forum non conveniens doctrine (Maryland) · Go Syfert
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forum non conveniens doctrine in Maryland

10 Maryland opinions name it 2 courts 1995–2025 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 (4)

CaseFollowedCited
Piper Aircraft Co. v. Reynogreen
scotus · 1982 · cited in 3 Maryland opinions naming this issue, 2017–2025
2 sentences

2025Tolling under those circumstances poses no conflict with the policies underlying the forum non conveniens doctrine, because any forum non conveniens dismissal presupposes that the plaintiff may reinstate the claims in an “alternative forum.” See, e.g., Piper Aircraft Co. v. Reyno, 454 U.S. 235 , 254 n.22 (1981).

2017The Majority cites Piper Aircraft Co. v. Reyno, 454 U.S. 235, 255-56 , 102 S.Ct. 252 , 70 L.Ed.2d 419 (1981), for the proposition that, in a forum non conveniens analysis, a foreign plaintiffs choice of venue deserves less deference than a plaintiff suing in his or her home court.

23
Norwood v. Kirkpatrickgreen
scotus · 1955 · cited in 2 Maryland opinions naming this issue, 2017–2017
2 sentences

2017Norwood v. Kirkpatrick, 349 U.S. 29, 32 , 75 S.Ct. 544, 546 , 99 L.Ed. 789, 793 (1955) (“Congress, in writing § 1404(a), which was an entirely new section, was revising as well as codifying.

2017Norwood v. Kirkpatrick, 349 U.S. 29, 32 , 75 S.Ct. 544, 546 , 99 L.Ed. 789, 793 (1955) (“Congress, in writing § 1404(a), which was an entirely new section, was revising as well as codifying.

22
Johnson v. G.D. Searle & Co.green
md · 1989 · cited in 3 Maryland opinions naming this issue, 1995–2023
2 sentences

2023The Court reasoned that “[i]n order to apply a forum non conveniens analysis there must be an alternative forum which is available for the litigation.” Id.

2003As this Court held in Johnson v. Searle, supra, 314 Md. at 523 , 552 A.2d at 30 , “a circuit court abuses its discretion by unconditionally dismissing actions on the ground of forum non conveniens when the statute of limitations has likely run in the alternative forum.” This was clearly not an appropriate case for applying the doctrine of forum non conveniens.

13
Spring Hope Rockwool, Inc. v. Industrial Clean Air, Inc.green
nced · 1981 · cited in 1 Maryland opinions naming this issue, 2012–2012
1 sentence

2012See Spring Hope Rockwool, Inc. v. Industrial Clean Air, Inc., supra, 504 F.Supp. at 1389-90 .

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 (6)

CaseCitedYears
Odenton Development Company v. Lamy green
md · 1990
2 sentences

2017Rather, the plaintiff’s right to choose a forum is the reason why a trial court should transfer only when “the balance weighs strongly in favor of the moving party.” Urquhart, 339 Md. at 18 n.7 (quoting Odenton, 320 Md. at 40 ).

2017Rather, the plaintiffs right to choose a forum is the reason why a trial court should transfer only when “the balance weighs strongly in favor of the moving party.” Urquhart, 339 Md. at 18 n.7, 660 A.2d 412 (quoting Odenton, 320 Md. at 40 , 576 A.2d 1235 ).

31995–2017
Urquhart v. Simmons green
md · 1995
2 sentences

2017Rather, the plaintiffs right to choose a forum is the reason why a trial court should transfer only when “the balance weighs strongly in favor of the moving party.” Urquhart, 339 Md. at 18 n.7, 660 A.2d 412 (quoting Odenton, 320 Md. at 40 , 576 A.2d 1235 ).

2017Rather, the plaintiffs right to choose a forum is the reason why a trial court should transfer only when “the balance weighs strongly in favor of the moving party.” Urquhart, 339 Md. at 18 n.7, 660 A.2d 412 (quoting Odenton, 320 Md. at 40 , 576 A.2d 1235 ).

22017–2017
Payton-Henderson v. Evans green
mdctspecapp · 2008
1 sentence

2013Id. at 281, 949 A.2d 654 .

12013–2013
Murray v. Transcare Maryland, Inc. green
mdctspecapp · 2012
2 sentences

2013The Court of Special Appeals also affirmed the decision to transfer the case from Baltimore City to Talbot County. 203 Md.App. at 187-97 , 37 A.3d 987 .

2013The Court of Special Appeals also affirmed the decision to transfer the case from Baltimore City to Talbot County. 203 Md.App. at 187-97 , 37 A.3d 987 .

12013–2013
Cobrand v. Adventist Healthcare, Inc. green
mdctspecapp · 2003
2 sentences

2008As Judge Sharer explained in Cobrand v. Adventist Healthcare, Inc., 149 Md.App. 431, 438 , 816 A.2d 117 (2003): Even though venue may be proper in one jurisdiction, a court has the discretion to transfer actions to another competent jurisdiction pursuant to the forum non conveniens doctrine.

2008As Judge Sharer explained in Cobrand v. Adventist Healthcare, Inc., 149 Md.App. 431, 438 , 816 A.2d 117 (2003): Even though venue may be proper in one jurisdiction, a court has the discretion to transfer actions to another competent jurisdiction pursuant to the forum non conveniens doctrine.

12008–2008
Stewart Organization, Inc. v. Ricoh Corp. green
scotus · 1988
2 sentences

1995In Odenton Development v. Lamy, 320 Md. 33 , 575 A.2d 1235 (1990), Judge Chasanow, writing for the Court, explained that the pertinent factors include “ ‘the convenience of the witnesses and those public-interest factors of systemic integrity and fairness that, in addition to private concerns, come under the heading of “the interests of justice.” ’ ” Id. at 40 , 575 A.2d at 1238 (quoting Stewart Organization, Inc. v. Ricoh Corp., 487 U.S. 22, 30 , 108 S.Ct. 2239, 2244 , 101 L.Ed.2d 22 (1988)).

1995In Odenton Development v. Lamy, 320 Md. 33 , 575 A.2d 1235 (1990), Judge Chasanow, writing for the Court, explained that the pertinent factors include “ ‘the convenience of the witnesses and those public-interest factors of systemic integrity and fairness that, in addition to private concerns, come under the heading of “the interests of justice.” ’ ” Id. at 40 , 575 A.2d at 1238 (quoting Stewart Organization, Inc. v. Ricoh Corp., 487 U.S. 22, 30 , 108 S.Ct. 2239, 2244 , 101 L.Ed.2d 22 (1988)).

11995–1995

Statutes the citing opinions construe

USC § 28u.s.c.1404 (5)

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

IL 259 (1948–2026) PA 113 (1959–2026) TX 110 (1960–2025) CA 109 (1953–2026) NY 105 (1943–2025) FL 88 (1954–2024) AL 74 (1990–2025) DE 68 (1961–2026) NJ 48 (1954–2024) OH 46 (1936–2025) CT 44 (1985–2020) MI 31 (1973–2020) DC 31 (1957–2015) WA 28 (1959–2026) MO 25 (1958–2023) WV 24 (1963–2026) MA 20 (1936–2024) MT 18 (1961–2017) GA 18 (1956–2025) LA 17 (1971–2010) MN 16 (1954–2019) MS 14 (1968–2020) TN 12 (1989–2025) MD 10 (1995–2025) ME 10 (1989–2020) NM 10 (1979–1998) KY 9 (1981–2023) OR 9 (1968–2025) IN 9 (1985–2019) CO 9 (1972–2019) OK 8 (1974–2014) RI 8 (2001–2016) UT 7 (1950–2023) SD 6 (1990–2015) VA 6 (1991–2013) AR 6 (1957–2010) NV 6 (2013–2022) AK 6 (1985–2024) NC 5 (2014–2020) WY 4 (1999–2024) KS 4 (1962–1990) IA 3 (1995–2018) NH 3 (1988–2007) AZ 3 (1978–2024) ND 2 (2009–2009) VI 2 (2023–2023) HI 2 (1948–1998) NE 2 (2007–2021)

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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