certainty error (Maryland) · Go Syfert
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certainty error in Maryland

9 Maryland opinions name it 2 courts 1947–2016 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 (2)

CaseFollowedCited
Canady v. McLeodgreen
ncctapp · 1994 · cited in 1 Maryland opinions naming this issue, 2016–2016
2 sentences

2016Va. v. Hutzler, 191 W.Va. 559 , 447 S.E.2d 22, 24-25 (1994) (recognizing merely that the relevant statute was inapplicable to the appellants — owners of property where alcohol was served — because the statute only applied to sellers of alcohol); Canady v. McLeod, 116 N.C.App. 82 , 446 S.E.2d 879, 881-82 (1994) (affirming summary judgment against the plaintiff because the plaintiff lacked evidence to satisfy the substantial certainty test to prevail under North Carolina’s Workers’ Compensation Act).

2016Va. v. Hutzler, 191 W.Va. 559 , 447 S.E.2d 22, 24-25 (1994) (recognizing merely that the relevant statute was inapplicable to the appellants — owners of property where alcohol was served — because the statute only applied to sellers of alcohol); Canady v. McLeod, 116 N.C.App. 82 , 446 S.E.2d 879, 881-82 (1994) (affirming summary judgment against the plaintiff because the plaintiff lacked evidence to satisfy the substantial certainty test to prevail under North Carolina’s Workers’ Compensation Act).

11
Farmers & Mechanics Mutual Fire Insurance v. Hutzlergreen
wva · 1994 · cited in 1 Maryland opinions naming this issue, 2016–2016
2 sentences

2016Va. v. Hutzler, 191 W.Va. 559 , 447 S.E.2d 22, 24-25 (1994) (recognizing merely that the relevant statute was inapplicable to the appellants — owners of property where alcohol was served — because the statute only applied to sellers of alcohol); Canady v. McLeod, 116 N.C.App. 82 , 446 S.E.2d 879, 881-82 (1994) (affirming summary judgment against the plaintiff because the plaintiff lacked evidence to satisfy the substantial certainty test to prevail under North Carolina’s Workers’ Compensation Act).

2016Va. v. Hutzler, 191 W.Va. 559 , 447 S.E.2d 22, 24-25 (1994) (recognizing merely that the relevant statute was inapplicable to the appellants — owners of property where alcohol was served — because the statute only applied to sellers of alcohol); Canady v. McLeod, 116 N.C.App. 82 , 446 S.E.2d 879, 881-82 (1994) (affirming summary judgment against the plaintiff because the plaintiff lacked evidence to satisfy the substantial certainty test to prevail under North Carolina’s Workers’ Compensation Act).

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
Brockmeyer v. Norris green
md · 1940
2 sentences

1973Second Nat’l Bank v. Wrightson, 63 Md. 81 [1885]; Bouldin [Boulden] v. Wood, 96 Md. 336 [332] ( 53 A. 911 ) [1903], And the evidence required for this purpose must be of the strongest character and the proof must be convincing.” ’ The Court, in Brockmeyer v. Norris, 177 Md. 466, 473 , 10 A. 2d 326 [1940], quoted, with approval, this passage from Pomeroy: ‘ “Courts of equity do not grant the high remedy of reformation upon a probability, nor even upon a mere preponderance of evidence, but only upon a certainty of the error.”’ See also Hubble v. Somerville, 187 Md. 418, 422 , 50 A. 2d 565 [1947]

1973Second Nat’l Bank v. Wrightson, 63 Md. 81 [1885]; Bouldin [Boulden] v. Wood, 96 Md. 336 [332] ( 53 A. 911 ) [1903], And the evidence required for this purpose must be of the strongest character and the proof must be convincing.” ’ The Court, in Brockmeyer v. Norris, 177 Md. 466, 473 , 10 A. 2d 326 [1940], quoted, with approval, this passage from Pomeroy: ‘ “Courts of equity do not grant the high remedy of reformation upon a probability, nor even upon a mere preponderance of evidence, but only upon a certainty of the error.”’ See also Hubble v. Somerville, 187 Md. 418, 422 , 50 A. 2d 565 [1947]

41947–1973
M & R Contractors & Builders, Inc. v. Michael green
md · 1958
2 sentences

1987In M & R Contractors & Builders, Inc. v. Michael, 215 Md. 340 , 138 A.2d 350 (1958), we noted that *41 the certainty rule has been modified into one of “reasonable certainty.” Modifications enumerated there were: (a) [I]f the fact of damage is proven with certainty, the extent or the amount thereof may be left to reasonable inference; (b) where a defendant’s wrong has caused the difficulty of proving damage, he cannot complain of the resulting uncertainty; (c) mere difficulty in ascertaining the amount of damage is not fatal; (d) mathematical precision in fixing the exact amount is not require

1987In M & R Contractors & Builders, Inc. v. Michael, 215 Md. 340 , 138 A.2d 350 (1958), we noted that *41 the certainty rule has been modified into one of “reasonable certainty.” Modifications enumerated there were: (a) [I]f the fact of damage is proven with certainty, the extent or the amount thereof may be left to reasonable inference; (b) where a defendant’s wrong has caused the difficulty of proving damage, he cannot complain of the resulting uncertainty; (c) mere difficulty in ascertaining the amount of damage is not fatal; (d) mathematical precision in fixing the exact amount is not require

31971–1987
Hubble v. Somerville green
md · 1947
2 sentences

1973Second Nat’l Bank v. Wrightson, 63 Md. 81 [1885]; Bouldin [Boulden] v. Wood, 96 Md. 336 [332] ( 53 A. 911 ) [1903], And the evidence required for this purpose must be of the strongest character and the proof must be convincing.” ’ The Court, in Brockmeyer v. Norris, 177 Md. 466, 473 , 10 A. 2d 326 [1940], quoted, with approval, this passage from Pomeroy: ‘ “Courts of equity do not grant the high remedy of reformation upon a probability, nor even upon a mere preponderance of evidence, but only upon a certainty of the error.”’ See also Hubble v. Somerville, 187 Md. 418, 422 , 50 A. 2d 565 [1947]

1973Second Nat’l Bank v. Wrightson, 63 Md. 81 [1885]; Bouldin [Boulden] v. Wood, 96 Md. 336 [332] ( 53 A. 911 ) [1903], And the evidence required for this purpose must be of the strongest character and the proof must be convincing.” ’ The Court, in Brockmeyer v. Norris, 177 Md. 466, 473 , 10 A. 2d 326 [1940], quoted, with approval, this passage from Pomeroy: ‘ “Courts of equity do not grant the high remedy of reformation upon a probability, nor even upon a mere preponderance of evidence, but only upon a certainty of the error.”’ See also Hubble v. Somerville, 187 Md. 418, 422 , 50 A. 2d 565 [1947]

31962–1973
Urquhart v. Alexander & Alexander, Inc. green
md · 1972
2 sentences

1973Second Nat’l Bank v. Wrightson, 63 Md. 81 [1885]; Bouldin [Boulden] v. Wood, 96 Md. 336 [332] ( 53 A. 911 ) [1903], And the evidence required for this purpose must be of the strongest character and the proof must be convincing.” ’ The Court, in Brockmeyer v. Norris, 177 Md. 466, 473 , 10 A. 2d 326 [1940], quoted, with approval, this passage from Pomeroy: ‘ “Courts of equity do not grant the high remedy of reformation upon a probability, nor even upon a mere preponderance of evidence, but only upon a certainty of the error.”’ See also Hubble v. Somerville, 187 Md. 418, 422 , 50 A. 2d 565 [1947]

1973Second Nat’l Bank v. Wrightson, 63 Md. 81 [1885]; Bouldin [Boulden] v. Wood, 96 Md. 336 [332] ( 53 A. 911 ) [1903], And the evidence required for this purpose must be of the strongest character and the proof must be convincing.” ’ The Court, in Brockmeyer v. Norris, 177 Md. 466, 473 , 10 A. 2d 326 [1940], quoted, with approval, this passage from Pomeroy: ‘ “Courts of equity do not grant the high remedy of reformation upon a probability, nor even upon a mere preponderance of evidence, but only upon a certainty of the error.”’ See also Hubble v. Somerville, 187 Md. 418, 422 , 50 A. 2d 565 [1947]

31962–1973
MacKe Co. v. Pizza of Gaithersburg, Inc. green
md · 1970
1 sentence

1983After describing the certainty requirement, though, Macke agrees with Robeson that "the use of a defendant’s future earnings [is] an appropriate method of determining lost profits....” 259 Md. at 492 .

11983–1983
Boulden v. Wood green
md · 1903
1 sentence

1973Second Nat’l Bank v. Wrightson, 63 Md. 81 [1885]; Bouldin [Boulden] v. Wood, 96 Md. 336 [332] ( 53 A. 911 ) [1903], And the evidence required for this purpose must be of the strongest character and the proof must be convincing.” ’ The Court, in Brockmeyer v. Norris, 177 Md. 466, 473 , 10 A. 2d 326 [1940], quoted, with approval, this passage from Pomeroy: ‘ “Courts of equity do not grant the high remedy of reformation upon a probability, nor even upon a mere preponderance of evidence, but only upon a certainty of the error.”’ See also Hubble v. Somerville, 187 Md. 418, 422 , 50 A. 2d 565 [1947]

11973–1973
Second National Bank v. Wrightson neutral
md · 1885
1 sentence

1973Second Nat’l Bank v. Wrightson, 63 Md. 81 [1885]; Bouldin [Boulden] v. Wood, 96 Md. 336 [332] ( 53 A. 911 ) [1903], And the evidence required for this purpose must be of the strongest character and the proof must be convincing.” ’ The Court, in Brockmeyer v. Norris, 177 Md. 466, 473 , 10 A. 2d 326 [1940], quoted, with approval, this passage from Pomeroy: ‘ “Courts of equity do not grant the high remedy of reformation upon a probability, nor even upon a mere preponderance of evidence, but only upon a certainty of the error.”’ See also Hubble v. Somerville, 187 Md. 418, 422 , 50 A. 2d 565 [1947]

11973–1973
Housing Equity Corp. v. Joyce green
md · 1972
2 sentences

1973More recently, we quoted Moyer with approval in Housing Equity Corp. v. Joyce, 265 Md. 570, 580-81 , 290 A. 2d 769 (1972).

1973More recently, we quoted Moyer with approval in Housing Equity Corp. v. Joyce, 265 Md. 570, 580-81 , 290 A. 2d 769 (1972).

11973–1973
Moyer v. Title Guarantee Co. green
md · 1962
1 sentence

1972And the evidence required for this purpose must be of the strongest character and the proof must be convincing.” ’ The Court, in Brockmeyer v. Norris, 177 Md. 466, 473 , 10 A. 2d 326 [1940], quoted, with approval, this passage from Pomeroy : ‘ “Courts of equity do not grant the high remedy of reformation upon a probability, nor even upon a mere preponderance of evidence, but only upon a certainty of the error.” ’ See also Hubble v. Somerville, 187 Md. 418, 422 , 50 A. 2d 565 [1947]; Urquhart v. Alexander, 218 Md. 405, 411 , 147 A. 2d 213 [1958].” 227 Md. at 504 Housing Equity does not rest its

11972–1972
Dulany v. Rogers green
md · 1879
1 sentence

1947In that case the Court quotes from Dulany v. Rogers, 50 Md. 524 , 533: “It is incumbent, however, upon the party seeking to reform a written instrument to show by conclusive proof, that it does not embody the final intention of the parties; Courts will not rectify it unless it was executed under a common mistake—both parties having done that which neither of them intended.

11947–1947

Where else courts name it

CA 40 (1983–2025) CT 37 (1993–2020) MI 29 (1945–2026) NY 24 (1915–2013) NJ 19 (1934–2024) ND 17 (1912–2019) OH 17 (1912–2020) FL 13 (1990–2024) NC 10 (1926–2023) WA 10 (1935–2025) MD 9 (1947–2016) LA 9 (1985–2026) IL 8 (1979–1995) OR 7 (1913–2014) CO 7 (1894–2016) TX 6 (1986–2005) KS 5 (1880–1979) MO 5 (1891–1945) TN 5 (1998–2019) OK 5 (2005–2019) DE 4 (1915–2000) SD 4 (1988–2022) VT 3 (2004–2018) PA 3 (1983–2015) AR 3 (1925–1988) SC 2 (1993–2004) HI 2 (1963–2008) UT 2 (1983–2009) AL 2 (1902–1925) GA 2 (2018–2018)

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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