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

17 Maryland opinions name it 2 courts 1908–2014 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.

Followed or applied (12)

CaseFollowedCited
Mathews v. Eldridgegreen
scotus · 1976 · cited in 2 Maryland opinions naming this issue, 2006–2011
2 sentences

2011See Mathews v. Eldridge, 424 U.S. 319, 333 , 96 S.Ct. 893, 902 , 47 L.Ed.2d 18 (1976).

2011See Mathews v. Eldridge, 424 U.S. 319, 333 , 96 S.Ct. 893, 902 , 47 L.Ed.2d 18 (1976).

22
Faber v. Wolfegreen
mdctspecapp · 1979 · cited in 2 Maryland opinions naming this issue, 1987–1999
2 sentences

1999See Faber v. Wolfe, 41 Md.App. 458 , 397 A.2d 270 (1979), holding that an oral exception must be reduced to writing within a “reasonable time.” Compare Thomas v. Ford, supra, 63 Md. [346] at 348 [(1885)].

1999See Faber v. Wolfe, 41 Md.App. 458 , 397 A.2d 270 (1979), holding that an oral exception must be reduced to writing within a “reasonable time.” Compare Thomas v. Ford, supra, 63 Md. [346] at 348 [(1885)].

22
Washabaugh v. Washabaughgreen
md · 1979 · cited in 2 Maryland opinions naming this issue, 1987–1999
2 sentences

1999Aware of these problems and taking cognizance of the footnote penned by this Court in Washabaugh [v. Washabaugh], supra, 285 Md. [393] at 399, n. 6, 404 A.2d 1027 [(1979)], the Rules Committee of this Court recommended substantial revision of Rule 510 so that the procedure for taking an in banc appeal would parallel, to. the extent possible, the procedure in taking an appeal to the Court of Special Appeals.

1999Aware of these problems and taking cognizance of the footnote penned by this Court in Washabaugh [v. Washabaugh], supra, 285 Md. [393] at 399, n. 6, 404 A.2d 1027 [(1979)], the Rules Committee of this Court recommended substantial revision of Rule 510 so that the procedure for taking an in banc appeal would parallel, to the extent possible, the procedure in taking an appeal to the Court of Special Appeals.

12
Attorney Grievance Commission v. Gordongreen
md · 2010 · cited in 1 Maryland opinions naming this issue, 2014–2014
2 sentences

2014Att’y Grievance Comm’n v. Gordon, 413 Md. 46, 54-55 , 991 A.2d 51, 56 (2010); see Md.

2014Att’y Grievance Comm’n v. Gordon, 413 Md. 46, 54-55 , 991 A.2d 51, 56 (2010); see Md.

11
ADM Partnership v. Martingreen
md · 1997 · cited in 1 Maryland opinions naming this issue, 2012–2012
2 sentences

2012When Respondent argued that the jury should not consider assumption of the risk because Respondent did not “believe there’s any indication [Respondent] voluntarily chose [to assume the risk],” the trial judge disagreed, stating that whether Respondent assumed the risk of her injuries is “going to be the issue [for the jury to decide].” Additionally, when Petitioner moved for a judgment at the end of Respondent’s case based on assumption of the risk, the trial judge responded that the court would not grant judgment based on the defense, but told Petitioner that “[i]t’s a matter you can argue to

2012When Respondent argued that the jury should not consider assumption of the risk because Respondent did not “believe there’s any indication [Respondent] voluntarily chose [to assume the risk],” the trial judge disagreed, stating that whether Respondent assumed the risk of her injuries is “going to be the issue [for the jury to decide].” Additionally, when Petitioner moved for a judgment at the end of Respondent’s case based on assumption of the risk, the trial judge responded that the court would not grant judgment based on the defense, but told Petitioner that “[i]t’s a matter you can argue to

11
People v. Toolesgreen
ill · 1997 · cited in 1 Maryland opinions naming this issue, 2010–2010
2 sentences

2010See People v. Tooles, 177 Ill.2d 462 , 227 Ill.Dec. 125 , 687 N.E.2d 48, 49-50, 53 (1997) (where statute required that jury trial waiver be “in writing,” court held “that the failure to procure defendants’ written jury waivers does not necessitate reversal of their convictions because the record otherwise evidences that defendants’ jury waivers were understanding^ made”); Loveless v. State, 21 S.W.3d 582, 584 (Tex.App.2000) (where no written jury trial waiver was obtained as required by statute, error was harmless because “there was sufficient evidence of an oral waiver of a jury trial”).

2010See People v. Tooles, 177 Ill.2d 462 , 227 Ill.Dec. 125 , 687 N.E.2d 48, 49-50, 53 (1997) (where statute required that jury trial waiver be “in writing,” court held “that the failure to procure defendants’ written jury waivers does not necessitate reversal of their convictions because the record otherwise evidences that defendants’ jury waivers were understanding^ made”); Loveless v. State, 21 S.W.3d 582, 584 (Tex.App.2000) (where no written jury trial waiver was obtained as required by statute, error was harmless because “there was sufficient evidence of an oral waiver of a jury trial”).

11
Loveless v. Stategreen
texapp · 2000 · cited in 1 Maryland opinions naming this issue, 2010–2010
1 sentence

2010See People v. Tooles, 177 Ill.2d 462 , 227 Ill.Dec. 125 , 687 N.E.2d 48, 49-50, 53 (1997) (where statute required that jury trial waiver be “in writing,” court held “that the failure to procure defendants’ written jury waivers does not necessitate reversal of their convictions because the record otherwise evidences that defendants’ jury waivers were understanding^ made”); Loveless v. State, 21 S.W.3d 582, 584 (Tex.App.2000) (where no written jury trial waiver was obtained as required by statute, error was harmless because “there was sufficient evidence of an oral waiver of a jury trial”).

11
People v. Moslygreen
michctapp · 2003 · cited in 1 Maryland opinions naming this issue, 2010–2010
2 sentences

2010In Mosly , the appellate court determined that the trial court's failure to *284 conduct an oral waiver colloquy on the record did not require reversal because "the record establish[ed] that defendant nonetheless understood that he had a right to a trial by jury and voluntarily chose to waive that right." Id. at 901.

2010In Mosly , the appellate court determined that the trial court’s failure to conduct an oral waiver colloquy on the record did not require reversal because “the record establish[ed] that defendant nonetheless understood that he had a right to a trial by jury and voluntarily chose to waive that right.” Id. at 901.

11
Monumental Health Plan, Inc. v. Department of Health & Human Servicesgreen
mdd · 1981 · cited in 1 Maryland opinions naming this issue, 1996–1996
1 sentence

1996Ass’n, 496 F.2d 174, 178 (4th Cir.1974), even if she was not afforded an oral hearing (and we do not so hold), it does not necessarily mean that she was denied due process, Monumental Health Plan, Inc. v. Department of Health & Human Servs., 510 F.Supp. 244, 248 (D.Md.1981). *26 Though the opportunity to be heard is commonly considered a procedural right, its denial vel non must be determined “by the substance of things, and not by mere form.” Simon v. Craft, 182 U.S. 427, 436 , 21 S.Ct. 836, 839 , 45 L.Ed. 1165 (1901).

11
Stuart M. Christhilf, Jr., M.D. v. The Annapolis Emergency Hospital Association, Inc.green
ca4 · 1974 · cited in 1 Maryland opinions naming this issue, 1996–1996
1 sentence

1996Ass’n, 496 F.2d 174, 178 (4th Cir.1974), even if she was not afforded an oral hearing (and we do not so hold), it does not necessarily mean that she was denied due process, Monumental Health Plan, Inc. v. Department of Health & Human Servs., 510 F.Supp. 244, 248 (D.Md.1981). *26 Though the opportunity to be heard is commonly considered a procedural right, its denial vel non must be determined “by the substance of things, and not by mere form.” Simon v. Craft, 182 U.S. 427, 436 , 21 S.Ct. 836, 839 , 45 L.Ed. 1165 (1901).

11
Phillips v. Venkergreen
md · 1989 · cited in 1 Maryland opinions naming this issue, 1994–1994
2 sentences

1994See Venker, 316 Md. at 217 , 557 A.2d 1338 .

1994See Venker, 316 Md. at 217 , 557 A.2d 1338 .

11
Thomas v. Fordgreen
md · 1885 · cited in 1 Maryland opinions naming this issue, 1987–1987
2 sentences

1987See Faber v. Wolfe, 41 Md.App. 458 , 397 A.2d 270 (1979), holding that an oral exception must be reduced to writing within a “reasonable time.” Compare Thomas v. Ford, supra, 63 Md. at 348 .

1987App. 458 , 397 A.2d 270 (1979), holding that an oral exception must be reduced to writing within a "reasonable time." Compare Thomas v. Ford, supra, 63 Md. at 348 .

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 (11)

CaseCitedYears
Bull Steamship Lines v. Fisher green
md · 1950
2 sentences

2001Maryland Rule 554 c provides that: “An oral instruction need not comply with the technical rules as to prayers.” Judge Morris A. Soper, one of the most eminent and distinguished jurists of our time, in discussing Maryland Rule 554 said: “Nor will it be too difficult for the judge * * * to state the law of the case in plain and simple terms far more helpful and intelligible to the jury than the technical, hypothetical and sometimes verbose instructions with which for the past century Maryland jurors have been served. * * * The jury will more easily understand and more readily apply the rules of

2001Maryland Rule 554 c provides that: “An oral instruction need not comply with the technical rules as to prayers.” Judge Morris A. Soper, one of the most eminent and distinguished jurists of our time, in discussing Maryland Rule 554 said: “Nor will it be too difficult for the judge * * * to state the law of the case in plain and simple terms far more helpful and intelligible to the jury than the technical, hypothetical and sometimes verbose instructions with which for the past century Maryland jurors have been served. * * * The jury will more easily understand and more readily apply the rules of

21964–2001
West v. Belle Isle Cab Co. green
md · 2001
2 sentences

2001Maryland Rule 554 c provides that: “An oral instruction need not comply with the technical rules as to prayers.” Judge Morris A. Soper, one of the most eminent and distinguished jurists of our time, in discussing Maryland Rule 554 said: “Nor will it be too difficult for the judge * * * to state the law of the case in plain and simple terms far more helpful and intelligible to the jury than the technical, hypothetical and sometimes verbose instructions with which for the past century Maryland jurors have been served. * * * The jury will more easily understand and more readily apply the rules of

2001Maryland Rule 554 c provides that: “An oral instruction need not comply with the technical rules as to prayers.” Judge Morris A. Soper, one of the most eminent and distinguished jurists of our time, in discussing Maryland Rule 554 said: “Nor will it be too difficult for the judge * * * to state the law of the case in plain and simple terms far more helpful and intelligible to the jury than the technical, hypothetical and sometimes verbose instructions with which for the past century Maryland jurors have been served. * * * The jury will more easily understand and more readily apply the rules of

21964–2001
Davis v. United States green
scotus · 1994
2 sentences

2011According to the State, the officer was permitted under Davis v. United States, 512 U.S. 452 , 114 S.Ct. 2350 , 129 L.Ed.2d 362 (1994), to ask clarifying questions to an ambiguous response and to confirm that appellant understood his Spanish when appellant was asked to complete the Advice of Rights form.

2011According to the State, the officer was permitted under Davis v. United States, 512 U.S. 452 , 114 S.Ct. 2350 , 129 L.Ed.2d 362 (1994), to ask clarifying questions to an ambiguous response and to confirm that appellant understood his Spanish when appellant was asked to complete the Advice of Rights form.

12011–2011
United States v. Amnon Saadya, United States of America v. Marco Abkasis green
ca9 · 1985
2 sentences

2010Id. at 1421 .

2010Id. at 1421 .

12010–2010
Thompson v. State green
md · 2006
1 sentence

2009“Having held that the Circuit Court erred by failing to give [Blake] an opportunity to respond to the State’s motion to dismiss the petition, we [did] not reach the issue of whether, and if so under what circumstances, a § 8-201 petitioner is entitled to an oral hearing.” Id. at 229 n. 12, 909 A.2d at 1029 n. 12.

12009–2009
Arey v. State green
md · 2007
2 sentences

2009In Arey v. State, 400 Md. 491 , 929 A.2d 501 (2007), we again addressed whether a circuit court should hold a hearing when the State asserts that DNA evidence no longer exists.

2009In Arey v. State, 400 Md. 491 , 929 A.2d 501 (2007), we again addressed whether a circuit court should hold a hearing when the State asserts that DNA evidence no longer exists.

12009–2009
Simon v. Craft green
scotus · 1901
2 sentences

1996Ass’n, 496 F.2d 174, 178 (4th Cir.1974), even if she was not afforded an oral hearing (and we do not so hold), it does not necessarily mean that she was denied due process, Monumental Health Plan, Inc. v. Department of Health & Human Servs., 510 F.Supp. 244, 248 (D.Md.1981). *26 Though the opportunity to be heard is commonly considered a procedural right, its denial vel non must be determined “by the substance of things, and not by mere form.” Simon v. Craft, 182 U.S. 427, 436 , 21 S.Ct. 836, 839 , 45 L.Ed. 1165 (1901).

1996Ass’n, 496 F.2d 174, 178 (4th Cir.1974), even if she was not afforded an oral hearing (and we do not so hold), it does not necessarily mean that she was denied due process, Monumental Health Plan, Inc. v. Department of Health & Human Servs., 510 F.Supp. 244, 248 (D.Md.1981). *26 Though the opportunity to be heard is commonly considered a procedural right, its denial vel non must be determined “by the substance of things, and not by mere form.” Simon v. Craft, 182 U.S. 427, 436 , 21 S.Ct. 836, 839 , 45 L.Ed. 1165 (1901).

11996–1996
Abrams v. Eckenrode green
md · 1920
2 sentences

1962AVhile a contract which is required by the statute of frauds to be in writing may not ordinarily be modified by a subsequent oral agreement, Abrams v. Eckenrode, 136 Md. 244 , 110 Atl. 468 (1920), the law is well settled that an optionor may, by his words or conduct, waive strict compliance by the optionee *500 of the terms of the option as to a condition precedent, and it is immaterial that the option is a part of the instrument which is required to be in writing under the statute of frauds.

1962AVhile a contract which is required by the statute of frauds to be in writing may not ordinarily be modified by a subsequent oral agreement, Abrams v. Eckenrode, 136 Md. 244 , 110 Atl. 468 (1920), the law is well settled that an optionor may, by his words or conduct, waive strict compliance by the optionee *500 of the terms of the option as to a condition precedent, and it is immaterial that the option is a part of the instrument which is required to be in writing under the statute of frauds.

11962–1962
Rosenkovitz v. United Railways & Electric Co. green
md · 1908
2 sentences

1942The use of oral instructions was discouraged in the case of Rosenkovitz v. United Rys. & Electric Co., 1908, 108 Md. 306, 316 , 70 A. 108, 112 , where it was said: “While it is clear that the power exists in the courts of submitting an oral instruction in cases where it applies, or may be considered necessary, yet it is a power that should be cautiously exercised, and will be found in practice a dangerous one, and open to abuse.

1942The use of oral instructions was discouraged in the case of Rosenkovitz v. United Rys. & Electric Co., 1908, 108 Md. 306, 316 , 70 A. 108, 112 , where it was said: “While it is clear that the power exists in the courts of submitting an oral instruction in cases where it applies, or may be considered necessary, yet it is a power that should be cautiously exercised, and will be found in practice a dangerous one, and open to abuse.

11942–1942
Downey v. Forrester green
md · 1872
1 sentence

1908In Downey v. Forrester, 35 Md. 117 , it was held to be competent for the Court by an oral instruction to make an explanation, ex mero motu of written instructions previously granted by the Court.

11908–1908
Hussey v. Ryan green
md · 1886
1 sentence

1908And in Hussey v. Brown, 64 Md. 426 , it is said, so far as defendant’s exception to this last instruction rests upon its being voluntary or an explanation of the prayer to which it relates, it is well settled that the Court may give instructions of its own or explain the effect of those granted at the instance of the parties, provided they are not inconsistent therewith.

11908–1908

Statutes the citing opinions construe

MD § Md. Code Ann., Crim. Proc. § 8-201 (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 308 (1939–2026) OH 217 (1966–2026) NY 105 (1906–2026) CA 91 (1864–2025) AL 57 (1915–2012) IL 55 (1898–2025) GA 48 (1959–2025) FL 34 (1883–2026) WA 32 (1917–2026) TN 21 (1941–2025) MD 17 (1908–2014) MI 16 (1967–2025) MO 16 (1933–2025) VA 14 (1846–2024) KS 14 (1875–2024) IN 13 (1881–2018) MS 12 (1956–2021) OK 12 (1901–1995) PA 11 (1954–2024) CT 11 (1954–2018) KY 10 (1920–2011) NE 10 (1930–2026) ID 10 (1894–1994) NM 10 (1990–2024) WI 10 (1992–2022) DC 10 (1978–2013) LA 9 (1929–2024) WV 9 (1908–2022) MA 9 (1926–2016) VT 8 (1981–2019) OR 8 (1992–2018) HI 8 (1980–2022) MN 7 (1923–2009) IA 7 (1897–2015) NC 6 (1972–2017) NJ 6 (1953–2017) NV 5 (1914–2015) MT 5 (1928–1994) AR 5 (1886–2016) AZ 4 (1949–2012) CO 4 (1974–2009) SD 3 (1990–2022) SC 3 (1993–2011) AK 3 (1986–2006) ND 3 (1917–2014) ME 2 (1967–2017) NH 2 (1974–2007) WY 2 (1987–1993) RI 2 (1991–1994) UT 2 (2011–2020)

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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