separation of powers doctrine in Maryland

2020Bd. of Elections, 399 Md. 710, 732 (2007); see also Shell Oil Co. v. Supervisor of Assessments of Prince George’s Cty., 276 Md. 36, 47 (1975) (“[A]ny attempt to authorize an administrative agency to perform what is deemed a purely judicial function or power, would violate the separation of powers principle.”) (cleaned up).

2020Bd. of Elections, 399 Md. 710, 732 (2007); see also Shell Oil Co. v. Supervisor of Assessments of Prince George’s Cty., 276 Md. 36, 47 (1975) (“Any attempt to authorize an - 27 - administrative agency to perform what is deemed a purely judicial function or power, would violate the separation of powers principle.”) (cleaned up).

2015Noting that the concept of separation of powers may “ ‘encompass a sensible degree of elasticity,’ ” id. (quoting Dep’t of Natural Res. v. Linchester, 274 Md. 211, 220 , 334 A.2d 514 (1975)), the Court stated: “The constitutional doctrine of separation of powers ... does not itself inhibit the delegation to an administrative agency of a blend of executive or legislative powers with powers judicial in nature; the determining factor is not so much the specific powers granted to the administrative agency, but rather the relationship of the courts to the exercise of that power.” Id. at 677-78, 655

2015Noting that the concept of separation of powers may “ ‘encompass a sensible degree of elasticity,’ ” id. (quoting Dep’t of Natural Res. v. Linchester, 274 Md. 211, 220 , 334 A.2d 514 (1975)), the Court stated: “The constitutional doctrine of separation of powers ... does not itself inhibit the delegation to an administrative agency of a blend of executive or legislative powers with powers judicial in nature; the determining factor is not so much the specific powers granted to the administrative agency, but rather the relationship of the courts to the exercise of that power.” Id. at 677-78, 655

2023See, e.g., Dep’t of Transp. v. Armacost, 311 Md. 64, 77-78 (1987) (“Steeped in the political theories of Montesquieu and Locke, those who framed the constitutions of our states and of the federal government believed that separating the functions of government and assigning the execution of those functions to different branches was fundamental to good government and the preservation of civil liberties.”); Att’y Gen. v. Waldron, 289 Md. 683, 688 (1981) (identifying the purpose of the separation of powers doctrine as “not to avoid friction, but, by means of the 17 inevitable friction incident to

2023See, e.g., Dep’t of Transp. v. Armacost, 311 Md. 64, 77-78 (1987) (“Steeped in the political theories of Montesquieu and Locke, those who framed the constitutions of our states and of the federal government believed that separating the functions of government and assigning the execution of those functions to different branches was fundamental to good government and the preservation of civil liberties.”); Att’y Gen. v. Waldron, 289 Md. 683, 688 (1981) (identifying the purpose of the separation of powers doctrine as “not to avoid friction, but, by means of the 17 inevitable friction incident to

2018Although, as the Court of Appeals has said, "the separation of powers doctrine does not impose, in every circumstance, a complete separation between the three branches of this State's government," it is also true "that the constitutional elasticity [of the doctrine] cannot be stretched to a point where, in effect, there no longer exists a separation of governmental power." Id. at 732 , 926 A.2d 216 (quoting Schisler v. State , 394 Md. 519 , 576, 907 A.2d 175 (2006). "[T]he purpose of the doctrine" is "to preserve[ ] to the one branch of government its essential functions and prohibit[ ] any ot

2018Although, as the Court of Appeals has said, "the separation of powers doctrine does not impose, in every circumstance, a complete separation between the three branches of this State's government," it is also true "that the constitutional elasticity [of the doctrine] cannot be stretched to a point where, in effect, there no longer exists a separation of governmental power." Id. at 732 , 926 A.2d 216 (quoting Schisler v. State , 394 Md. 519 , 576, 907 A.2d 175 (2006). "[T]he purpose of the doctrine" is "to preserve[ ] to the one branch of government its essential functions and prohibit[ ] any ot

2014See Baltimore v. State, 15 Md. 376, 457 (1860) (stating that “[t]he words of [Article 8] appear to be plain enough, but they *195 have not been accepted in their literal sense”); see also McCulloch v. Glendening, 347 Md. 272, 283 , 701 A.2d 99 (1997) (stating that “the doctrine has never been rigidly applied”); Dep’t of Natural Res. v. Linchester Sand & Gravel Co., 274 Md. 211, 220 , 334 A.2d 514 (1975) (stating that the separation of powers doctrine encompasses “a sensible degree of elasticity”); Dan Friedman, The Maryland State Constitution, supra, 34 (stating that “Maryland courts have neve

2000With the exception of these two cases, the similar cases to which they refer, and the two aberrational cases arising out of the strife of Maryland’s peculiar position during the Civil War, McCormick v. Deaver, 22 Md. 187 (1864) and Mayor of Baltimore v. Howard, 15 Md. 376 (1860), this Court has long been a paramount guardian of the separation of powers doctrine.

2022See 2012 Districting, 436 Md. at 159 (noting that choices made in the district boundaries are “political one[s], well within the authority of the political branches to make”); see also Murphy v. Liberty Mutual Company, 478 Md. 333, 372-82 (2022) (explaining the constraints that the Separation of Powers clause in Maryland’s Declaration of Rights places on the exercise by one branch of government of core powers belonging to another); Getty v. Carroll County Board of Elections, 399 Md. 710, 741 (2007) (“[T]he power of judicial review does not equate to the power to exercise functions that are exp

2022See 2012 Districting, 436 Md. at 159 (noting that choices made in the district boundaries are “political one[s], well within the authority of the political branches to make”); see also Murphy v. Liberty Mutual Company, 478 Md. 333, 372-82 (2022) (explaining the constraints that the Separation of Powers clause in Maryland’s Declaration of Rights places on the exercise by one branch of government of core powers belonging to another); Getty v. Carroll County Board of Elections, 399 Md. 710, 741 (2007) (“[T]he power of judicial review does not equate to the power to exercise functions that are exp

2023See, e.g., Dep’t of Transp. v. Armacost, 311 Md. 64, 77-78 (1987) (“Steeped in the political theories of Montesquieu and Locke, those who framed the constitutions of our states and of the federal government believed that separating the functions of government and assigning the execution of those functions to different branches was fundamental to good government and the preservation of civil liberties.”); Att’y Gen. v. Waldron, 289 Md. 683, 688 (1981) (identifying the purpose of the separation of powers doctrine as “not to avoid friction, but, by means of the 17 inevitable friction incident to

2023See, e.g., Dep’t of Transp. v. Armacost, 311 Md. 64, 77-78 (1987) (“Steeped in the political theories of Montesquieu and Locke, those who framed the constitutions of our states and of the federal government believed that separating the functions of government and assigning the execution of those functions to different branches was fundamental to good government and the preservation of civil liberties.”); Att’y Gen. v. Waldron, 289 Md. 683, 688 (1981) (identifying the purpose of the separation of powers doctrine as “not to avoid friction, but, by means of the 17 inevitable friction incident to

2026As it has roots in the constitutional doctrine of separation of powers, a similar privilege extends to the judicial and legislative branches as well.” Hamilton, 287 Md. at 553 n.3. 33 GP § 4-344 provides that “[a] custodian may deny inspection of any part of an interagency or intra-agency letter or memorandum that would not be available by law to a private party in litigation with the unit.” To invoke this conditional exemption, a custodian must “believe” that the requested inspection “would be contrary to the public interest.” GP § 4-343; Admin.

2022See Hamilton v. Verdow, 287 Md. 544, 554, 556 (1980) (regarding executive privilege, noting that “[a]s it has roots in the constitutional doctrine of separation of powers, a similar privilege extends to the judicial and legislative branches as well.”).

2023See, e.g., Dep’t of Transp. v. Armacost, 311 Md. 64, 77-78 (1987) (“Steeped in the political theories of Montesquieu and Locke, those who framed the constitutions of our states and of the federal government believed that separating the functions of government and assigning the execution of those functions to different branches was fundamental to good government and the preservation of civil liberties.”); Att’y Gen. v. Waldron, 289 Md. 683, 688 (1981) (identifying the purpose of the separation of powers doctrine as “not to avoid friction, but, by means of the 17 inevitable friction incident to

2023See, e.g., Dep’t of Transp. v. Armacost, 311 Md. 64, 77-78 (1987) (“Steeped in the political theories of Montesquieu and Locke, those who framed the constitutions of our states and of the federal government believed that separating the functions of government and assigning the execution of those functions to different branches was fundamental to good government and the preservation of civil liberties.”); Att’y Gen. v. Waldron, 289 Md. 683, 688 (1981) (identifying the purpose of the separation of powers doctrine as “not to avoid friction, but, by means of the 17 inevitable friction incident to

2023See, e.g., Dep’t of Transp. v. Armacost, 311 Md. 64, 77-78 (1987) (“Steeped in the political theories of Montesquieu and Locke, those who framed the constitutions of our states and of the federal government believed that separating the functions of government and assigning the execution of those functions to different branches was fundamental to good government and the preservation of civil liberties.”); Att’y Gen. v. Waldron, 289 Md. 683, 688 (1981) (identifying the purpose of the separation of powers doctrine as “not to avoid friction, but, by means of the 17 inevitable friction incident to

2023See, e.g., Dep’t of Transp. v. Armacost, 311 Md. 64, 77-78 (1987) (“Steeped in the political theories of Montesquieu and Locke, those who framed the constitutions of our states and of the federal government believed that separating the functions of government and assigning the execution of those functions to different branches was fundamental to good government and the preservation of civil liberties.”); Att’y Gen. v. Waldron, 289 Md. 683, 688 (1981) (identifying the purpose of the separation of powers doctrine as “not to avoid friction, but, by means of the 17 inevitable friction incident to

2000But see McCulloch v. Glendening, 347 Md. 272, 282-84 , 701 A.2d 99, 104 (1997) (noting that Article 8 does not mandate an absolute separation of powers among the branches of government); Judy v. Schaefer, 331 Md. 239, 261 , 627 A.2d 1039, 1050 (1993) (stating that “Article] 8 does not impose a complete separation between the branches of government,” and delegation of legislative power to the executive branch is constitutionally permissible “where sufficient safeguards are legislatively provided for the guidance ... in ... administration of the statute.’ ” (quoting Department of Transp. v. Arma

2000But see McCulloch v. Glendening, 347 Md. 272, 282-84 , 701 A.2d 99, 104 (1997) (noting that Article 8 does not mandate an absolute separation of powers among the branches of government); Judy v. Schaefer, 331 Md. 239, 261 , 627 A.2d 1039, 1050 (1993) (stating that “Article] 8 does not impose a complete separation between the branches of government,” and delegation of legislative power to the executive branch is constitutionally permissible “where sufficient safeguards are legislatively provided for the guidance ... in ... administration of the statute.’ ” (quoting Department of Transp. v. Arma

2019United States v. Johnson , 383 U.S. 169 , 178, 86 S. Ct. 749 , 754 [ 15 L.Ed.2d 681 ] (1966) ; also Blondes v. State , 16 Md.

2019United States v. Johnson , 383 U.S. 169 , 178, 86 S. Ct. 749 , 754 [ 15 L.Ed.2d 681 ] (1966) ; also Blondes v. State , 16 Md.

2014See Shell Oil Co. v. Supervisor of Assessments of Prince George’s Cnty., 276 Md. 36, 46 , 343 A.2d 521 (1975) (stating that courts cannot perform “nonjudicial functions” and that administrative agencies cannot perform “judicial functions”); accord O’Hara v. Kovens, 92 Md.App. 9, 22-23 , 606 A.2d 286 , cert. denied, 328 Md. 93 , 612 A.2d 1316 (1992) (stating that “the separation of powers doctrine preserves to the one branch of government its essential functions and prohibits any other branch from interfering with or usurping those functions”) (emphasis in original).

2014See Shell Oil Co. v. Supervisor of Assessments of Prince George’s Cnty., 276 Md. 36, 46 , 343 A.2d 521 (1975) (stating that courts cannot perform “nonjudicial functions” and that administrative agencies cannot perform “judicial functions”); accord O’Hara v. Kovens, 92 Md.App. 9, 22-23 , 606 A.2d 286 , cert. denied, 328 Md. 93 , 612 A.2d 1316 (1992) (stating that “the separation of powers doctrine preserves to the one branch of government its essential functions and prohibits any other branch from interfering with or usurping those functions”) (emphasis in original).

2015Noting that the concept of separation of powers may “‘encompass a sensible degree of elasticity,’” id. (quoting Dep’t of Natural Res. v. Linchester, 274 Md. 211, 220 (1975)), the Court stated: “The constitutional doctrine of separation of powers . . . does not itself inhibit the delegation to an administrative agency of a blend of executive or legislative powers with powers judicial in nature; the determining factor is not so much the specific powers granted to the administrative agency, but rather the relationship of the courts to the exercise of that power.” Id. at 677-78 (quoting Investors

2015Noting that the concept of separation of powers may “ ‘encompass a sensible degree of elasticity,’ ” id. (quoting Dep’t of Natural Res. v. Linchester, 274 Md. 211, 220 , 334 A.2d 514 (1975)), the Court stated: “The constitutional doctrine of separation of powers ... does not itself inhibit the delegation to an administrative agency of a blend of executive or legislative powers with powers judicial in nature; the determining factor is not so much the specific powers granted to the administrative agency, but rather the relationship of the courts to the exercise of that power.” Id. at 677-78, 655

2008Appellant relies on In re Demetrius J., 321 Md. 468 , 583 A.2d 258 (1991), to support her position that the CCTO violated the doctrine of separation of powers.

2008Appellant relies on In re Demetrius J., 321 Md. 468 , 583 A.2d 258 (1991), to support her position that the CCTO violated the doctrine of separation of powers.

2018Although, as the Court of Appeals has said, "the separation of powers doctrine does not impose, in every circumstance, a complete separation between the three branches of this State's government," it is also true "that the constitutional elasticity [of the doctrine] cannot be stretched to a point where, in effect, there no longer exists a separation of governmental power." Id. at 732 , 926 A.2d 216 (quoting Schisler v. State , 394 Md. 519 , 576, 907 A.2d 175 (2006). "[T]he purpose of the doctrine" is "to preserve[ ] to the one branch of government its essential functions and prohibit[ ] any ot

2018Although, as the Court of Appeals has said, "the separation of powers doctrine does not impose, in every circumstance, a complete separation between the three branches of this State's government," it is also true "that the constitutional elasticity [of the doctrine] cannot be stretched to a point where, in effect, there no longer exists a separation of governmental power." Id. at 732 , 926 A.2d 216 (quoting Schisler v. State , 394 Md. 519 , 576, 907 A.2d 175 (2006). "[T]he purpose of the doctrine" is "to preserve[ ] to the one branch of government its essential functions and prohibit[ ] any ot

2007When they transcend defined limits, their acts are unauthorized, and being without warrant, are necessarily to be viewed as nullities.” Crane v. Meginnis, 1 G. & J. 463, 472 (1829) (emphasis added); see also, e.g., Schisler v. State, 394 Md. 519, 549-79 , 907 A.2d 175, 193-211 (2006) (providing a detailed history and evolution of the separation of powers doctrine), and cases cited therein; Wright v. Wright’s Lessee, 2 Md. 429 (1852) (elucidating the purpose of the separation of powers doctrine).

1997II. (a) Appellants argue, quoting Crane v. Meginnis, 1 G. & J. 463, 477 (1829), that the separation of powers doctrine creates a sharp demarcation in the lines of authority of government, and it “confine[s] in practice the action of each department to its own appropriate sphere, by forbidding to it the use of powers allotted to the co-ordinate departments.” Hence, they insist that, by issuing the Executive Order “absent express legislative authority” and in spite of numerous legislative defeats of similar initiatives, the Governor effectively usurped the law-making power of the Legislature.

2000See Prince George’s County Comm’rs v. Mitchell, 97 Md. 330, 340 , 55 A. 673, 675 (1903) (voiding as unconstitutional, pursuant to Article 8, a statute that placed control of a local courthouse, in which the entire county government was housed, in the hands of a court-appointed judicial officer); Board of Supervisors v. Todd, 97 Md. 247, 263-65 , 54 A. 963, 966 (1903) (voiding a statute under the separation of powers doctrine that mandated the circuit court to order elections upon petition); Robey v. Prince George’s County Comm’rs, 92 Md. 150, 160-62 , 48 A. 48, 50-51 (1900) (striking down a st

2000See Prince George’s County Comm’rs v. Mitchell, 97 Md. 330, 340 , 55 A. 673, 675 (1903) (voiding as unconstitutional, pursuant to Article 8, a statute that placed control of a local courthouse, in which the entire county government was housed, in the hands of a court-appointed judicial officer); Board of Supervisors v. Todd, 97 Md. 247, 263-65 , 54 A. 963, 966 (1903) (voiding a statute under the separation of powers doctrine that mandated the circuit court to order elections upon petition); Robey v. Prince George’s County Comm’rs, 92 Md. 150, 160-62 , 48 A. 48, 50-51 (1900) (striking down a st

2024See, e.g., State v. Butler, 72 Md. 98 (1890) (rejecting argument that a court could not strike a judgment after a convicted defendant had been sentenced and committed to custody); Czaplinski, 196 Md. at 660-61 (noting that Maryland and other jurisdictions have allowed sentences to be decreased “even though execution has been entered into”); State v. Schlick, 465 Md. 566 , 578 n.4 (2019) (“Schlick II”) (reiterating that, in Maryland, “modifying a sentence is a judicial act that does not violate the separation of powers doctrine nor usurp the Governor’s power to pardon”).

2024See, e.g., State v. Butler, 72 Md. 98 (1890) (rejecting argument that a court could not strike a judgment after a convicted defendant had been sentenced and committed to custody); Czaplinski, 196 Md. at 660-61 (noting that Maryland and other jurisdictions have allowed sentences to be decreased “even though execution has been entered into”); State v. Schlick, 465 Md. 566 , 578 n.4 (2019) (“Schlick II”) (reiterating that, in Maryland, “modifying a sentence is a judicial act that does not violate the separation of powers doctrine nor usurp the Governor’s power to pardon”).

2024See, e.g., State v. Butler, 72 Md. 98 (1890) (rejecting argument that a court could not strike a judgment after a convicted defendant had been sentenced and committed to custody); Czaplinski, 196 Md. at 660-61 (noting that Maryland and other jurisdictions have allowed sentences to be decreased “even though execution has been entered into”); State v. Schlick, 465 Md. 566 , 578 n.4 (2019) (“Schlick II”) (reiterating that, in Maryland, “modifying a sentence is a judicial act that does not violate the separation of powers doctrine nor usurp the Governor’s power to pardon”).

2024See, e.g., State v. Butler, 72 Md. 98 (1890) (rejecting argument that a court could not strike a judgment after a convicted defendant had been sentenced and committed to custody); Czaplinski, 196 Md. at 660-61 (noting that Maryland and other jurisdictions have allowed sentences to be decreased “even though execution has been entered into”); State v. Schlick, 465 Md. 566 , 578 n.4 (2019) (“Schlick II”) (reiterating that, in Maryland, “modifying a sentence is a judicial act that does not violate the separation of powers doctrine nor usurp the Governor’s power to pardon”).

2024See, e.g., State v. Butler, 72 Md. 98 (1890) (rejecting argument that a court could not strike a judgment after a convicted defendant had been sentenced and committed to custody); Czaplinski, 196 Md. at 660-61 (noting that Maryland and other jurisdictions have allowed sentences to be decreased “even though execution has been entered into”); State v. Schlick, 465 Md. 566 , 578 n.4 (2019) (“Schlick II”) (reiterating that, in Maryland, “modifying a sentence is a judicial act that does not violate the separation of powers doctrine nor usurp the Governor’s power to pardon”).

2024See, e.g., State v. Butler, 72 Md. 98 (1890) (rejecting argument that a court could not strike a judgment after a convicted defendant had been sentenced and committed to custody); Czaplinski, 196 Md. at 660-61 (noting that Maryland and other jurisdictions have allowed sentences to be decreased “even though execution has been entered into”); State v. Schlick, 465 Md. 566 , 578 n.4 (2019) (“Schlick II”) (reiterating that, in Maryland, “modifying a sentence is a judicial act that does not violate the separation of powers doctrine nor usurp the Governor’s power to pardon”).

2022The court noted that legislative privilege has “long been regarded as an important protection of the independence and integrity of the legislature and, in this country, as also reinforcing the core doctrine of separation of powers.” Schooley, 97 Md.

2022The court noted that legislative privilege has “long been regarded as an important protection of the independence and integrity of the legislature and, in this country, as also reinforcing the core doctrine of separation of powers.” Schooley, 97 Md.

2022See 2012 Districting, 436 Md. at 159 (noting that choices made in the district boundaries are “political one[s], well within the authority of the political branches to make”); see also Murphy v. Liberty Mutual Company, 478 Md. 333, 372-82 (2022) (explaining the constraints that the Separation of Powers clause in Maryland’s Declaration of Rights places on the exercise by one branch of government of core powers belonging to another); Getty v. Carroll County Board of Elections, 399 Md. 710, 741 (2007) (“[T]he power of judicial review does not equate to the power to exercise functions that are exp

2022See 2012 Districting, 436 Md. at 159 (noting that choices made in the district boundaries are “political one[s], well within the authority of the political branches to make”); see also Murphy v. Liberty Mutual Company, 478 Md. 333, 372-82 (2022) (explaining the constraints that the Separation of Powers clause in Maryland’s Declaration of Rights places on the exercise by one branch of government of core powers belonging to another); Getty v. Carroll County Board of Elections, 399 Md. 710, 741 (2007) (“[T]he power of judicial review does not equate to the power to exercise functions that are exp

2022See 2012 Districting, 436 Md. at 159 (noting that choices made in the district boundaries are “political one[s], well within the authority of the political branches to make”); see also Murphy v. Liberty Mutual Company, 478 Md. 333, 372-82 (2022) (explaining the constraints that the Separation of Powers clause in Maryland’s Declaration of Rights places on the exercise by one branch of government of core powers belonging to another); Getty v. Carroll County Board of Elections, 399 Md. 710, 741 (2007) (“[T]he power of judicial review does not equate to the power to exercise functions that are exp

2022See 2012 Districting, 436 Md. at 159 (noting that choices made in the district boundaries are “political one[s], well within the authority of the political branches to make”); see also Murphy v. Liberty Mutual Company, 478 Md. 333, 372-82 (2022) (explaining the constraints that the Separation of Powers clause in Maryland’s Declaration of Rights places on the exercise by one branch of government of core powers belonging to another); Getty v. Carroll County Board of Elections, 399 Md. 710, 741 (2007) (“[T]he power of judicial review does not equate to the power to exercise functions that are exp

2013See, e.g., Edmonds v. Murphy, 83 Md.App. 133, 150 , 573 A.2d 853 (1990), aff'd sub nom., 325 Md. 342 , 601 A.2d 102 (1992) ("[W]e hold that [the Cap] does not violate the separation of powers doctrine embodied in Article 8.”); Univ. of Md.

2013See, e.g., Edmonds v. Murphy, 83 Md.App. 133, 150 , 573 A.2d 853 (1990), aff'd sub nom., 325 Md. 342 , 601 A.2d 102 (1992) ("[W]e hold that [the Cap] does not violate the separation of powers doctrine embodied in Article 8.”); Univ. of Md.

2015Noting that the concept of separation of powers may “ ‘encompass a sensible degree of elasticity,’ ” id. (quoting Dep’t of Natural Res. v. Linchester, 274 Md. 211, 220 , 334 A.2d 514 (1975)), the Court stated: “The constitutional doctrine of separation of powers ... does not itself inhibit the delegation to an administrative agency of a blend of executive or legislative powers with powers judicial in nature; the determining factor is not so much the specific powers granted to the administrative agency, but rather the relationship of the courts to the exercise of that power.” Id. at 677-78, 655

2015Noting that the concept of separation of powers may “ ‘encompass a sensible degree of elasticity,’ ” id. (quoting Dep’t of Natural Res. v. Linchester, 274 Md. 211, 220 , 334 A.2d 514 (1975)), the Court stated: “The constitutional doctrine of separation of powers ... does not itself inhibit the delegation to an administrative agency of a blend of executive or legislative powers with powers judicial in nature; the determining factor is not so much the specific powers granted to the administrative agency, but rather the relationship of the courts to the exercise of that power.” Id. at 677-78, 655

2013See, e.g., Edmonds v. Murphy, 83 Md.App. 133, 150 , 573 A.2d 853 (1990), aff'd sub nom., 325 Md. 342 , 601 A.2d 102 (1992) ("[W]e hold that [the Cap] does not violate the separation of powers doctrine embodied in Article 8.”); Univ. of Md.

2013See, e.g., Edmonds v. Murphy, 83 Md.App. 133, 150 , 573 A.2d 853 (1990), aff'd sub nom., 325 Md. 342 , 601 A.2d 102 (1992) ("[W]e hold that [the Cap] does not violate the separation of powers doctrine embodied in Article 8.”); Univ. of Md.

2018Ass'n , 134 Md. 629 , 108 A. 209 , 211 (1919). 16 The separation of powers doctrine, embodied in Article 8 of the Maryland Declaration of Rights, "explicitly prohibit[s] one branch of government from assuming or usurping the power of any other branch." Getty v. Carroll Cty.

2018Ass'n , 134 Md. 629 , 108 A. 209 , 211 (1919). 16 The separation of powers doctrine, embodied in Article 8 of the Maryland Declaration of Rights, "explicitly prohibit[s] one branch of government from assuming or usurping the power of any other branch." Getty v. Carroll Cty.