due diligence standard (Maryland) · Go Syfert
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due diligence standard in Maryland

9 Maryland opinions name it 2 courts 1990–2022 4 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
Green v. Stategreen
md · 2017 · cited in 1 Maryland opinions naming this issue, 2021–2021
2 sentences

2021Appendix C of the Supplement9 noted that the due diligence requirement “is generally consistent with [ABA Standards] but is stated in somewhat broader terms.” Supplement, App’x C at 3.10 9 “Unlike a Committee Note, an appendix to a Report of the Rules Committee does not become incorporated into the Maryland Rules.” Green, 456 Md. at 145 n.8, 171 A.3d at 1189 n.8. 10 Assuming arguendo that the more permissive ABA due diligence obligation was the Maryland Rule, the State presumably still would have not violated discovery rules.

2021Appendix C of the Supplement9 noted that the due diligence requirement “is generally consistent with [ABA Standards] but is stated in somewhat broader terms.” Supplement, App’x C at 3.10 9 “Unlike a Committee Note, an appendix to a Report of the Rules Committee does not become incorporated into the Maryland Rules.” Green, 456 Md. at 145 n.8, 171 A.3d at 1189 n.8. 10 Assuming arguendo that the more permissive ABA due diligence obligation was the Maryland Rule, the State presumably still would have not violated discovery rules.

11
Keyes v. Stategreen
mdctspecapp · 2014 · cited in 1 Maryland opinions naming this issue, 2015–2015
2 sentences

2015See Keyes v. State, 215 Md.App. 660, 669 , 84 A.3d 141 (2014) (CP § 8-301(a)(2) defines a due diligence standard by express reference to Rule 4-321).

2015See Keyes v. State, 215 Md.App. 660, 669 , 84 A.3d 141 (2014) (CP § 8-301(a)(2) defines a due diligence standard by express reference to Rule 4-321).

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
Hunt v. State green
md · 2021
2 sentences

2022Id., 252 A.3d at 958 .

2022Id., 252 A.3d at 958 .

32022–2022
Jackson v. State green
md · 2000
1 sentence

2018Id.

12018–2018
State v. Seward green
mdctspecapp · 2014
2 sentences

2016Id. at 25-26 , 102 A.3d at 812-13 .

2016Id. at 25-26 , 102 A.3d at 812-13 .

12016–2016
Argyrou v. State green
md · 1998
2 sentences

2015In assessing the “due diligence” requirement in the context of a motion for a new trial pursuant to Rule 4-331(c), the Court of Appeals has interpreted the term “due diligence” as requiring that a litigant “act reasonably and in good faith to obtain the evidence, in light of the totality of the circumstances and the facts known to him or her.” Argy-rou, 349 Md. at 604-05 , 709 A.2d 1194 .

2015In assessing the “due diligence” requirement in the context of a motion for a new trial pursuant to Rule 4-331(c), the Court of Appeals has interpreted the term “due diligence” as requiring that a litigant “act reasonably and in good faith to obtain the evidence, in light of the totality of the circumstances and the facts known to him or her.” Argy-rou, 349 Md. at 604-05 , 709 A.2d 1194 .

12015–2015
Campbell v. State green
md · 2003
2 sentences

2014At the outset, we recognize that, generally, appellate review of a circuit court’s denial of a motion for new trial is limited to whether the trial court abused its discretion, see Campbell v. State, 373 Md. 637, 665 , 821 A.2d 1 (2003), but, because the issue before us is the legal sufficiency of the *670 petition, our review is de novo. 6 That said, caselaw addressing motions for new trial, on the grounds of newly discovered evidence, is instructive in determining what is “newly discovered evidence” and when it is sufficiently persuasive so as to “create[ ] a substantial or significant possi

2014At the outset, we recognize that, generally, appellate review of a circuit court’s denial of a motion for new trial is limited to whether the trial court abused its discretion, see Campbell v. State, 373 Md. 637, 665 , 821 A.2d 1 (2003), but, because the issue before us is the legal sufficiency of the *670 petition, our review is de novo. 6 That said, caselaw addressing motions for new trial, on the grounds of newly discovered evidence, is instructive in determining what is “newly discovered evidence” and when it is sufficiently persuasive so as to “create[ ] a substantial or significant possi

12014–2014
State v. Toney green
md · 1989
2 sentences

1990In fact, in State v. Toney, supra, 315 Md. at 133 , 553 A.2d 696 , the Court rejected this standard.

1990In fact, in State v. Toney, supra, 315 Md. at 133 , 553 A.2d 696 , the Court rejected this standard.

11990–1990

Where else courts name it

PA 156 (1979–2026) IL 138 (1976–2026) NY 133 (1984–2026) TX 110 (1979–2026) CA 51 (1946–2026) FL 38 (1982–2026) MI 26 (1973–2025) WA 20 (1987–2024) TN 20 (1995–2026) AL 13 (1992–2025) MD 9 (1990–2022) VA 9 (1996–2010) NV 7 (1994–2022) NM 7 (2001–2014) ME 7 (1997–2020) MO 7 (1994–2013) LA 7 (1976–2005) CO 6 (1994–2025) GA 6 (1998–2015) IA 6 (1994–2016) NC 6 (1985–2022) OH 6 (1998–2019) AK 5 (1985–1996) IN 5 (1972–2017) MT 5 (1980–2025) MN 4 (1987–1997) UT 4 (2003–2023) CT 4 (1976–2017) MS 4 (2009–2014) SD 3 (1981–2015) AZ 3 (1986–2021) WY 2 (1991–2002) KS 2 (1996–2004) HI 2 (1967–1991) DC 2 (1993–2013) DE 2 (2018–2019) MA 2 (1991–2013) WI 2 (2002–2019) OK 2 (1982–2023)

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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