close hearing (Maryland) · Go Syfert
← Maryland issues

close hearing in Maryland

15 Maryland opinions name it 2 courts 1981–2025 1 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 (8)

CaseFollowedCited
Rogers v. Radio Shackgreen
md · 1974 · cited in 2 Maryland opinions naming this issue, 1981–1993
2 sentences

1993Schultz v. Pritts, supra, 291 Md. at 7 , 432 A.2d at 1323 (“When an administrative agency relies upon evidence submitted after the close of a hearing, due process may be violated if no opportunity is provided to challenge the evidence by cross-examination or rebuttal”); Rogers v. Radio Shack, supra, 271 Md. at 129 , 314 A.2d at 115 (“with no opportunity for cross-examination or rebuttal, fundamental fairness would preclude reliance upon the [subsequently received] report by an administrative agency”); Temmink v. Bd. of Zoning Appeals, supra, 205 Md. at 497 , 109 A.2d at 89 (holding that where

1993Schultz v. Pritts, supra, 291 Md. at 7 , 432 A.2d at 1323 (“When an administrative agency relies upon evidence submitted after the close of a hearing, due process may be violated if no opportunity is provided to challenge the evidence by cross-examination or rebuttal”); Rogers v. Radio Shack, supra, 271 Md. at 129 , 314 A.2d at 115 (“with no opportunity for cross-examination or rebuttal, fundamental fairness would preclude reliance upon the [subsequently received] report by an administrative agency”); Temmink v. Bd. of Zoning Appeals, supra, 205 Md. at 497 , 109 A.2d at 89 (holding that where

22
Temmink v. Board of Zoning Appealsgreen
md · 2001 · cited in 2 Maryland opinions naming this issue, 1981–1993
2 sentences

1993Schultz v. Pritts, supra, 291 Md. at 7 , 432 A.2d at 1323 (“When an administrative agency relies upon evidence submitted after the close of a hearing, due process may be violated if no opportunity is provided to challenge the evidence by cross-examination or rebuttal”); Rogers v. Radio Shack, supra, 271 Md. at 129 , 314 A.2d at 115 (“with no opportunity for cross-examination or rebuttal, fundamental fairness would preclude reliance upon the [subsequently received] report by an administrative agency”); Temmink v. Bd. of Zoning Appeals, supra, 205 Md. at 497 , 109 A.2d at 89 (holding that where

1993Schultz v. Pritts, supra, 291 Md. at 7 , 432 A.2d at 1323 (“When an administrative agency relies upon evidence submitted after the close of a hearing, due process may be violated if no opportunity is provided to challenge the evidence by cross-examination or rebuttal”); Rogers v. Radio Shack, supra, 271 Md. at 129 , 314 A.2d at 115 (“with no opportunity for cross-examination or rebuttal, fundamental fairness would preclude reliance upon the [subsequently received] report by an administrative agency”); Temmink v. Bd. of Zoning Appeals, supra, 205 Md. at 497 , 109 A.2d at 89 (holding that where

22
Schultz v. Prittsgreen
md · 1981 · cited in 2 Maryland opinions naming this issue, 1993–2017
2 sentences

2017It "determined that there had been a denial of due process because the [b]oard had considered evidence submitted after the close of the hearing." Id.

1993Schultz v. Pritts, supra, 291 Md. at 7 , 432 A.2d at 1323 (“When an administrative agency relies upon evidence submitted after the close of a hearing, due process may be violated if no opportunity is provided to challenge the evidence by cross-examination or rebuttal”); Rogers v. Radio Shack, supra, 271 Md. at 129 , 314 A.2d at 115 (“with no opportunity for cross-examination or rebuttal, fundamental fairness would preclude reliance upon the [subsequently received] report by an administrative agency”); Temmink v. Bd. of Zoning Appeals, supra, 205 Md. at 497 , 109 A.2d at 89 (holding that where

12
United States v. William T. Panza, United States of America v. John Tatesgreen
ca9 · 1980 · cited in 1 Maryland opinions naming this issue, 2011–2011
1 sentence

2011See, e.g., United States v. Rantz, 862 F.2d 808, 812 (10th Cir.1988) (finding a Brooks violation where a defendant was forced to testify at the start of his case in chief, but holding the error harmless); United States v. Luce, 718 F.2d 1236 , 1241 n. 4 (6th Cir.1983) (citing Brooks for the proposition that a defendant “may not constitutionally be forced to decide whether he will testify at any point before the close of his defense”), aff'd, 469 U.S. 38 , 105 S.Ct. 460 , 83 L.Ed.2d 443 (1984); United States v. Panza, 612 F.2d 432, 439 (9th Cir.1980) (finding no violation of the Brooks guarante

11
United States v. Bobby Gene Rantzgreen
ca10 · 1988 · cited in 1 Maryland opinions naming this issue, 2011–2011
1 sentence

2011See, e.g., United States v. Rantz, 862 F.2d 808, 812 (10th Cir.1988) (finding a Brooks violation where a defendant was forced to testify at the start of his case in chief, but holding the error harmless); United States v. Luce, 718 F.2d 1236 , 1241 n. 4 (6th Cir.1983) (citing Brooks for the proposition that a defendant “may not constitutionally be forced to decide whether he will testify at any point before the close of his defense”), aff'd, 469 U.S. 38 , 105 S.Ct. 460 , 83 L.Ed.2d 443 (1984); United States v. Panza, 612 F.2d 432, 439 (9th Cir.1980) (finding no violation of the Brooks guarante

11
State v. Kidogreen
hawapp · 2003 · cited in 1 Maryland opinions naming this issue, 2011–2011
2 sentences

2011See, e.g., United States v. Rantz, 862 F.2d 808, 812 (10th Cir.1988) (finding a Brooks violation where a defendant was forced to testify at the start of his case in chief, but holding the error harmless); United States v. Luce, 718 F.2d 1236 , 1241 n. 4 (6th Cir.1983) (citing Brooks for the proposition that a defendant “may not constitutionally be forced to decide whether he will testify at any point before the close of his defense”), aff'd, 469 U.S. 38 , 105 S.Ct. 460 , 83 L.Ed.2d 443 (1984); United States v. Panza, 612 F.2d 432, 439 (9th Cir.1980) (finding no violation of the Brooks guarante

2011See, e.g., United States v. Rantz, 862 F.2d 808, 812 (10th Cir.1988) (finding a Brooks violation where a defendant was forced to testify at the start of his case in chief, but holding the error harmless); United States v. Luce, 718 F.2d 1236 , 1241 n. 4 (6th Cir.1983) (citing Brooks for the proposition that a defendant “may not constitutionally be forced to decide whether he will testify at any point before the close of his defense”), aff'd, 469 U.S. 38 , 105 S.Ct. 460 , 83 L.Ed.2d 443 (1984); United States v. Panza, 612 F.2d 432, 439 (9th Cir.1980) (finding no violation of the Brooks guarante

11
Dal Maso v. Board of County Commissionersgreen
md · 1965 · cited in 1 Maryland opinions naming this issue, 1993–1993
2 sentences

1993See also Dal Maso v. Bd. of County Comm’rs, 238 Md. 333, 337 , 209 A.2d 62 , 65 (1965).

1993See also Dal Maso v. Bd. of County Comm'rs, 238 Md. 333, 337 , 209 A.2d 62 , 65 (1965).

11
Lyles v. Stategreen
mdctspecapp · 1985 · cited in 1 Maryland opinions naming this issue, 1986–1986
2 sentences

1986See Lyles v. State, 63 Md.App. 376 , 492 A.2d 959 , cert. granted, 304 Md. 362 , 499 A. 2d 191 (1985). 1 B.

1986See Lyles v. State, 63 Md.App. 376 , 492 A.2d 959 , cert. granted, 304 Md. 362 , 499 A. 2d 191 (1985). 1 B.

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 (13)

CaseCitedYears
Anne Arundel County v. Rode neutral
mdctspecapp · 2013
1 sentence

2025Id. at 704-05 .

12025–2025
Maryland State Police v. Zeigler green
md · 1993
2 sentences

2018Maryland State Police v. Zeigler , 330 Md. 540 , 557, 625 A.2d 914 (1993).

2018Maryland State Police v. Zeigler , 330 Md. 540 , 557, 625 A.2d 914 (1993).

12018–2018
Brown v. Baer green
md · 1981
2 sentences

2015While the court did not resolve the underlying merits of the board’s decision — the court did not decide whether the property owner was entitled to the special exception — the court determined that the agency’s decision was inconsistent with law as a result of its review. (5) Brown v. Baer, 291 Md. 377 , 435 A.2d 96 (1981) concerned a county liquor board’s denial of a license application.

2015While the court did not resolve the underlying merits of the board’s decision — the court did not decide whether the property owner was entitled to the special exception — the court determined that the agency’s decision was inconsistent with law as a result of its review. (5) Brown v. Baer, 291 Md. 377 , 435 A.2d 96 (1981) concerned a county liquor board’s denial of a license application.

12015–2015
Powell v. Breslin green
mdctspecapp · 2010
1 sentence

2015Powell v. Breslin, 195 Md.App. *568 340, 345, 6 A.3d 360 (2010), aff'd, 421 Md. 266 , 26 A.3d 878 (2011).

12015–2015
Breslin v. Powell green
md · 2011
2 sentences

2015Powell v. Breslin, 195 Md.App. *568 340, 345, 6 A.3d 360 (2010), aff'd, 421 Md. 266 , 26 A.3d 878 (2011).

2015Powell v. Breslin, 195 Md.App. *568 340, 345, 6 A.3d 360 (2010), aff'd, 421 Md. 266 , 26 A.3d 878 (2011).

12015–2015
Luce v. United States green
scotus · 1984
2 sentences

2011See, e.g., United States v. Rantz, 862 F.2d 808, 812 (10th Cir.1988) (finding a Brooks violation where a defendant was forced to testify at the start of his case in chief, but holding the error harmless); United States v. Luce, 718 F.2d 1236 , 1241 n. 4 (6th Cir.1983) (citing Brooks for the proposition that a defendant “may not constitutionally be forced to decide whether he will testify at any point before the close of his defense”), aff'd, 469 U.S. 38 , 105 S.Ct. 460 , 83 L.Ed.2d 443 (1984); United States v. Panza, 612 F.2d 432, 439 (9th Cir.1980) (finding no violation of the Brooks guarante

2011See, e.g., United States v. Rantz, 862 F.2d 808, 812 (10th Cir.1988) (finding a Brooks violation where a defendant was forced to testify at the start of his case in chief, but holding the error harmless); United States v. Luce, 718 F.2d 1236 , 1241 n. 4 (6th Cir.1983) (citing Brooks for the proposition that a defendant “may not constitutionally be forced to decide whether he will testify at any point before the close of his defense”), aff'd, 469 U.S. 38 , 105 S.Ct. 460 , 83 L.Ed.2d 443 (1984); United States v. Panza, 612 F.2d 432, 439 (9th Cir.1980) (finding no violation of the Brooks guarante

12011–2011
Board of Education v. L. R. Foy Construction Co. green
kan · 1985
2 sentences

2004Co., Inc., 237 Kan. 1 , 697 P.2d 456 (1985), an arbitration panel was required by rule to issue its decision within 30 days of the close of the hearing.

2004Co., Inc., 237 Kan. 1 , 697 P.2d 456 (1985), an arbitration panel was required by rule to issue its decision within 30 days of the close of the hearing.

12004–2004
State v. Ware green
md · 2002
1 sentence

2003At the close of the hearing, the court determined that it was in Caya’s best interest that custody and guardianship remain with Steven and Michelle S. 6 It closed the case “except for the purpose of complying with any mandate of an appellate court....” In response to a question by Christine’s counsel as to how visitation would be effectuated, the court responded, “I think guardianship doesn’t include visitation, unless someone can persuade me otherwise.” Counsel for the Department agreed with the court and added that, in any event, “Steven ... is not going to preclude her from visiting Caya...

12003–2003
In Re Yve S. green
md · 2003
1 sentence

2003At the close of the hearing, the court determined that it was in Caya’s best interest that custody and guardianship remain with Steven and Michelle S. 6 It closed the case “except for the purpose of complying with any mandate of an appellate court....” In response to a question by Christine’s counsel as to how visitation would be effectuated, the court responded, “I think guardianship doesn’t include visitation, unless someone can persuade me otherwise.” Counsel for the Department agreed with the court and added that, in any event, “Steven ... is not going to preclude her from visiting Caya...

12003–2003
Brooke Group Ltd. v. Brown & Williamson Tobacco Corp. green
scotus · 1993
2 sentences

2002Determining whether recoupment of predatory losses is likely requires an estimate of the cost of the alleged predation and a close analysis of both the scheme alleged by the plaintiff and the structure and conditions of the relevant market. 509 U.S. at 225-26 , 113 S.Ct. 2578 (emphasis supplied).

2002Determining whether recoupment of predatory losses is likely requires an estimate of the cost of the alleged predation and a close analysis of both the scheme alleged by the plaintiff and the structure and conditions of the relevant market. 509 U.S. at 225-26 , 113 S.Ct. 2578 (emphasis supplied).

12002–2002
Dillsworth v. State green
mdctspecapp · 1986
2 sentences

1998Judge Alpert held, 66 Md.App. at 267 , 503 A.2d 734 : At the close of the defense’s case below, appellant’s counsel moved for a judgment of acquittal “an the grounds [that] there is insufficient evidence to establish the intent to commit such a crime.” As no argument was made below on this precise issue, it is not preserved for our review.

1998Judge Alpert held, 66 Md.App. at 267 , 503 A.2d 734 : At the close of the defense’s case below, appellant’s counsel moved for a judgment of acquittal “an the grounds [that] there is insufficient evidence to establish the intent to commit such a crime.” As no argument was made below on this precise issue, it is not preserved for our review.

11998–1998
Stevens v. Department of Treasury green
scotus · 1991
2 sentences

1995According to counsel, the effect of Stevens, 500 U.S. at 1 , 111 S.Ct. at 1562 , was that “nothing could be done to salvage [Taylor’s] claim, because no claim in fact existed as of November 4, 1988, as a matter of law, when my client was retained.” Taylor contends that this was a new defense, previously unraised.

1995According to counsel, the effect of Stevens, 500 U.S. at 1 , 111 S.Ct. at 1562 , was that “nothing could be done to salvage [Taylor’s] claim, because no claim in fact existed as of November 4, 1988, as a matter of law, when my client was retained.” Taylor contends that this was a new defense, previously unraised.

11995–1995
Cohen v. American Home Assurance Co. green
md · 1969
2 sentences

1989Cohen v. American Home Assurance Co., 255 Md. 334, 348 , 258 A.2d 225 (1969). 2 .

1989Cohen v. American Home Assurance Co., 255 Md. 334, 348 , 258 A.2d 225 (1969). 2 .

11989–1989

Where else courts name it

IL 76 (1909–2026) NY 68 (1881–2026) CA 53 (1892–2026) TX 50 (1916–2025) PA 48 (1944–2026) OH 32 (1917–2025) LA 31 (1950–2025) FL 26 (1939–2017) IN 24 (1871–2020) CT 17 (1944–2016) NJ 17 (1925–2026) MN 17 (1973–2016) MD 15 (1981–2025) AZ 15 (1936–2018) HI 13 (1959–2025) AL 13 (1907–2025) MO 13 (1913–2017) MS 11 (1919–2009) NM 11 (1967–2024) MT 11 (1934–2024) KS 11 (1932–2025) WI 11 (1906–2023) UT 10 (1990–2026) CO 10 (1938–2025) ID 9 (1976–2023) GA 9 (1976–2024) AR 9 (1978–2024) ME 9 (1969–2012) KY 9 (1919–2025) DC 8 (1969–2025) MA 8 (1933–2017) WV 8 (1981–2018) MI 8 (1973–2021) OR 7 (1916–2019) NE 7 (1923–2020) OK 7 (1967–2006) ND 7 (1965–2012) WA 7 (1948–2023) NC 6 (1981–2016) IA 6 (1934–2017) WY 5 (1986–2005) NH 4 (2015–2024) RI 4 (1992–2018) SD 4 (1978–1998) VA 3 (1930–2026) SC 3 (1973–2017) DE 2 (1986–2016) VT 2 (2014–2022) TN 2 (1993–2008) AK 2 (1990–2011)

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.

← Caselaw search · G Cite Topics · Brief Check