statutory construction analysis (Maryland) · Go Syfert
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statutory construction analysis in Maryland

22 Maryland opinions name it 2 courts 1993–2025 9 in the last five years

The cases below were cited by Maryland courts in a sentence that names this issue. Sides come from how each citing opinion treated the case (Syfertize flag on that citation), so a case can appear on both: that is where the law is contested. A red or yellow chip is the case's own overall treatment.

Followed or applied (15)

CaseFollowedCited
Schreyer v. Chaplaingreen
md · 2010 · cited in 6 Maryland opinions naming this issue, 2018–2022
2 sentences

2022“When conducting a statutory construction analysis, we begin ‘with the plain language of the statute, and ordinary, popular understanding of the English language dictates interpretation of its terminology.’” Blackstone, 461 Md. at 113 (quoting Schreyer v. Chaplain, 416 Md. 94, 101 (2010)).

2021The statutory construction analysis begins “with the plain language of the statute, and ordinary, popular understanding of the English language dictates interpretation of its terminology.” Id. (quoting Schreyer v. Chaplain, 416 Md. 94, 101 , 5 A.3d 1054 (2010)).

46
Downes v. Downesgreen
md · 2005 · cited in 4 Maryland opinions naming this issue, 2018–2021
2 sentences

2021See Downes v. Downes, 388 Md. 561, 571 (2005).

2018See Downes v. Downes , 388 Md. 561 , 571, 880 A.2d 343 (2005).

44
State v. Beygreen
md · 2017 · cited in 4 Maryland opinions naming this issue, 2018–2019
2 sentences

2019When the “words of a statute are ambiguous and subject to more than one reasonable interpretation, or where the words are clear and unambiguous when viewed in isolation, but become ambiguous when read as part of a larger statutory scheme, a court must resolve the ambiguity by searching for legislative intent 17 in other indicia[.]” State v. Bey, 452 Md. 255, 266 (2017).

2019When the “words of a statute are ambiguous and subject to more than one reasonable interpretation, or where the words are clear and unambiguous when viewed in isolation, but become ambiguous when read as part of a larger statutory scheme, a court must resolve the ambiguity by searching for legislative intent 17 in other indicia[.]” State v. Bey, 452 Md. 255, 266 (2017).

34
Johnson v. Stategreen
md · 2020 · cited in 3 Maryland opinions naming this issue, 2021–2022
2 sentences

2022“The statutory construction analysis commences with the plain language of the statute.” Johnson v. State, 467 Md. 362, 372 (2020) (internal citations and quotations omitted); see also Blackstone v. Sharma, 461 Md. 87, 113 (2018) (“[W]e begin ‘with the plain language of the statute, and ordinary, popular understanding of the English language dictates interpretation of its terminology.’”) (citation omitted).

2021The more likely reading of this statute is (Continued…) -6- The statutory construction analysis commences “with the plain language of the statute.” Johnson v. State, 467 Md. 362, 372 (2020) (Internal citations and quotations omitted).

33
In Re Wallace W.green
md · 1993 · cited in 2 Maryland opinions naming this issue, 2013–2022
2 sentences

2022Following the statutory construction principle of ejusdem generis,8 “if the [General Assembly] had intended the general words to be construed in an unrestricted sense, it would not have enumerated the specific things.” In re Wallace W., 333 Md. 186, 190 , 634 A.2d 53, 56 (1993) (citations omitted).

2022Following the statutory construction principle of ejusdem generis,8 “if the [General Assembly] had intended the general words to be construed in an unrestricted sense, it would not have enumerated the specific things.” In re Wallace W., 333 Md. 186, 190 , 634 A.2d 53, 56 (1993) (citations omitted).

22
Blackstone v. Sharmagreen
md · 2018 · cited in 2 Maryland opinions naming this issue, 2022–2022
2 sentences

2022“The statutory construction analysis commences with the plain language of the statute.” Johnson v. State, 467 Md. 362, 372 (2020) (internal citations and quotations omitted); see also Blackstone v. Sharma, 461 Md. 87, 113 (2018) (“[W]e begin ‘with the plain language of the statute, and ordinary, popular understanding of the English language dictates interpretation of its terminology.’”) (citation omitted).

2022“When conducting a statutory construction analysis, we begin ‘with the plain language of the statute, and ordinary, popular understanding of the English language dictates interpretation of its terminology.’” Blackstone, 461 Md. at 113 (quoting Schreyer v. Chaplain, 416 Md. 94, 101 (2010)).

12
Douglas v. Stategreen
md · 2011 · cited in 2 Maryland opinions naming this issue, 2020–2021
2 sentences

2021We read “the statute as a whole to ensure that no word, clause, sentence or phrase is rendered surplusage, superfluous, meaningless or nugatory.” Phillips, 451 Md. at 196-97 , 152 A.3d 712 (quoting Douglas v. State, 423 Md. 156, 178 , 31 A.3d 250 (2011)).

2021We read “the statute as a whole to ensure that no word, clause, sentence or phrase is rendered surplusage, superfluous, meaningless or nugatory.” Phillips, 451 Md. at 196-97 , 152 A.3d 712 (quoting Douglas v. State, 423 Md. 156, 178 , 31 A.3d 250 (2011)).

12
State v. Roshchingreen
md · 2016 · cited in 1 Maryland opinions naming this issue, 2022–2022
1 sentence

2022“Even in instances ‘when the language is unambiguous, it is useful to review legislative history of the statute to confirm that interpretation and to eliminate another version of legislative intent alleged to be latent in the language.’” Id. (quoting State v. Roshchin, 446 Md. 128, 140 (2016)).

11
Opert v. Criminal Injuries Compensation Boardgreen
md · 2008 · cited in 1 Maryland opinions naming this issue, 2021–2021
1 sentence

2021“If the language is clear and unambiguous, we ordinarily need not look beyond the statute’s provisions and our analysis ends.” Opert v. Criminal Injuries, 403 Md. 587, 593 (2008) (Internal citations and quotations omitted).

11
Giant of Maryland, Inc. v. State's Attorneygreen
md · 1975 · cited in 1 Maryland opinions naming this issue, 2013–2013
2 sentences

2013We explained that doctrine in In re Wallace W., 333 Md. 186, 190 , 634 A.2d 53, 55-56 (1993): “[W]hen general words in a statute follow the designation of particular things or classes of subjects or persons, the general words will usually be construed to include only those things or persons of the same class or general nature as those specifically mentioned.” (quoting Giant of Md. v. State’s Attorney, 274 Md. 158, 167 , 334 A.2d 107, 113 (1975)) (internal quotation marks omitted).

2013We explained that doctrine in In re Wallace W., 333 Md. 186, 190 , 634 A.2d 53, 55-56 (1993): “[W]hen general words in a statute follow the designation of particular things or classes of subjects or persons, the general words will usually be construed to include only those things or persons of the same class or general nature as those specifically mentioned.” (quoting Giant of Md. v. State’s Attorney, 274 Md. 158, 167 , 334 A.2d 107, 113 (1975)) (internal quotation marks omitted).

11
State v. Wiegmanngreen
md · 1998 · cited in 1 Maryland opinions naming this issue, 2000–2000
2 sentences

2000See State v. Wiegmann, 350 Md. 585, 593 , 714 A.2d 841 (1998); Cox v. Prince George’s County, 86 Md.App. 179, 194 , 586 A.2d 43 (1991).

2000See State v. Wiegmann, 350 Md. 585, 593 , 714 A.2d 841 (1998); Cox v. Prince George’s County, 86 Md.App. 179, 194 , 586 A.2d 43 (1991).

11
Forbes v. Stategreen
md · 1991 · cited in 1 Maryland opinions naming this issue, 1993–1993
2 sentences

1993See, e.g., Forbes v. State, 324 Md. 335, 342 , 597 A.2d 427, 431 (1991) (“ ‘The General Assembly is presumed to be aware of this Court’s interpretation of its enactments and, if such interpretation is not legislatively overturned, to have acquiesced in that interpretation,’ ” quoting Williams v. State, 292 Md. 201, 210 , 438 A.2d 1301, 1305 (1981)); Nationwide v. USF & G, 314 Md. 131, 143 , 550 A.2d 69, 75 (1988) (referring to "our decision" previously interpreting the statute and to “ ‘this Court’s' ” prior interpretation); Frank v. Storer, 308 Md. 194, 203 , 517 A.2d 1098, 1102-1103 (1986) (

1993See, e.g., Forbes v. State, 324 Md. 335, 342 , 597 A.2d 427, 431 (1991) (“ ‘The General Assembly is presumed to be aware of this Court’s interpretation of its enactments and, if such interpretation is not legislatively overturned, to have acquiesced in that interpretation,’ ” quoting Williams v. State, 292 Md. 201, 210 , 438 A.2d 1301, 1305 (1981)); Nationwide v. USF & G, 314 Md. 131, 143 , 550 A.2d 69, 75 (1988) (referring to "our decision" previously interpreting the statute and to “ ‘this Court’s' ” prior interpretation); Frank v. Storer, 308 Md. 194, 203 , 517 A.2d 1098, 1102-1103 (1986) (

11
Nationwide Mutual Insurance v. United States Fidelity & Guaranty Co.green
md · 1988 · cited in 1 Maryland opinions naming this issue, 1993–1993
2 sentences

1993See, e.g., Forbes v. State, 324 Md. 335, 342 , 597 A.2d 427, 431 (1991) (“ ‘The General Assembly is presumed to be aware of this Court’s interpretation of its enactments and, if such interpretation is not legislatively overturned, to have acquiesced in that interpretation,’ ” quoting Williams v. State, 292 Md. 201, 210 , 438 A.2d 1301, 1305 (1981)); Nationwide v. USF & G, 314 Md. 131, 143 , 550 A.2d 69, 75 (1988) (referring to "our decision" previously interpreting the statute and to “ ‘this Court’s' ” prior interpretation); Frank v. Storer, 308 Md. 194, 203 , 517 A.2d 1098, 1102-1103 (1986) (

1993See, e.g., Forbes v. State, 324 Md. 335, 342 , 597 A.2d 427, 431 (1991) (“ ‘The General Assembly is presumed to be aware of this Court’s interpretation of its enactments and, if such interpretation is not legislatively overturned, to have acquiesced in that interpretation,’ ” quoting Williams v. State, 292 Md. 201, 210 , 438 A.2d 1301, 1305 (1981)); Nationwide v. USF & G, 314 Md. 131, 143 , 550 A.2d 69, 75 (1988) (referring to "our decision" previously interpreting the statute and to “ ‘this Court’s' ” prior interpretation); Frank v. Storer, 308 Md. 194, 203 , 517 A.2d 1098, 1102-1103 (1986) (

11
Frank v. Storergreen
md · 1986 · cited in 1 Maryland opinions naming this issue, 1993–1993
2 sentences

1993See, e.g., Forbes v. State, 324 Md. 335, 342 , 597 A.2d 427, 431 (1991) (“ ‘The General Assembly is presumed to be aware of this Court’s interpretation of its enactments and, if such interpretation is not legislatively overturned, to have acquiesced in that interpretation,’ ” quoting Williams v. State, 292 Md. 201, 210 , 438 A.2d 1301, 1305 (1981)); Nationwide v. USF & G, 314 Md. 131, 143 , 550 A.2d 69, 75 (1988) (referring to "our decision" previously interpreting the statute and to “ ‘this Court’s' ” prior interpretation); Frank v. Storer, 308 Md. 194, 203 , 517 A.2d 1098, 1102-1103 (1986) (

1993See, e.g., Forbes v. State, 324 Md. 335, 342 , 597 A.2d 427, 431 (1991) (“ ‘The General Assembly is presumed to be aware of this Court’s interpretation of its enactments and, if such interpretation is not legislatively overturned, to have acquiesced in that interpretation,’ ” quoting Williams v. State, 292 Md. 201, 210 , 438 A.2d 1301, 1305 (1981)); Nationwide v. USF & G, 314 Md. 131, 143 , 550 A.2d 69, 75 (1988) (referring to "our decision" previously interpreting the statute and to “ ‘this Court’s' ” prior interpretation); Frank v. Storer, 308 Md. 194, 203 , 517 A.2d 1098, 1102-1103 (1986) (

11
Williams v. Stategreen
md · 1981 · cited in 1 Maryland opinions naming this issue, 1993–1993
2 sentences

1993See, e.g., Forbes v. State, 324 Md. 335, 342 , 597 A.2d 427, 431 (1991) (“ ‘The General Assembly is presumed to be aware of this Court’s interpretation of its enactments and, if such interpretation is not legislatively overturned, to have acquiesced in that interpretation,’ ” quoting Williams v. State, 292 Md. 201, 210 , 438 A.2d 1301, 1305 (1981)); Nationwide v. USF & G, 314 Md. 131, 143 , 550 A.2d 69, 75 (1988) (referring to "our decision" previously interpreting the statute and to “ ‘this Court’s' ” prior interpretation); Frank v. Storer, 308 Md. 194, 203 , 517 A.2d 1098, 1102-1103 (1986) (

1993See, e.g., Forbes v. State, 324 Md. 335, 342 , 597 A.2d 427, 431 (1991) (“ ‘The General Assembly is presumed to be aware of this Court’s interpretation of its enactments and, if such interpretation is not legislatively overturned, to have acquiesced in that interpretation,’ ” quoting Williams v. State, 292 Md. 201, 210 , 438 A.2d 1301, 1305 (1981)); Nationwide v. USF & G, 314 Md. 131, 143 , 550 A.2d 69, 75 (1988) (referring to "our decision" previously interpreting the statute and to “ ‘this Court’s' ” prior interpretation); Frank v. Storer, 308 Md. 194, 203 , 517 A.2d 1098, 1102-1103 (1986) (

11

Distinguished, questioned or overruled (0)

CaseNegativeCited
No negative-treatment citations attached to this issue in Maryland. Read the followed side critically anyway.

Also cited on this issue (7)

CaseCitedYears
Adventist Health Care Inc. v. Maryland Health Care Commission green
md · 2006
2 sentences

2019As we have previously stated: When conducting a statutory construction analysis, we begin “with the plain language of the statute, and ordinary, popular understanding of the English language dictates interpretation of its terminology.” Schreyer v. Chaplain, 416 Md. 94, 101 (2010) (quoting Adventist Health Care Inc. v. Maryland Health Care Comm’n, 392 Md. 103 , 124 n.13 (2006)).

2019As we have previously stated: When conducting a statutory construction analysis, we begin “with the plain language of the statute, and ordinary, popular understanding of the English language dictates interpretation of its terminology.” Schreyer v. Chaplain, 416 Md. 94, 101 (2010) (quoting Adventist Health Care Inc. v. Maryland Health Care Comm’n, 392 Md. 103 , 124 n.13 (2006)).

42018–2019
Phillips v. State green
md · 2017
2 sentences

2021The statutory construction analysis begins “with the plain language of the statute, and ordinary, popular understanding of the English language dictates interpretation of its terminology.” Id. (quoting Schreyer v. Chaplain, 416 Md. 94, 101 , 5 A.3d 1054 (2010)).

2020The statutory construction analysis begins “with the plain language of the statute, and ordinary, popular understanding of the English language dictates interpretation of its terminology.” Id. (quoting Schreyer v. Chaplain, 416 Md. 94, 101 (2010)).

22020–2021
Greenbelt Consumer Services, Inc. v. Acme Markets, Inc. green
md · 1974
1 sentence

2025After conducting a statutory construction analysis, this Court determined that actions “involving landlord and tenant” encompassed “only those possessory in rem or quasi in rem actions that provide[] a means by which a landlord might rapidly and inexpensively obtain repossession of his [or her] premises situated in this State or seek security for rent due from personalty located on the leasehold.” See id. at 227–29 (noting that if the statute had instead stated “an action involving a landlord and a tenant,” the District Court’s jurisdiction would be “practically limitless” and reasoning that t

12025–2025
Gargliano v. State green
md · 1994
2 sentences

2025Applying the statutory construction framework set forth in Gargliano v. State, 334 Md. 428 , 639 A.2d 675 (1994), the Appellate Court concluded that CS § 3-702(c) is applicable only where an inmate has been convicted of a violation of CR § 3-307 prior to the commission of the offense for which the inmate is serving the sentence at issue.

2025Applying the statutory construction framework set forth in Gargliano v. State, 334 Md. 428 , 639 A.2d 675 (1994), the Appellate Court concluded that CS § 3-702(c) is applicable only where an inmate has been convicted of a violation of CR § 3-307 prior to the commission of the offense for which the inmate is serving the sentence at issue.

12025–2025
Simpson v. United States green
scotus · 1978
1 sentence

2014Id.

12014–2014
Cox v. Prince George's County green
mdctspecapp · 1991
2 sentences

2000See State v. Wiegmann, 350 Md. 585, 593 , 714 A.2d 841 (1998); Cox v. Prince George’s County, 86 Md.App. 179, 194 , 586 A.2d 43 (1991).

2000See State v. Wiegmann, 350 Md. 585, 593 , 714 A.2d 841 (1998); Cox v. Prince George’s County, 86 Md.App. 179, 194 , 586 A.2d 43 (1991).

12000–2000
Rayner v. State green
· 1879
2 sentences

1994Judge Alvey concluded as follows ( 52 Md. at 376-377 , emphasis added): "It has been urged that, as the rights of personal liberty and of private property are involved, it would be a strange defect of the law, and a great hardship, if the party be denied the right of resorting to this Court to have the question of the constitutionality of the statute, under which it is supposed his rights have been unjustifiably invaded, finally decided.

1994Judge Alvey concluded as follows ( 52 Md. at 376-377 , emphasis added): “It has been urged that, as the rights of personal liberty and of private property are involved, it would be a strange defect of the law, and a great hardship, if the party be denied the right of resorting to this Court to have the question of the constitutionality of the statute, under which it is supposed his rights have been unjustifiably invaded, finally decided.

11994–1994

Where else courts name it

FL 81 (1974–2024) PA 68 (1980–2026) TX 52 (1961–2025) CA 41 (1959–2024) MI 34 (1984–2026) IL 30 (1984–2025) WA 28 (1994–2021) OR 24 (1916–2026) MD 22 (1993–2025) NM 11 (1991–2024) TN 10 (1981–2020) WI 10 (1989–2020) CT 9 (1978–2020) OH 8 (1992–2026) VT 7 (1995–2018) LA 7 (1980–2021) GA 6 (2014–2025) IA 6 (1957–2017) CO 6 (1992–2013) WV 5 (1983–2026) VA 5 (2010–2025) NC 5 (1985–2020) AZ 5 (1987–2014) AK 4 (1984–2022) NY 4 (1987–2010) SC 4 (2001–2020) ID 4 (1990–2014) AR 3 (1994–2018) HI 3 (2008–2022) WY 3 (2006–2019) NJ 3 (1984–2016) AL 3 (1952–2001) SD 2 (2001–2001) KS 2 (2007–2013) RI 2 (1996–2011) MO 2 (1994–2024)

Opinions by the citing court's state. A doctrine retained in one state and abandoned in another shows up here as a year span that stalls.

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