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20 Maryland opinions name it 2 courts 2000–2020 0 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.
| Case | Followed | Cited |
|---|---|---|
Leppo v. State Highway Administrationgreen2 sentences2011Faulk, 371 Md. at 304 , 808 A.2d at 1276 ; Grubbs v. Prince George’s County, 267 Md. 318, 320-21 , 297 A.2d 754, 755-56 (1972) (stating “we have regarded it [the predecessor statute to the LGTCA, Md.Code (1957, 1972 RepLVoL), Art. 57, § 18] as a condition precedent to the right to maintain an action for damages”); see also Neuenschwander v. Washington Suburban Sanitary Comm’n, 187 Md. 67, 77 , 48 A.2d 593, 599 (1946) (stating that “the notice is a condition precedent to the right to maintain the suit”), overruled on other grounds by statute as stated in Arnold v. Prince George’s County, 270 Md 2011Faulk, 371 Md. at 304 , 808 A.2d at 1276 ; Grubbs v. Prince George’s County, 267 Md. 318, 320-21 , 297 A.2d 754, 755-56 (1972) (stating “we have regarded it [the predecessor statute to the LGTCA, Md.Code (1957, 1972 RepLVoL), Art. 57, § 18] as a condition precedent to the right to maintain an action for damages”); see also Neuenschwander v. Washington Suburban Sanitary Comm’n, 187 Md. 67, 77 , 48 A.2d 593, 599 (1946) (stating that “the notice is a condition precedent to the right to maintain the suit”), overruled on other grounds by statute as stated in Arnold v. Prince George’s County, 270 Md | 3 | 3 |
Heron v. Stradergreen2 sentences2011Kleinke v. Ocean City, 147 N.J.Super. 575 , 371 A.2d 785 (N.J.Super.App.Div.1977); serious physical or mental injury and/or location out-of-state; the inability to retain counsel in cases involving complex litigation; and ignorance of the statutory notice requirement. ..." Heron, 361 Md. at 272-73 , 761 A.2d at 63-64 (citations omitted). 2011They are “ ‘excusable neglect or mistake (generally determined in reference to a reasonably prudent person standard), serious physical or mental injury and/or location out-of-state, the inability to retain counsel in cases involving complex litigation, and ignorance of the statutory notice requirement.’ ” Id. (quoting Heron, at 272, 761 A.2d 56 ) (citations omitted). | 2 | 8 |
White v. Prince George's Countygreen2 sentences2009We therefore concluded that the claimant “did not substantially comply with the statutory notice requirement by filing a complaint with I.A.D. about police brutality.” Id. at 147 , 877 A.2d 1129 . 2009We therefore concluded that the claimant “did not substantially comply with the statutory notice requirement by filing a complaint with I.A.D. about police brutality.” Id. at 147 , 877 A.2d 1129 . | 2 | 5 |
Redfern v. Holtite Manufacturing Co.green2 sentences2011Co., 209 Md. 106, 111-12 , 120 A.2d 370, 372-73 (1956) (finding that statutory notice was a condition precedent to applying for payment for deaths pursuant to the Workmen’s Compensation Act). 386 Md. at 126-27 , 872 A.2d 1 . 2011Co., 209 Md. 106, 111-12 , 120 A.2d 370, 372-73 (1956) (finding that statutory notice was a condition precedent to applying for payment for deaths pursuant to the Workmen’s Compensation Act). 386 Md. at 126-27 , 872 A.2d 1 . | 2 | 3 |
Neuenschwander v. Washington Suburban Sanitary Commissiongreen2 sentences2011Faulk, 371 Md. at 304 , 808 A.2d at 1276 ; Grubbs v. Prince George’s County, 267 Md. 318, 320-21 , 297 A.2d 754, 755-56 (1972) (stating “we have regarded it [the predecessor statute to the LGTCA, Md.Code (1957, 1972 RepLVoL), Art. 57, § 18] as a condition precedent to the right to maintain an action for damages”); see also Neuenschwander v. Washington Suburban Sanitary Comm’n, 187 Md. 67, 77 , 48 A.2d 593, 599 (1946) (stating that “the notice is a condition precedent to the right to maintain the suit”), overruled on other grounds by statute as stated in Arnold v. Prince George’s County, 270 Md 2011Faulk, 371 Md. at 304 , 808 A.2d at 1276 ; Grubbs v. Prince George’s County, 267 Md. 318, 320-21 , 297 A.2d 754, 755-56 (1972) (stating “we have regarded it [the predecessor statute to the LGTCA, Md.Code (1957, 1972 RepLVoL), Art. 57, § 18] as a condition precedent to the right to maintain an action for damages”); see also Neuenschwander v. Washington Suburban Sanitary Comm’n, 187 Md. 67, 77 , 48 A.2d 593, 599 (1946) (stating that “the notice is a condition precedent to the right to maintain the suit”), overruled on other grounds by statute as stated in Arnold v. Prince George’s County, 270 Md | 2 | 2 |
Arnold v. Prince George's Countygreen2 sentences2011Faulk, 371 Md. at 304 , 808 A.2d at 1276 ; Grubbs v. Prince George’s County, 267 Md. 318, 320-21 , 297 A.2d 754, 755-56 (1972) (stating “we have regarded it [the predecessor statute to the LGTCA, Md.Code (1957, 1972 RepLVoL), Art. 57, § 18] as a condition precedent to the right to maintain an action for damages”); see also Neuenschwander v. Washington Suburban Sanitary Comm’n, 187 Md. 67, 77 , 48 A.2d 593, 599 (1946) (stating that “the notice is a condition precedent to the right to maintain the suit”), overruled on other grounds by statute as stated in Arnold v. Prince George’s County, 270 Md 2011Faulk, 371 Md. at 304 , 808 A.2d at 1276 ; Grubbs v. Prince George’s County, 267 Md. 318, 320-21 , 297 A.2d 754, 755-56 (1972) (stating “we have regarded it [the predecessor statute to the LGTCA, Md.Code (1957, 1972 RepLVoL), Art. 57, § 18] as a condition precedent to the right to maintain an action for damages”); see also Neuenschwander v. Washington Suburban Sanitary Comm’n, 187 Md. 67, 77 , 48 A.2d 593, 599 (1946) (stating that “the notice is a condition precedent to the right to maintain the suit”), overruled on other grounds by statute as stated in Arnold v. Prince George’s County, 270 Md | 2 | 2 |
Grubbs v. Prince George's Countygreen2 sentences2011Faulk, 371 Md. at 304 , 808 A.2d at 1276 ; Grubbs v. Prince George’s County, 267 Md. 318, 320-21 , 297 A.2d 754, 755-56 (1972) (stating “we have regarded it [the predecessor statute to the LGTCA, Md.Code (1957, 1972 RepLVoL), Art. 57, § 18] as a condition precedent to the right to maintain an action for damages”); see also Neuenschwander v. Washington Suburban Sanitary Comm’n, 187 Md. 67, 77 , 48 A.2d 593, 599 (1946) (stating that “the notice is a condition precedent to the right to maintain the suit”), overruled on other grounds by statute as stated in Arnold v. Prince George’s County, 270 Md 2011Faulk, 371 Md. at 304 , 808 A.2d at 1276 ; Grubbs v. Prince George’s County, 267 Md. 318, 320-21 , 297 A.2d 754, 755-56 (1972) (stating “we have regarded it [the predecessor statute to the LGTCA, Md.Code (1957, 1972 RepLVoL), Art. 57, § 18] as a condition precedent to the right to maintain an action for damages”); see also Neuenschwander v. Washington Suburban Sanitary Comm’n, 187 Md. 67, 77 , 48 A.2d 593, 599 (1946) (stating that “the notice is a condition precedent to the right to maintain the suit”), overruled on other grounds by statute as stated in Arnold v. Prince George’s County, 270 Md | 2 | 2 |
Rios v. Montgomery Countygreen2 sentences2013In certain other jurisdictions, a plaintiff shows good cause for his or her failure to comply with a tort claims act’s notice requirement where the plaintiff was: (1) responsible for “excusable neglect or mistake (generally determined in reference to a reasonably prudent person standard)”; (2) suffering a “serious physical or mental injury”; (3) “locat[ed] out-of-state”; (4) unable “to retain counsel in [a] case[] involving complex litigation”; or (5) “ignoran[t] of the statutory notice requirement^]” Id. at 141 , 872 A.2d at 22-23 (citations and internal quotation marks omitted). 2013In certain other jurisdictions, a plaintiff shows good cause for his or her failure to comply with a tort claims act’s notice requirement where the plaintiff was: (1) responsible for “excusable neglect or mistake (generally determined in reference to a reasonably prudent person standard)”; (2) suffering a “serious physical or mental injury”; (3) “locat[ed] out-of-state”; (4) unable “to retain counsel in [a] case[] involving complex litigation”; or (5) “ignoran[t] of the statutory notice requirement^]” Id. at 141 , 872 A.2d at 22-23 (citations and internal quotation marks omitted). | 1 | 3 |
Moore v. Norouzigreen2 sentences2007Moore [v. Norouzi], 371 Md. [154] at 169, 807 A.2d 632 . 2004In a footnote in Heron, 361 Md. at 272 n. 13, 761 A.2d 56 , the Heron Court cited our decision in Williams v. Montgomery County, 123 Md.App. 119 , 716 A.2d 1100 (1998), for the proposition that this Court “has specifically rejected ignorance of the law requiring notice as good cause.” Thereafter, in Hargrove, 146 Md.App. at 467 , 807 A.2d 149 , we discussed Heron , noting that the Heron Court “reaffirmed that Maryland has specifically rejected the ignorance of the law requirement as good cause.” In the consolidated case of Moore v. Norouzi, 371 Md. at 159, 807 A.2d 632 , the claimants were inj | 1 | 3 |
Mayor of Baltimore v. Stokesgreen2 sentences2016Mayor and City Council of Baltimore v. Stokes, 217 Md.App. 471, 486-88 , 94 A.3d 159 (2014) (quoting Wilbon v. Hunsicker, 172 Md.App. 181, 205-06 , 913 A.2d 678 (2006)). 2016Mayor and City Council of Baltimore v. Stokes, 217 Md.App. 471, 486-88 , 94 A.3d 159 (2014) (quoting Wilbon v. Hunsicker, 172 Md.App. 181, 205-06 , 913 A.2d 678 (2006)). | 1 | 2 |
Hughes v. Moyergreen2 sentences2020CODE ANN., SPP § 11- 106(a)(5) was to ensure fair process. 452 Md. 77, 99 , 156 A.3d 770, 783 (2017). 2020CODE ANN., SPP § 11- 106(a)(5) was to ensure fair process. 452 Md. 77, 99 , 156 A.3d 770, 783 (2017). | 1 | 1 |
| Case | Negative | Cited |
|---|---|---|
| No negative-treatment citations attached to this issue in Maryland. Read the followed side critically anyway. | ||
| Case | Cited | Years |
|---|---|---|
Wilbon v. Hunsicker
green
2 sentences2010These were summarized in Wilbon : excusable neglect or mistake (generally determined in reference to a reasonably prudent person standard), [2] serious physical or mental injury and/or location out-of-state, [3] the inability to retain counsel in cases involving complex litigation, ... [4j ignorance of the statutory notice requirement!,] or [5] misleading representations made by [a] representative of the local government. 172 Md.App. at 205-06 , 913 A.2d 678 (Quotations and citations omitted.) 35 Appellants argue that none of these conditions are present here. 2010These were summarized in Wilbon : excusable neglect or mistake (generally determined in reference to a reasonably prudent person standard), [2] serious physical or mental injury and/or location out-of-state, [3] the inability to retain counsel in cases involving complex litigation, ... [4j ignorance of the statutory notice requirement!,] or [5] misleading representations made by [a] representative of the local government. 172 Md.App. at 205-06 , 913 A.2d 678 (Quotations and citations omitted.) 35 Appellants argue that none of these conditions are present here. | 5 | 2009–2016 |
Williams v. Montgomery County
green
2 sentences2006In Williams v. Montgomery County, 123 Md.App. 119, 134 , 716 A.2d 1100 (1998), this Court specifically rejected ignorance of the statutory notice requirement as good cause. 16 . 2006In Williams v. Montgomery County, 123 Md.App. 119, 134 , 716 A.2d 1100 (1998), this Court specifically rejected ignorance of the statutory notice requirement as good cause. 16 . | 3 | 2004–2006 |
Faulk v. Ewing
green
2 sentences2011Faulk, 371 Md. at 304 , 808 A.2d at 1276 ; Grubbs v. Prince George’s County, 267 Md. 318, 320-21 , 297 A.2d 754, 755-56 (1972) (stating “we have regarded it [the predecessor statute to the LGTCA, Md.Code (1957, 1972 RepLVoL), Art. 57, § 18] as a condition precedent to the right to maintain an action for damages”); see also Neuenschwander v. Washington Suburban Sanitary Comm’n, 187 Md. 67, 77 , 48 A.2d 593, 599 (1946) (stating that “the notice is a condition precedent to the right to maintain the suit”), overruled on other grounds by statute as stated in Arnold v. Prince George’s County, 270 Md 2011Faulk, 371 Md. at 304 , 808 A.2d at 1276 ; Grubbs v. Prince George’s County, 267 Md. 318, 320-21 , 297 A.2d 754, 755-56 (1972) (stating “we have regarded it [the predecessor statute to the LGTCA, Md.Code (1957, 1972 RepLVoL), Art. 57, § 18] as a condition precedent to the right to maintain an action for damages”); see also Neuenschwander v. Washington Suburban Sanitary Comm’n, 187 Md. 67, 77 , 48 A.2d 593, 599 (1946) (stating that “the notice is a condition precedent to the right to maintain the suit”), overruled on other grounds by statute as stated in Arnold v. Prince George’s County, 270 Md | 2 | 2005–2011 |
Bell v. County of Camden
green
2 sentences2005Ctr., 140 N.J.Super. 323 , 356 A.2d 75 (1976); and ignorance of the statutory notice requirement, see, e.g., Bell v. Camden County, 147 N.J.Super. 139 , 370 A.2d 886 (1977). 2005Ctr., 140 N.J.Super. 323 , 356 A.2d 75 (1976); and ignorance of the statutory notice requirement, see, e.g., Bell v. Camden County, 147 N.J.Super. 139 , 370 A.2d 886 (1977). | 2 | 2000–2005 |
Torres v. Jersey City Medical Center
green
2 sentences2005Ctr., 140 N.J.Super. 323 , 356 A.2d 75 (1976); and ignorance of the statutory notice requirement, see, e.g., Bell v. Camden County, 147 N.J.Super. 139 , 370 A.2d 886 (1977). 2005Ctr., 140 N.J.Super. 323 , 356 A.2d 75 (1976); and ignorance of the statutory notice requirement, see, e.g., Bell v. Camden County, 147 N.J.Super. 139 , 370 A.2d 886 (1977). | 2 | 2000–2005 |
Westfarm Associates Limited Partnership v. Washington Suburban Sanitary Commission
green
1 sentence2011They are “ ‘excusable neglect or mistake (generally determined in reference to a reasonably prudent person standard), serious physical or mental injury and/or location out-of-state, the inability to retain counsel in cases involving complex litigation, and ignorance of the statutory notice requirement.’ ” Id. (quoting Heron, at 272, 761 A.2d 56 ) (citations omitted). | 1 | 2011–2011 |
Kleinke v. City of Ocean City
green
2 sentences2011Kleinke v. Ocean City, 147 N.J.Super. 575 , 371 A.2d 785 (N.J.Super.App.Div.1977); serious physical or mental injury and/or location out-of-state; the inability to retain counsel in cases involving complex litigation; and ignorance of the statutory notice requirement. ..." Heron, 361 Md. at 272-73 , 761 A.2d at 63-64 (citations omitted). 2011Kleinke v. Ocean City, 147 N.J.Super. 575 , 371 A.2d 785 (N.J.Super.App.Div.1977); serious physical or mental injury and/or location out-of-state; the inability to retain counsel in cases involving complex litigation; and ignorance of the statutory notice requirement. ..." Heron, 361 Md. at 272-73 , 761 A.2d at 63-64 (citations omitted). | 1 | 2011–2011 |
Whittlesey v. State
green
2 sentences2010The State’s Attorney’s Office for Washington County represented that it is that office’s practice to make personal service of the notice upon the defendant even if the defendant is represented by counsel. 3 *493 Although it is clear that oral notice is insufficient, Gorge v. State, 386 Md. 600, 613 , 873 A.2d 1171 (2005), and timely notice is essential, Hammersla v. State, 184 Md.App. 295, 313 , 965 A.2d 912 (2009), the discussion in Whittlesey v. State, 340 Md. 30, 83 , 665 A.2d 223 (1995), suggests that service upon counsel of record in accordance with Maryland Rule 1-321 (a) would satisfy t 2010The State’s Attorney’s Office for Washington County represented that it is that office’s practice to make personal service of the notice upon the defendant even if the defendant is represented by counsel. 3 *493 Although it is clear that oral notice is insufficient, Gorge v. State, 386 Md. 600, 613 , 873 A.2d 1171 (2005), and timely notice is essential, Hammersla v. State, 184 Md.App. 295, 313 , 965 A.2d 912 (2009), the discussion in Whittlesey v. State, 340 Md. 30, 83 , 665 A.2d 223 (1995), suggests that service upon counsel of record in accordance with Maryland Rule 1-321 (a) would satisfy t | 1 | 2010–2010 |
Hammersla v. State
green
2 sentences2010The State’s Attorney’s Office for Washington County represented that it is that office’s practice to make personal service of the notice upon the defendant even if the defendant is represented by counsel. 3 *493 Although it is clear that oral notice is insufficient, Gorge v. State, 386 Md. 600, 613 , 873 A.2d 1171 (2005), and timely notice is essential, Hammersla v. State, 184 Md.App. 295, 313 , 965 A.2d 912 (2009), the discussion in Whittlesey v. State, 340 Md. 30, 83 , 665 A.2d 223 (1995), suggests that service upon counsel of record in accordance with Maryland Rule 1-321 (a) would satisfy t 2010The State’s Attorney’s Office for Washington County represented that it is that office’s practice to make personal service of the notice upon the defendant even if the defendant is represented by counsel. 3 *493 Although it is clear that oral notice is insufficient, Gorge v. State, 386 Md. 600, 613 , 873 A.2d 1171 (2005), and timely notice is essential, Hammersla v. State, 184 Md.App. 295, 313 , 965 A.2d 912 (2009), the discussion in Whittlesey v. State, 340 Md. 30, 83 , 665 A.2d 223 (1995), suggests that service upon counsel of record in accordance with Maryland Rule 1-321 (a) would satisfy t | 1 | 2010–2010 |
Gorge v. State
green
2 sentences2010The State’s Attorney’s Office for Washington County represented that it is that office’s practice to make personal service of the notice upon the defendant even if the defendant is represented by counsel. 3 *493 Although it is clear that oral notice is insufficient, Gorge v. State, 386 Md. 600, 613 , 873 A.2d 1171 (2005), and timely notice is essential, Hammersla v. State, 184 Md.App. 295, 313 , 965 A.2d 912 (2009), the discussion in Whittlesey v. State, 340 Md. 30, 83 , 665 A.2d 223 (1995), suggests that service upon counsel of record in accordance with Maryland Rule 1-321 (a) would satisfy t 2010The State’s Attorney’s Office for Washington County represented that it is that office’s practice to make personal service of the notice upon the defendant even if the defendant is represented by counsel. 3 *493 Although it is clear that oral notice is insufficient, Gorge v. State, 386 Md. 600, 613 , 873 A.2d 1171 (2005), and timely notice is essential, Hammersla v. State, 184 Md.App. 295, 313 , 965 A.2d 912 (2009), the discussion in Whittlesey v. State, 340 Md. 30, 83 , 665 A.2d 223 (1995), suggests that service upon counsel of record in accordance with Maryland Rule 1-321 (a) would satisfy t | 1 | 2010–2010 |
Hargrove v. Mayor and City Council of Baltimore
green
2 sentences2004In a footnote in Heron, 361 Md. at 272 n. 13, 761 A.2d 56 , the Heron Court cited our decision in Williams v. Montgomery County, 123 Md.App. 119 , 716 A.2d 1100 (1998), for the proposition that this Court “has specifically rejected ignorance of the law requiring notice as good cause.” Thereafter, in Hargrove, 146 Md.App. at 467 , 807 A.2d 149 , we discussed Heron , noting that the Heron Court “reaffirmed that Maryland has specifically rejected the ignorance of the law requirement as good cause.” In the consolidated case of Moore v. Norouzi, 371 Md. at 159, 807 A.2d 632 , the claimants were inj 2004In a footnote in Heron, 361 Md. at 272 n. 13, 761 A.2d 56 , the Heron Court cited our decision in Williams v. Montgomery County, 123 Md.App. 119 , 716 A.2d 1100 (1998), for the proposition that this Court “has specifically rejected ignorance of the law requiring notice as good cause.” Thereafter, in Hargrove, 146 Md.App. at 467 , 807 A.2d 149 , we discussed Heron , noting that the Heron Court “reaffirmed that Maryland has specifically rejected the ignorance of the law requirement as good cause.” In the consolidated case of Moore v. Norouzi, 371 Md. at 159, 807 A.2d 632 , the claimants were inj | 1 | 2004–2004 |
Friolo v. Frankel
green
2 sentences2003For a recent opinion of this Court setting forth standards for the awards of attorney fees under fee shifting statutes, see Friolo v. Frankel, 373 Md. 501 , 819 A.2d 354 (2003). 2003For a recent opinion of this Court setting forth standards for the awards of attorney fees under fee shifting statutes, see Friolo v. Frankel, 373 Md. 501 , 819 A.2d 354 (2003). | 1 | 2003–2003 |
Keller v. County of Somerset
green
2 sentences2000Ctr., 140 N.J.Super. 323 , 356 A.2d 75 (Law Div.1976); and ignorance of the statutory notice requirement, 13 see, e.g., Bell v. Camden County, 147 N.J.Super. 139 , 370 A.2d 886 (App.Div.1977); Keller v. Somerset County, 137 N.J.Super. 1 , 347 A.2d 529 (App.Div.1975). 2000Ctr., 140 N.J.Super. 323 , 356 A.2d 75 (Law Div.1976); and ignorance of the statutory notice requirement, 13 see, e.g., Bell v. Camden County, 147 N.J.Super. 139 , 370 A.2d 886 (App.Div.1977); Keller v. Somerset County, 137 N.J.Super. 1 , 347 A.2d 529 (App.Div.1975). | 1 | 2000–2000 |
Counted by distinct opinions that both name this issue and are annotated to the section; sections every opinion cites regardless of issue are not filtered here, so read the counts against the total above.
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.