intermediate standard (Maryland) · Go Syfert
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intermediate standard in Maryland

18 Maryland opinions name it 2 courts 1981–2022 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 (11)

CaseFollowedCited
Wills v. Stategreen
md · 1993 · cited in 3 Maryland opinions naming this issue, 1995–2022
2 sentences

2022The “Clear and Convincing” Standard and the General Assembly’s Use of That Standard Elsewhere Our State recognizes “only three standards of proof: ‘[t]he lowest standard requires proof by a “preponderance” of the evidence; the highest standard demands proof “beyond a reasonable doubt;” an intermediate standard calls for proof that is “clear and convincing.”’” Urban Site Venture II Ltd. v. Levering Assocs., 340 Md. 223, 228 (1995) (alteration in original) (quoting Wills v. State, 329 Md. 370, 374 (1993)).

1995Maryland courts recognize only three standards of proof: “[t]he lowest standard requires proof by a ‘preponderance’ of the evidence; the highest standard demands proof ‘beyond a reasonable doubt;’ an intermediate standard calls for proof that is ‘clear and convincing.’ ” Wills v. State, 329 Md. 370, 373-74 , 620 A.2d 295 (1993).

23
Woodby v. Immigration & Naturalization Servicegreen
scotus · 1966 · cited in 2 Maryland opinions naming this issue, 1981–1993
2 sentences

1993The intermediate standard, which usually employs some combination of the words “clear,” “cogent,” “unequivocal,” and “convincing,” is less commonly used but nonetheless “is no stranger to the civil law.” Woodby v. INS, 385 U.S. 276, 285 [ 87 S.Ct. 483, 488 , 17 L.Ed.2d 362 ] (1966).

1993The intermediate standard, which usually employs some combination of the words “clear,” “cogent,” “unequivocal,” and “convincing,” is less commonly used but nonetheless “is no stranger to the civil law.” Woodby v. INS, 385 U.S. 276, 285 [ 87 S.Ct. 483, 488 , 17 L.Ed.2d 362 ] (1966).

22
Addington v. Texasgreen
scotus · 1979 · cited in 4 Maryland opinions naming this issue, 1988–2019
2 sentences

2019"The intermediate standard, of clear, cogent, or convincing evidence, is used in cases, such as fraud, quasi-criminal wrongdoing, or 'to protect particularly important individual interests in various civil cases' where the interest at stake is 'deemed to be more substantial than mere loss of money.' " Volodarsky , 397 Md. at 305 , 916 A.2d 991 (quoting Addington , 441 U.S. at 424 , 99 S.Ct. 1804 ).

2019"The intermediate standard, of clear, cogent, or convincing evidence, is used in cases, such as fraud, quasi-criminal wrongdoing, or 'to protect particularly important individual interests in various civil cases' where the interest at stake is 'deemed to be more substantial than mere loss of money.' " Volodarsky , 397 Md. at 305 , 916 A.2d 991 (quoting Addington , 441 U.S. at 424 , 99 S.Ct. 1804 ).

14
Santosky v. Kramergreen
scotus · 1982 · cited in 3 Maryland opinions naming this issue, 2002–2007
2 sentences

2003The intermediate standard of clear and convincing evidence is mandated “when the individual interests at stake in a state proceeding are both ‘particularly important’ and ‘more substantial than mere loss of money.’ ” Santosky, 455 U.S. at 756 , 102 S.Ct. at 1396 , 71 L.Ed.2d at 608 (quoting Addington, supra).

2003The intermediate standard of clear and convincing evidence is mandated “when the individual interests at stake in a state proceeding are both ‘particularly important’ and ‘more substantial than mere loss of money.’ ” Santosky, 455 U.S. at 756 , 102 S.Ct. at 1396 , 71 L.Ed.2d at 608 (quoting Addington, supra).

13
Mathews v. Eldridgegreen
scotus · 1976 · cited in 2 Maryland opinions naming this issue, 2002–2007
2 sentences

2007See also Mathews v. Eldridge, 424 U.S. 319 , 96 S.Ct. 893 , 47 L.Ed.2d 18 (1976); Santosky v. Kramer, 455 U.S. 745, 754-55 , 102 S.Ct. 1388, 1395-96 , 71 L.Ed.2d 599, 607 (1982).

2007See also Mathews v. Eldridge, 424 U.S. 319 , 96 S.Ct. 893 , 47 L.Ed.2d 18 (1976); Santosky v. Kramer, 455 U.S. 745, 754-55 , 102 S.Ct. 1388, 1395-96 , 71 L.Ed.2d 599, 607 (1982).

12
Weisman v. Connorsgreen
mdctspecapp · 1988 · cited in 2 Maryland opinions naming this issue, 2000–2002
2 sentences

2002See also Wills v. State, 329 Md. 370, 374 , 620 A.2d 295, 297 (1993) (noting that the terms “preponderance,” “clear and convincing,” and “reasonable doubt” are not “at least in their legal sense, street familiar”); Weisman v. Connors, 76 Md.App. 488, 503 , 547 A.2d 636, 643 (1988) (noting the “amorphous” nature of the clear and convincing standard); Tippett v. Maryland, 436 F.2d 1153, 1158-59 (4th Cir.1971), cert. dismissed, sub nom.

2002See also Wills v. State, 329 Md. 370, 374 , 620 A.2d 295, 297 (1993) (noting that the terms “preponderance,” “clear and convincing,” and “reasonable doubt” are not “at least in their legal sense, street familiar”); Weisman v. Connors, 76 Md.App. 488, 503 , 547 A.2d 636, 643 (1988) (noting the “amorphous” nature of the clear and convincing standard); Tippett v. Maryland, 436 F.2d 1153, 1158-59 (4th Cir.1971), cert. dismissed, sub nom.

12
Urban Site Venture II Ltd. Partnership v. Levering Associates Ltd. Partnershipgreen
md · 1995 · cited in 1 Maryland opinions naming this issue, 2022–2022
1 sentence

2022The “Clear and Convincing” Standard and the General Assembly’s Use of That Standard Elsewhere Our State recognizes “only three standards of proof: ‘[t]he lowest standard requires proof by a “preponderance” of the evidence; the highest standard demands proof “beyond a reasonable doubt;” an intermediate standard calls for proof that is “clear and convincing.”’” Urban Site Venture II Ltd. v. Levering Assocs., 340 Md. 223, 228 (1995) (alteration in original) (quoting Wills v. State, 329 Md. 370, 374 (1993)).

11
Donnelly Advertising Corp. v. Mayor of Baltimoregreen
md · 1977 · cited in 1 Maryland opinions naming this issue, 2021–2021
1 sentence

2021Cf. Donnelly Advertising Corp. of Maryland v. City of Baltimore, 279 Md. 660, 668-70 (1977) (applying intermediate scrutiny and rational basis tests in holding that ordinance requiring removal of all off-premises signs in urban renewal district did not violate First or Fourteenth Amendments). 17 Clear Channel suggests that an owner of a site leased for a billboard may be wary of messages critical of local officials and that, some years ago, City officials might have been unhappy about a billboard advertisement purchased by a public employees’ union that was critical of the City government at t

11
Pitney-Bowes, Inc. v. Mestregreen
flsd · 1980 · cited in 1 Maryland opinions naming this issue, 2002–2002
1 sentence

2002The attorney-client privilege is not absolute and “is not an inviolable seal upon the attorney’s lips.” Pitney-Bowes, Inc. v. Mestre, 86 F.R.D. 444, 446 (S.D.Fl.1980)(citing Laughner v. U.S., 373 F.2d 326, 327 (5th Cir.1967)).

11
Arthur C. Laughner v. United Statesgreen
ca5 · 1967 · cited in 1 Maryland opinions naming this issue, 2002–2002
1 sentence

2002The attorney-client privilege is not absolute and “is not an inviolable seal upon the attorney’s lips.” Pitney-Bowes, Inc. v. Mestre, 86 F.R.D. 444, 446 (S.D.Fl.1980)(citing Laughner v. U.S., 373 F.2d 326, 327 (5th Cir.1967)).

11
cluster 294270green
ca4 · 1971 · cited in 1 Maryland opinions naming this issue, 2002–2002
1 sentence

2002See also Wills v. State, 329 Md. 370, 374 , 620 A.2d 295, 297 (1993) (noting that the terms “preponderance,” “clear and convincing,” and “reasonable doubt” are not “at least in their legal sense, street familiar”); Weisman v. Connors, 76 Md.App. 488, 503 , 547 A.2d 636, 643 (1988) (noting the “amorphous” nature of the clear and convincing standard); Tippett v. Maryland, 436 F.2d 1153, 1158-59 (4th Cir.1971), cert. dismissed, sub nom.

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 (10)

CaseCitedYears
Yorke v. State green
md · 1989
2 sentences

2005As this Court observed in Love v. State, 95 Md.App. 420, 431 , 621 A.2d 910 (1993): In Yorke v. State, 315 Md. 578 , 556 A.2d 230 (1989), however, the Court of Appeals opted to adopt an intermediate standard that fell somewhere between the Berry test and the Larrison test.

2005As this Court observed in Love v. State, 95 Md.App. 420, 431 , 621 A.2d 910 (1993): In Yorke v. State, 315 Md. 578 , 556 A.2d 230 (1989), however, the Court of Appeals opted to adopt an intermediate standard that fell somewhere between the Berry test and the Larrison test.

31993–2005
Volodarsky v. Tarachanskaya green
md · 2007
2 sentences

2019"The intermediate standard, of clear, cogent, or convincing evidence, is used in cases, such as fraud, quasi-criminal wrongdoing, or 'to protect particularly important individual interests in various civil cases' where the interest at stake is 'deemed to be more substantial than mere loss of money.' " Volodarsky , 397 Md. at 305 , 916 A.2d 991 (quoting Addington , 441 U.S. at 424 , 99 S.Ct. 1804 ).

2019"The intermediate standard, of clear, cogent, or convincing evidence, is used in cases, such as fraud, quasi-criminal wrongdoing, or 'to protect particularly important individual interests in various civil cases' where the interest at stake is 'deemed to be more substantial than mere loss of money.' " Volodarsky , 397 Md. at 305 , 916 A.2d 991 (quoting Addington , 441 U.S. at 424 , 99 S.Ct. 1804 ).

12019–2019
Bowers v. State green
md · 1990
2 sentences

2005Ironically, that language from a newly discovered evidence case is the very language that Bowers v. State, 320 Md. 416, 427 , 578 A.2d 734 (1990), would adopt for measuring prejudice in ineffective assistance of counsel cases and that State v. Thomas, 325 Md. 160 , 190 n. 8, 599 A.2d 1171 (1992), would adopt for measuring Brady materiality. 4 .

2005Ironically, that language from a newly discovered evidence case is the very language that Bowers v. State, 320 Md. 416, 427 , 578 A.2d 734 (1990), would adopt for measuring prejudice in ineffective assistance of counsel cases and that State v. Thomas, 325 Md. 160 , 190 n. 8, 599 A.2d 1171 (1992), would adopt for measuring Brady materiality. 4 .

12005–2005
State v. Thomas green
md · 1992
2 sentences

2005Ironically, that language from a newly discovered evidence case is the very language that Bowers v. State, 320 Md. 416, 427 , 578 A.2d 734 (1990), would adopt for measuring prejudice in ineffective assistance of counsel cases and that State v. Thomas, 325 Md. 160 , 190 n. 8, 599 A.2d 1171 (1992), would adopt for measuring Brady materiality. 4 .

2005Ironically, that language from a newly discovered evidence case is the very language that Bowers v. State, 320 Md. 416, 427 , 578 A.2d 734 (1990), would adopt for measuring prejudice in ineffective assistance of counsel cases and that State v. Thomas, 325 Md. 160 , 190 n. 8, 599 A.2d 1171 (1992), would adopt for measuring Brady materiality. 4 .

12005–2005
Love v. State green
mdctspecapp · 1993
2 sentences

2005As this Court observed in Love v. State, 95 Md.App. 420, 431 , 621 A.2d 910 (1993): In Yorke v. State, 315 Md. 578 , 556 A.2d 230 (1989), however, the Court of Appeals opted to adopt an intermediate standard that fell somewhere between the Berry test and the Larrison test.

2005As this Court observed in Love v. State, 95 Md.App. 420, 431 , 621 A.2d 910 (1993): In Yorke v. State, 315 Md. 578 , 556 A.2d 230 (1989), however, the Court of Appeals opted to adopt an intermediate standard that fell somewhere between the Berry test and the Larrison test.

12005–2005
Elkton Care Center Associates Ltd. Partnership v. Quality Care Management, Inc. green
mdctspecapp · 2002
2 sentences

2003As we stated in that opinion, under the intermediate test, the court makes a “fact specific case-by-case analysis to determine whether the privilege has been waived.” Id. at 545 , 805 A.2d 1177 .

2003As we stated in that opinion, under the intermediate test, the court makes a “fact specific case-by-case analysis to determine whether the privilege has been waived.” Id. at 545 , 805 A.2d 1177 .

12003–2003
Scott J. Hoffman, an Incompetent Person, by Harriet Hoffman, the Conservator of His Person and Estate v. United States green
ca9 · 1985
2 sentences

1990The court seemed to rely heavily on an Eighth Circuit case 20 in which that court chose not to apply heightened scrutiny to a statute that placed a six-year statute of limitations on malpractice actions except when foreign bodies unintentionally left in the body cause injury or death “because the case involved none of the classifications to which the Supreme Court has applied an intermediate test (illegitimacy or gender).” Hoffman, 767 F.2d at 1436 .

1990The Hoffman court then stated, Finding that [the cap] does not involve any suspect or quasi-suspect classification, a fundamental right, or a classification requiring a heightened scrutiny, we conclude that the proper level of scrutiny is the rational basis test. *158 Id.

11990–1990
Cox v. Tayman neutral
md · 1943
2 sentences

1988Weisman notes other cases requiring the evidence to be “clear,” “precise,” and even “indubitable.” See, for example, Gingell v. Backus, 246 Md. at 90 , 227 A.2d 349 ; Cox v. Tayman, 182 Md. at 80 , 32 A.2d 368 .

1988Weisman notes other cases requiring the evidence to be “clear,” “precise,” and even “indubitable.” See, for example, Gingell v. Backus, 246 Md. at 90 , 227 A.2d 349 ; Cox v. Tayman, 182 Md. at 80 , 32 A.2d 368 .

11988–1988
GINGELL, T/A ROCKVILLE CRANE RENTAL COMPANY v. Backus green
md · 1967
2 sentences

1988Weisman notes other cases requiring the evidence to be “clear,” “precise,” and even “indubitable.” See, for example, Gingell v. Backus, 246 Md. at 90 , 227 A.2d 349 ; Cox v. Tayman, 182 Md. at 80 , 32 A.2d 368 .

1988Weisman notes other cases requiring the evidence to be “clear,” “precise,” and even “indubitable.” See, for example, Gingell v. Backus, 246 Md. at 90 , 227 A.2d 349 ; Cox v. Tayman, 182 Md. at 80 , 32 A.2d 368 .

11988–1988
American Radio-Telephone Service, Inc. v. Public Service Commission green
mdctspecapp · 1976
1 sentence

1982The events following remand were detailed in this Court’s opinion in American Radio-Telephone Service, Inc. v. Public Service Commission of Maryland, 33 Md.

11982–1982

Statutes the citing opinions construe

MD § Md. Code Ann., Fam. Law § 9-101 (3)

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.

Where else courts name it

TX 532 (1981–2026) PA 54 (1978–2025) CA 45 (1978–2026) UT 45 (1930–2025) IL 45 (1986–2024) LA 43 (1920–2020) ND 39 (1974–2018) IN 39 (1888–2026) WA 28 (1917–2026) OH 28 (1992–2021) GA 24 (1993–2026) DE 23 (1980–2026) CT 22 (1985–2025) KS 22 (1987–2024) CO 21 (1982–2003) MD 18 (1981–2022) NC 17 (1984–2025) NJ 16 (1972–2017) FL 14 (1963–2018) ID 14 (1982–1999) NY 13 (1949–2025) OK 11 (1980–2024) HI 10 (1996–2025) TN 9 (1959–2010) WI 8 (1996–2020) OR 8 (1983–2020) NM 7 (1988–2023) AZ 7 (1988–2011) ME 6 (1984–2015) DC 6 (1978–1997) IA 6 (2009–2023) SC 5 (1996–2022) MI 5 (1978–2015) MO 4 (1980–2016) KY 3 (1954–2010) WV 3 (1995–2024) VA 3 (1995–2004) MA 3 (1975–1990) VI 2 (2013–2026) MN 2 (1987–2011) SD 2 (1991–1993) MS 2 (1984–2013) MT 2 (1995–2005) NV 2 (2020–2020)

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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