or actual malice represents something-more than conduct that is merely negligent.” Referring to its definition of malice found in Stevenson v. Baltimore Club, 250 Md. 482 , 243 A. 2d 533 (1968), and Orrison v. Vance, 262 Md. 285 , 277 A. 2d 573 (1971), the Court said, in Jacron, at 600: “* * * thus the reckless disregard standard now appears to be firmly established in Maryland as a test, albeit not the exclusive test, for abuse of a conditional privilege.

2021The Court of Appeals revisited gross negligence in the law enforcement context again in Cooper v. Rodriguez, 443 Md. 680 (2015): This case concerns the brutal murder of an inmate [Philip Parker, Jr.] by another inmate during a ride on a prison transport bus that was staffed by five correctional officers.

1978Quoting the Stevenson formulation in Jacron Sales Co. v. Sindorf, 276 Md. 580, 599-600 , 350 A. 2d 688 (1976), we italicized the words “reckless disregard of truth” and to impart further emphasis also added there that “the reckless disregard standard now appears to be firmly established in Maryland as a test, albeit not the exclusive test, for abuse of a conditional privilege.” And just this term, in IBEW, Local 1805 v. Mayo, 281 Md. 475, 479-81 , 379 A. 2d 1223 (1977), we reiterated our preference for a more stringent standard of malice, stating that *135 “reckless disregard as to truth or fa

1978Quoting the Stevenson formulation in Jacron Sales Co. v. Sindorf, 276 Md. 580, 599-600 , 350 A. 2d 688 (1976), we italicized the words “reckless disregard of truth” and to impart further emphasis also added there that “the reckless disregard standard now appears to be firmly established in Maryland as a test, albeit not the exclusive test, for abuse of a conditional privilege.” And just this term, in IBEW, Local 1805 v. Mayo, 281 Md. 475, 479-81 , 379 A. 2d 1223 (1977), we reiterated our preference for a more stringent standard of malice, stating that *135 “reckless disregard as to truth or fa

1978Quoting the Stevenson formulation in Jacron Sales Co. v. Sindorf, 276 Md. 580, 599-600 , 350 A. 2d 688 (1976), we italicized the words “reckless disregard of truth” and to impart further emphasis also added there that “the reckless disregard standard now appears to be firmly established in Maryland as a test, albeit not the exclusive test, for abuse of a conditional privilege.” And just this term, in IBEW, Local 1805 v. Mayo, 281 Md. 475, 479-81 , 379 A. 2d 1223 (1977), we reiterated our preference for a more stringent standard of malice, stating that *135 “reckless disregard as to truth or fa

1978Quoting the Stevenson formulation in Jacron Sales Co. v. Sindorf, 276 Md. 580, 599-600 , 350 A. 2d 688 (1976), we italicized the words “reckless disregard of truth” and to impart further emphasis also added there that “the reckless disregard standard now appears to be firmly established in Maryland as a test, albeit not the exclusive test, for abuse of a conditional privilege.” And just this term, in IBEW, Local 1805 v. Mayo, 281 Md. 475, 479-81 , 379 A. 2d 1223 (1977), we reiterated our preference for a more stringent standard of malice, stating that *135 “reckless disregard as to truth or fa

1977“The Maryland cases on abuse of conditional privilege are couched in terms of ‘express malice’ or ‘actual malice.’ ” “Express or actual malice represents something-more than conduct that is merely negligent.” Referring to its definition of malice found in Stevenson v. Baltimore Club, 250 Md. 482 , 243 A. 2d 533 (1968), and Orrison v. Vance, 262 Md. 285 , 277 A. 2d 573 (1971), the Court said, in Jacron, at 600: “* * * thus the reckless disregard standard now appears to be firmly established in Maryland as a test, albeit not the exclusive test, for abuse of a conditional privilege.

1977“The Maryland cases on abuse of conditional privilege are couched in terms of ‘express malice’ or ‘actual malice.’ ” “Express or actual malice represents something-more than conduct that is merely negligent.” Referring to its definition of malice found in Stevenson v. Baltimore Club, 250 Md. 482 , 243 A. 2d 533 (1968), and Orrison v. Vance, 262 Md. 285 , 277 A. 2d 573 (1971), the Court said, in Jacron, at 600: “* * * thus the reckless disregard standard now appears to be firmly established in Maryland as a test, albeit not the exclusive test, for abuse of a conditional privilege.