premises exception (Maryland) · Go Syfert
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premises exception in Maryland

19 Maryland opinions name it 2 courts 1969–2025 2 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 (6)

CaseFollowedCited
Kiriakos v. Phillips Dankos v. Stapfgreen
md · 2016 · cited in 3 Maryland opinions naming this issue, 2016–2025
2 sentences

2025See, e.g., Kiriakos, 448 Md. at 468 (“[U]pon a finding that the social host defendant knowingly and willfully allowed a member of the protected class to consume alcohol on the host’s premises in violation of the statute, in an action against the social host brought by or on behalf of the minor or, as in the Kiriakos case, by an injured third party, such conduct—if it substantially contributed to a diminution of the underaged person’s ability to act in a reasonable manner, and thereby caused injury—can be found to be a substantial factor in bringing about the harm to the underage person himself

2025See, e.g., Kiriakos, 448 Md. at 468 (“[U]pon a finding that the social host defendant knowingly and willfully allowed a member of the protected class to consume alcohol on the host’s premises in violation of the statute, in an action against the social host brought by or on behalf of the minor or, as in the Kiriakos case, by an injured third party, such conduct—if it substantially contributed to a diminution of the underaged person’s ability to act in a reasonable manner, and thereby caused injury—can be found to be a substantial factor in bringing about the harm to the underage person himself

33
Ross v. Housing Authoritygreen
md · 2013 · cited in 2 Maryland opinions naming this issue, 2025–2025
2 sentences

2025See, e.g., Kiriakos, 448 Md. at 468 (“[U]pon a finding that the social host defendant knowingly and willfully allowed a member of the protected class to consume alcohol on the host’s premises in violation of the statute, in an action against the social host brought by or on behalf of the minor or, as in the Kiriakos case, by an injured third party, such conduct—if it substantially contributed to a diminution of the underaged person’s ability to act in a reasonable manner, and thereby caused injury—can be found to be a substantial factor in bringing about the harm to the underage person himself

2025See, e.g., Kiriakos, 448 Md. at 468 (“[U]pon a finding that the social host defendant knowingly and willfully allowed a member of the protected class to consume alcohol on the host’s premises in violation of the statute, in an action against the social host brought by or on behalf of the minor or, as in the Kiriakos case, by an injured third party, such conduct—if it substantially contributed to a diminution of the underaged person’s ability to act in a reasonable manner, and thereby caused injury—can be found to be a substantial factor in bringing about the harm to the underage person himself

22
Eagle-Picher Industries, Inc. v. Balbosgreen
md · 1992 · cited in 1 Maryland opinions naming this issue, 2016–2016
2 sentences

2016See EaglePicher Indus., Inc. v. Balbos, 326 Md. 179, 208-09 , 604 A.2d 445 (1992) (enunciating substantial-factor causation rule).

2016See EaglePicher Indus., Inc. v. Balbos, 326 Md. 179, 208-09 , 604 A.2d 445 (1992) (enunciating substantial-factor causation rule).

11
Union Mutual Fire Insurance v. Joerggreen
vt · 2003 · cited in 1 Maryland opinions naming this issue, 2005–2005
2 sentences

2005Of the courts following this approach, most that have denied subrogation have done so because of the existence of specific provisions in the lease, such as a provision obligating the landlord to purchase fire insurance on the premises or a clause excepting fire damage from the tenant’s responsibility to maintain or return the property in a good state and condition.” Id. at 589-90.

2005The holding of the Vermont court was that “where the lease requires the landlord to carry fire insurance on the leased premises, such insurance is for the mutual benefit of landlord and tenant, and, as such, the tenant is deemed a coinsured under the landlord’s insurance policy and is protected against subrogation claims by the landlord’s insurer.” Id. at 591.

11
Jaeger Baking Co. v. Kretschmanngreen
wis · 1980 · cited in 1 Maryland opinions naming this issue, 2001–2001
2 sentences

2001Indeed, “ ‘by establishing or sponsoring a parking lot not contiguous to the working premises, the employer has created the necessity for encountering hazards lying between these two portions of the premises.’ ” Jaeger Baking Co. v. Kretschmann, 96 Wis.2d 590 , 292 N.W.2d 622, 628 (1980) (quoting 1 Larson, Worker’s Compensation Law § 15.12 (1978)).

2001Indeed, “ ‘by establishing or sponsoring a parking lot not contiguous to the working premises, the employer has created the necessity for encountering hazards lying between these two portions of the premises.’ ” Jaeger Baking Co. v. Kretschmann, 96 Wis.2d 590 , 292 N.W.2d 622, 628 (1980) (quoting 1 Larson, Worker’s Compensation Law § 15.12 (1978)).

11
Citaramanis v. Hallowellgreen
md · 1992 · cited in 1 Maryland opinions naming this issue, 1998–1998
2 sentences

1998See id. at 149-50 , 613 A.2d 964 .

1998See id. at 149-50 , 613 A.2d 964 .

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 (15)

CaseCitedYears
Rogers v. Home Equity USA, Inc. green
md · 2017
2 sentences

2025More recently, in Rogers v. Home Equity USA, Inc., we provided a roadmap for determining whether a plaintiff’s injury is causally connected to the specific property owned by the defendant. 453 Md. 251 .

2025More recently, in Rogers v. Home Equity USA, Inc., we provided a roadmap for determining whether a plaintiff’s injury is causally connected to the specific property owned by the defendant. 453 Md. 251 .

22025–2025
Mancusi v. DeForte green
scotus · 1968
2 sentences

2011In Mancusi v. De Forte, 392 U.S. 364 [ 88 S.Ct. 2120 , 20 L.Ed.2d 1154 ] (1968), the U.S. Supreme Court held that a union official had standing to object to a search of the offices where he worked even though it was an office shared by several union officials and even though the defendant did not claim the records were seized from an area set aside for his personal use.

2011In Mancusi v. De Forte, 392 U.S. 364 [ 88 S.Ct. 2120 , 20 L.Ed.2d 1154 ] (1968), the U.S. Supreme Court held that a union official had standing to object to a search of the offices where he worked even though it was an office shared by several union officials and even though the defendant did not claim the records were seized from an area set aside for his personal use.

21975–2011
Wiley Manufacturing Co. v. Wilson green
md · 1977
2 sentences

2001The premises exception “is usually invoked where the employee is injured while traveling along or across a public road between two portions of his employer’s premises, whether going or coming, or pursuing the actual duties of his employment.” Wiley, 280 Md. at 206 , 373 A.2d 613 .

2001The premises exception “is usually invoked where the employee is injured while traveling along or across a public road between two portions of his employer’s premises, whether going or coming, or pursuing the actual duties of his employment.” Wiley, 280 Md. at 206 , 373 A.2d 613 .

21984–2001
Ryan v. Kasaskeris green
mdctspecapp · 1977
2 sentences

1992These exceptions may be stated as follows: (a) The free transportation exception (b) The employer conveyance exception (c) The premises exception (d) The proximity or special hazard exception. *199 A. Free transportation exception We addressed this exception in Ryan v. Kasaskeris, 38 Md.App. 317, 328-29 , 381 A.2d 294 (1977) (emphasis added). [I]n terms of the “free transportation” exception to the “going and coming” rule, an injury occurring while an employee is on his way to or from work, which otherwise would be noncompensable as being the result of normal hazards unconnected with the emplo

1992These exceptions may be stated as follows: (a) The free transportation exception (b) The employer conveyance exception (c) The premises exception (d) The proximity or special hazard exception. *199 A. Free transportation exception We addressed this exception in Ryan v. Kasaskeris, 38 Md.App. 317, 328-29 , 381 A.2d 294 (1977) (emphasis added). [I]n terms of the “free transportation” exception to the “going and coming” rule, an injury occurring while an employee is on his way to or from work, which otherwise would be noncompensable as being the result of normal hazards unconnected with the emplo

21980–1992
Proctor-Silex Corp. v. DeBrick green
md · 1969
2 sentences

1970While this statutory language does not necessarily enunciate the fine distinctions implicit in the going and coming rule, it does point to a relationship which we have recognized between the work plant and the premises around the plant. 1 *609 In Proctor-Silex v. DeBrick, 253 Md. 477 , 252 A. 2d 800 (1969) Judge Smith for this Court exhaustively reviewed the Maryland cases and a number of leading cases from other jurisdictions involving the premises rule.

1970While this statutory language does not necessarily enunciate the fine distinctions implicit in the going and coming rule, it does point to a relationship which we have recognized between the work plant and the premises around the plant. 1 *609 In Proctor-Silex v. DeBrick, 253 Md. 477 , 252 A. 2d 800 (1969) Judge Smith for this Court exhaustively reviewed the Maryland cases and a number of leading cases from other jurisdictions involving the premises rule.

21970–1984
Board of Trustees of the Employees' Retirement System v. Novik green
md · 1992
2 sentences

2010Rejecting that argument, the Court quoted Police Comm’r v. King, 219 Md. 127, 134-35 , 148 A.2d 562 (1959), to demonstrate that prior decisions of the Court of Appeals had “ ‘recognized a striking analogy between the terms “in the actual performance of duty” and “out of and in the course of his employment.” ’ ” Novik, 326 Md. at 457 , 605 A.2d 145 .

2010Rejecting that argument, the Court quoted Police Comm’r v. King, 219 Md. 127, 134-35 , 148 A.2d 562 (1959), to demonstrate that prior decisions of the Court of Appeals had “ ‘recognized a striking analogy between the terms “in the actual performance of duty” and “out of and in the course of his employment.” ’ ” Novik, 326 Md. at 457 , 605 A.2d 145 .

12010–2010
Police Commissioner v. King green
md · 1959
2 sentences

2010Rejecting that argument, the Court quoted Police Comm’r v. King, 219 Md. 127, 134-35 , 148 A.2d 562 (1959), to demonstrate that prior decisions of the Court of Appeals had “ ‘recognized a striking analogy between the terms “in the actual performance of duty” and “out of and in the course of his employment.” ’ ” Novik, 326 Md. at 457 , 605 A.2d 145 .

2010Rejecting that argument, the Court quoted Police Comm’r v. King, 219 Md. 127, 134-35 , 148 A.2d 562 (1959), to demonstrate that prior decisions of the Court of Appeals had “ ‘recognized a striking analogy between the terms “in the actual performance of duty” and “out of and in the course of his employment.” ’ ” Novik, 326 Md. at 457 , 605 A.2d 145 .

12010–2010
Scott v. Watson green
md · 1976
2 sentences

2002We find to be absolutely dispositive the opinion of Chief Judge Murphy for the Court of Appeals in Scott v. Watson, 278 Md. 160 , 359 A.2d 548 (1976).

2002We find to be absolutely dispositive the opinion of Chief Judge Murphy for the Court of Appeals in Scott v. Watson, 278 Md. 160 , 359 A.2d 548 (1976).

12002–2002
Saylor v. Black & Decker Manufacturing Co. green
md · 1970
2 sentences

1998The only exceptions at issue in this case are the second and third, the “premises” exception and the “proximity” or “special hazard exception.” *533 Under the premises exception, although the notion of “premises” does not necessarily include all of the property owned by the employer, it does contemplate “compensation for injuries occurring on parking lots provided for the use of the employees,” Saylor, 258 Md. at 609 , 267 A.2d at 88 , and where there is an “integral relationship between the place of injury on the employer’s property and where [the employee] worked.” Furthermore, the employee

1998The only exceptions at issue in this case are the second and third, the “premises” exception and the “proximity” or “special hazard exception.” *533 Under the premises exception, although the notion of “premises” does not necessarily include all of the property owned by the employer, it does contemplate “compensation for injuries occurring on parking lots provided for the use of the employees,” Saylor, 258 Md. at 609 , 267 A.2d at 88 , and where there is an “integral relationship between the place of injury on the employer’s property and where [the employee] worked.” Furthermore, the employee

11998–1998
Board of Trustees v. Novik green
mdctspecapp · 1991
2 sentences

1992Novik was upon her employer’s premises at the time of her accident and, therefore, under the premises exception to the “Going and Coming” rule, was in the “actual performance of duty.” We thus share the view of the Court of Special Appeals that, in the circumstances of this case, Novik’s accident was “sufficiently incidental to the actual performance of her duties” to justify the award of accidental disability benefits under § 9(j). 87 Md.App. at 315 , 589 A.2d 976 .

1992Novik was upon her employer’s premises at the time of her accident and, therefore, under the premises exception to the “Going and Coming” rule, was in the “actual performance of duty.” We thus share the view of the Court of Special Appeals that, in the circumstances of this case, Novik’s accident was “sufficiently incidental to the actual performance of her duties” to justify the award of accidental disability benefits under § 9(j). 87 Md.App. at 315 , 589 A.2d 976 .

11992–1992
Carter v. M v. Construction Corp. green
mdctspecapp · 1980
2 sentences

1992Premises exception Once again, the Carter court, Carter, 47 Md.App. at 177 , 422 A.2d 44 , cited professor Larson’s work.

1992Premises exception Once again, the Carter court, Carter, 47 Md.App. at 177 , 422 A.2d 44 , cited professor Larson’s work.

11992–1992
Hotel Ass'n of Washington v. District of Columbia Minimum Wage & Industrial Safety Board green
dc · 1974
1 sentence

1980App. 317 , 318 A.2d 294 (1977), we had before us "the free transportation” exception to the "going and coming” rule.

11980–1980
Maryland Paper Products Co. v. Judson green
md · 1958
2 sentences

1972Co., supra. Appellant contends that she is entitled to recover under the proximity rule as enunciated in Schneider, Workmen’s Compensation (1951) Vol. 8, § 1724 which says: “The proximity rule exception to the general going and coming rule is that an employee is generally considered to be in the course of his employment while coming to or going from his work, when, though off the actual premises of his employer, he is still in close proximity thereto, and is proceeding diligently at an appropriate time, by reasonable means, over the natural, practical, customary, convenient and recognized way

1972Co., supra. Appellant contends that she is entitled to recover under the proximity rule as enunciated in Schneider, Workmen’s Compensation (1951) Vol. 8, § 1724 which says: “The proximity rule exception to the general going and coming rule is that an employee is generally considered to be in the course of his employment while coming to or going from his work, when, though off the actual premises of his employer, he is still in close proximity thereto, and is proceeding diligently at an appropriate time, by reasonable means, over the natural, practical, customary, convenient and recognized way

11972–1972
Pariser Bakery & State Accident Fund v. Koontz green
md · 1965
1 sentence

1972Co., supra. Appellant contends that she is entitled to recover under the proximity rule as enunciated in Schneider, Workmen’s Compensation (1951) Vol. 8, § 1724 which says: “The proximity rule exception to the general going and coming rule is that an employee is generally considered to be in the course of his employment while coming to or going from his work, when, though off the actual premises of his employer, he is still in close proximity thereto, and is proceeding diligently at an appropriate time, by reasonable means, over the natural, practical, customary, convenient and recognized way

11972–1972
E. I. Du Pont De Nemours Company, Inc. v. Leo Hall neutral
ca4 · 1956
1 sentence

1969We see no basis upon which it can logically be applied to the area of more than 200,000 acres * * * except as to the limited areas in which work was being carried on.” Id. at 149 .

11969–1969

Where else courts name it

NY 64 (1851–2026) CA 34 (1868–2025) IL 28 (1903–2022) NJ 28 (1940–2026) TX 25 (1921–2024) MD 19 (1969–2025) FL 17 (1933–2016) WY 14 (1963–2018) MI 14 (1885–2016) KS 11 (1934–2009) AR 10 (1959–2009) WA 9 (1931–2025) UT 8 (1912–2019) AZ 8 (1918–1995) OH 7 (1907–2016) PA 7 (1914–2026) TN 7 (1992–2016) LA 7 (1931–2002) MA 7 (1904–2015) MO 6 (1881–2019) CT 6 (1949–2017) WI 5 (1932–2000) NM 5 (1981–1991) MS 5 (1957–2007) OR 5 (1962–2013) MN 5 (1949–2017) ID 5 (1947–2014) NC 5 (1953–2010) VA 4 (1915–1998) DE 4 (1995–2022) OK 4 (1937–2006) AL 3 (1899–1940) DC 3 (1970–2006) GA 3 (1955–1982) IA 3 (1935–1998) NE 3 (1898–2025) AK 3 (1990–1999) ND 3 (2003–2021) KY 2 (1953–1978) RI 2 (1998–2004) MT 2 (1992–2021) SC 2 (1987–2025) VT 2 (1880–1928) NV 2 (1968–1979)

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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