res ipsa doctrine (Maryland) · Go Syfert
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res ipsa doctrine in Maryland

9 Maryland opinions name it 2 courts 1970–2011 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 (7)

CaseFollowedCited
Ramsey v. D.P.A. Associatesgreen
md · 1972 · cited in 2 Maryland opinions naming this issue, 1975–1993
2 sentences

1993Id. at 644, 229 A.2d 79 ; see also Ramsey, 265 Md. at 326 , 289 A.2d 321 (1972) (“A glass door through which occupants of an apartment house and their guests constantly pass and repass is not under such exclusive control of the landlord as to permit invocation of the res ipsa doctrine.”), overruled on other grounds by B & K Rentals and Sales Co. v. Universal Leaf Tobacco Co., 324 Md. 147 , 596 A.2d 640 (1991); Dorsey v. General Elevator Co., 241 Md. 99, 107 , 215 A.2d 757 (1966) (elevator service company did not have control of elevator because it was manually operated); Burkowske v. Church Ho

1993Id. at 644, 229 A.2d 79 ; see also Ramsey, 265 Md. at 326 , 289 A.2d 321 (1972) (“A glass door through which occupants of an apartment house and their guests constantly pass and repass is not under such exclusive control of the landlord as to permit invocation of the res ipsa doctrine.”), overruled on other grounds by B & K Rentals and Sales Co. v. Universal Leaf Tobacco Co., 324 Md. 147 , 596 A.2d 640 (1991); Dorsey v. General Elevator Co., 241 Md. 99, 107 , 215 A.2d 757 (1966) (elevator service company did not have control of elevator because it was manually operated); Burkowske v. Church Ho

12
Leikach v. Royal Crown Bottling Co. of Baltimore, Inc.green
md · 1971 · cited in 2 Maryland opinions naming this issue, 1975–1986
2 sentences

1986Leikach, supra, 261 Md. at 542, 276 A.2d 81 .

1986Leikach, supra, 261 Md. at 542, 276 A.2d 81 .

12
Joyce A. Robinson v. Burlington Northern Railroad Companygreen
ca7 · 1997 · cited in 1 Maryland opinions naming this issue, 2011–2011
1 sentence

2011Lines, 473 F.2d 821, 826 (5th Cir.1973) (Freight car door fell on employee, a car-cleaner, when he opened the door to clean the car. ”[T]he teachings of Jesionowski mandate the rejection” of the railroad’s argument "that by opening the boxcar door Dugas was at least in partial control of the instrumentality whence came the injuries, thus defeating the application of the res ipsa doctrine.”); Robinson v. Burlington N. R.R., 131 F.3d 648, 653 (7th Cir.1997) ("In Jesionowski , which remains the *487 governing precedent, the Supreme Court emphasized that, in the context oí FELA cases, federal cour

11
R. P. Dugas v. The Kansas City Southern Railway Linesgreen
ca5 · 1973 · cited in 1 Maryland opinions naming this issue, 2011–2011
1 sentence

2011Lines, 473 F.2d 821, 826 (5th Cir.1973) (Freight car door fell on employee, a car-cleaner, when he opened the door to clean the car. ”[T]he teachings of Jesionowski mandate the rejection” of the railroad’s argument "that by opening the boxcar door Dugas was at least in partial control of the instrumentality whence came the injuries, thus defeating the application of the res ipsa doctrine.”); Robinson v. Burlington N. R.R., 131 F.3d 648, 653 (7th Cir.1997) ("In Jesionowski , which remains the *487 governing precedent, the Supreme Court emphasized that, in the context oí FELA cases, federal cour

11
B & K Rentals & Sales Co. v. Universal Leaf Tobacco Co.green
md · 1991 · cited in 1 Maryland opinions naming this issue, 1993–1993
2 sentences

1993Id. at 644, 229 A.2d 79 ; see also Ramsey, 265 Md. at 326 , 289 A.2d 321 (1972) (“A glass door through which occupants of an apartment house and their guests constantly pass and repass is not under such exclusive control of the landlord as to permit invocation of the res ipsa doctrine.”), overruled on other grounds by B & K Rentals and Sales Co. v. Universal Leaf Tobacco Co., 324 Md. 147 , 596 A.2d 640 (1991); Dorsey v. General Elevator Co., 241 Md. 99, 107 , 215 A.2d 757 (1966) (elevator service company did not have control of elevator because it was manually operated); Burkowske v. Church Ho

1993Id. at 644, 229 A.2d 79 ; see also Ramsey, 265 Md. at 326 , 289 A.2d 321 (1972) (“A glass door through which occupants of an apartment house and their guests constantly pass and repass is not under such exclusive control of the landlord as to permit invocation of the res ipsa doctrine.”), overruled on other grounds by B & K Rentals and Sales Co. v. Universal Leaf Tobacco Co., 324 Md. 147 , 596 A.2d 640 (1991); Dorsey v. General Elevator Co., 241 Md. 99, 107 , 215 A.2d 757 (1966) (elevator service company did not have control of elevator because it was manually operated); Burkowske v. Church Ho

11
Delahunt v. United Telephone & Telegraph Co.green
pa · 1906 · cited in 1 Maryland opinions naming this issue, 1975–1975
2 sentences

1975Co., 64 A. 515, 517 (Pa. 1906): “Where the thing is shown to be under the management of the defendant or his servants, and the accident is such as in the ordinary course of things does not happen if those who have the management use proper care, it affords reasonable evidence, in the absence of explanation by the defendants, that the accident arose from want of care ” In Kane v. Ten Eyck Co., Inc., supra, Jungjohann v. Hotel Buffalo, supra, and Brown Hotel Company v. Marx, supra, the doctrine of res ipsa was applied when an injury to a guest in a hotel was caused by the breaking of a handle of

1975Co., 64 A. 515, 517 (Pa. 1906): “Where the thing is shown to be under the management of the defendant or his servants, and the accident is such as in the ordinary course of things does not happen if those who have the management use proper care, it affords reasonable evidence, in the absence of explanation by the defendants, that the accident arose from want of care ” In Kane v. Ten Eyck Co., Inc., supra, Jungjohann v. Hotel Buffalo, supra, and Brown Hotel Company v. Marx, supra, the doctrine of res ipsa was applied when an injury to a guest in a hotel was caused by the breaking of a handle of

11
Hickory Transfer Co. v. Nezbedgreen
md · 1953 · cited in 1 Maryland opinions naming this issue, 1970–1970
2 sentences

1970We find the presumption in the present case analogous to the presumption established under the doctrine of res ipsa, loquitur and we find that the language of Chief Judge Sobeloff, speaking for the Court, in Hickory Transfer Co., Inc. v. Nezbed, 202 Md. 253, 263 , 96 A. 2d 241, 245 (1953) to be applicable here: “When the plaintiff invokes this procedure [res ipsa loquitur], thus putting his reliance upon the inference of negligence springing from the event, it has been authoritatively held that it must not appear by his own evidence, or the evidence adduced in his behalf, that causes for which

1970We find the presumption in the present case analogous to the presumption established under the doctrine of res ipsa, loquitur and we find that the language of Chief Judge Sobeloff, speaking for the Court, in Hickory Transfer Co., Inc. v. Nezbed, 202 Md. 253, 263 , 96 A. 2d 241, 245 (1953) to be applicable here: “When the plaintiff invokes this procedure [res ipsa loquitur], thus putting his reliance upon the inference of negligence springing from the event, it has been authoritatively held that it must not appear by his own evidence, or the evidence adduced in his behalf, that causes for which

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
Hanes v. State, Use of Lamm green
md · 1964
2 sentences

2009Unsatisfied Claim & Judgment Fund Board v. Bowles, 25 Md.App. 558 , 563 n. 2, 334 A.2d 532 (1975) (stating it was appropriate to consider the applicability of res ipsa despite the parties’ failure to raise it because under the Maryland rules of practice the res ipsa doctrine is not a rule of pleading but relates to the burden of proof and sufficiency of evidence.) (citing Hanes, 236 Md. at 32 , 202 A.2d 364 ).

2009Unsatisfied Claim & Judgment Fund Board v. Bowles, 25 Md.App. 558 , 563 n. 2, 334 A.2d 532 (1975) (stating it was appropriate to consider the applicability of res ipsa despite the parties’ failure to raise it because under the Maryland rules of practice the res ipsa doctrine is not a rule of pleading but relates to the burden of proof and sufficiency of evidence.) (citing Hanes, 236 Md. at 32 , 202 A.2d 364 ).

31975–2009
UNSAT. C. & J. FUND BD. v. Bowles green
mdctspecapp · 1975
2 sentences

2009Unsatisfied Claim & Judgment Fund Board v. Bowles, 25 Md.App. 558 , 563 n. 2, 334 A.2d 532 (1975) (stating it was appropriate to consider the applicability of res ipsa despite the parties’ failure to raise it because under the Maryland rules of practice the res ipsa doctrine is not a rule of pleading but relates to the burden of proof and sufficiency of evidence.) (citing Hanes, 236 Md. at 32 , 202 A.2d 364 ).

2009Unsatisfied Claim & Judgment Fund Board v. Bowles, 25 Md.App. 558 , 563 n. 2, 334 A.2d 532 (1975) (stating it was appropriate to consider the applicability of res ipsa despite the parties’ failure to raise it because under the Maryland rules of practice the res ipsa doctrine is not a rule of pleading but relates to the burden of proof and sufficiency of evidence.) (citing Hanes, 236 Md. at 32 , 202 A.2d 364 ).

12009–2009
Dorsey v. General Elevator Co. neutral
md · 1966
2 sentences

1993Id. at 644, 229 A.2d 79 ; see also Ramsey, 265 Md. at 326 , 289 A.2d 321 (1972) (“A glass door through which occupants of an apartment house and their guests constantly pass and repass is not under such exclusive control of the landlord as to permit invocation of the res ipsa doctrine.”), overruled on other grounds by B & K Rentals and Sales Co. v. Universal Leaf Tobacco Co., 324 Md. 147 , 596 A.2d 640 (1991); Dorsey v. General Elevator Co., 241 Md. 99, 107 , 215 A.2d 757 (1966) (elevator service company did not have control of elevator because it was manually operated); Burkowske v. Church Ho

1993Id. at 644, 229 A.2d 79 ; see also Ramsey, 265 Md. at 326 , 289 A.2d 321 (1972) (“A glass door through which occupants of an apartment house and their guests constantly pass and repass is not under such exclusive control of the landlord as to permit invocation of the res ipsa doctrine.”), overruled on other grounds by B & K Rentals and Sales Co. v. Universal Leaf Tobacco Co., 324 Md. 147 , 596 A.2d 640 (1991); Dorsey v. General Elevator Co., 241 Md. 99, 107 , 215 A.2d 757 (1966) (elevator service company did not have control of elevator because it was manually operated); Burkowske v. Church Ho

11993–1993
Smith v. Kelly green
md · 1967
2 sentences

1993Id. at 644, 229 A.2d 79 ; see also Ramsey, 265 Md. at 326 , 289 A.2d 321 (1972) (“A glass door through which occupants of an apartment house and their guests constantly pass and repass is not under such exclusive control of the landlord as to permit invocation of the res ipsa doctrine.”), overruled on other grounds by B & K Rentals and Sales Co. v. Universal Leaf Tobacco Co., 324 Md. 147 , 596 A.2d 640 (1991); Dorsey v. General Elevator Co., 241 Md. 99, 107 , 215 A.2d 757 (1966) (elevator service company did not have control of elevator because it was manually operated); Burkowske v. Church Ho

1993Id. at 644, 229 A.2d 79 ; see also Ramsey, 265 Md. at 326 , 289 A.2d 321 (1972) ("A glass door through which occupants of an apartment house and their guests constantly pass and repass is not under such exclusive control of the landlord as to permit invocation of the res ipsa doctrine."), overruled on other grounds by B & K Rentals and Sales Co. v. Universal Leaf Tobacco Co., 324 Md. 147 , 596 A.2d 640 (1991); Dorsey v. General Elevator Co., 241 Md. 99, 107 , 215 A.2d 757 (1966) (elevator service company did not have control of elevator because it was manually operated); Burkowske v. Church Ho

11993–1993
Burkowske v. Church Hospital Corp. green
mdctspecapp · 1982
2 sentences

1993Corp., 50 Md.App. 515, 523 , 439 A.2d 40 (defendant hospital did not have exclusive posses sion and control over a bench that collapsed for unknown reasons), cert, denied, 293 Md. 331 (1982).

1993Corp., 50 Md.App. 515, 523 , 439 A.2d 40 (defendant hospital did not have exclusive posses sion and control over a bench that collapsed for unknown reasons), cert, denied, 293 Md. 331 (1982).

11993–1993
Brown Hotel Company v. Marx green
kyctapphigh · 1967
2 sentences

1975Co., 64 A. 515, 517 (Pa. 1906): “Where the thing is shown to be under the management of the defendant or his servants, and the accident is such as in the ordinary course of things does not happen if those who have the management use proper care, it affords reasonable evidence, in the absence of explanation by the defendants, that the accident arose from want of care ” In Kane v. Ten Eyck Co., Inc., supra, Jungjohann v. Hotel Buffalo, supra, and Brown Hotel Company v. Marx, supra, the doctrine of res ipsa was applied when an injury to a guest in a hotel was caused by the breaking of a handle of

1975Co., 64 A. 515, 517 (Pa. 1906): “Where the thing is shown to be under the management of the defendant or his servants, and the accident is such as in the ordinary course of things does not happen if those who have the management use proper care, it affords reasonable evidence, in the absence of explanation by the defendants, that the accident arose from want of care ” In Kane v. Ten Eyck Co., Inc., supra, Jungjohann v. Hotel Buffalo, supra, and Brown Hotel Company v. Marx, supra, the doctrine of res ipsa was applied when an injury to a guest in a hotel was caused by the breaking of a handle of

11975–1975
Kane v. Ten Eyck Co. green
nysupct · 1943
2 sentences

1975Co., 64 A. 515, 517 (Pa. 1906): “Where the thing is shown to be under the management of the defendant or his servants, and the accident is such as in the ordinary course of things does not happen if those who have the management use proper care, it affords reasonable evidence, in the absence of explanation by the defendants, that the accident arose from want of care ” In Kane v. Ten Eyck Co., Inc., supra, Jungjohann v. Hotel Buffalo, supra, and Brown Hotel Company v. Marx, supra, the doctrine of res ipsa was applied when an injury to a guest in a hotel was caused by the breaking of a handle of

1975Co., 64 A. 515, 517 (Pa. 1906): “Where the thing is shown to be under the management of the defendant or his servants, and the accident is such as in the ordinary course of things does not happen if those who have the management use proper care, it affords reasonable evidence, in the absence of explanation by the defendants, that the accident arose from want of care ” In Kane v. Ten Eyck Co., Inc., supra, Jungjohann v. Hotel Buffalo, supra, and Brown Hotel Company v. Marx, supra, the doctrine of res ipsa was applied when an injury to a guest in a hotel was caused by the breaking of a handle of

11975–1975
Schanberg v. State neutral
nyclaimsct · 1969
1 sentence

1975In Schanberg v. New York, 296 N.Y.S.2d 646 (1969) *594 it applied where the faucet handle which broke was in an office of the Attorney General of New York.

11975–1975
Jungjohann v. Hotel Buffalo green
nyappdiv · 1958
2 sentences

1975Co., 64 A. 515, 517 (Pa. 1906): “Where the thing is shown to be under the management of the defendant or his servants, and the accident is such as in the ordinary course of things does not happen if those who have the management use proper care, it affords reasonable evidence, in the absence of explanation by the defendants, that the accident arose from want of care ” In Kane v. Ten Eyck Co., Inc., supra, Jungjohann v. Hotel Buffalo, supra, and Brown Hotel Company v. Marx, supra, the doctrine of res ipsa was applied when an injury to a guest in a hotel was caused by the breaking of a handle of

1975Co., 64 A. 515, 517 (Pa. 1906): “Where the thing is shown to be under the management of the defendant or his servants, and the accident is such as in the ordinary course of things does not happen if those who have the management use proper care, it affords reasonable evidence, in the absence of explanation by the defendants, that the accident arose from want of care ” In Kane v. Ten Eyck Co., Inc., supra, Jungjohann v. Hotel Buffalo, supra, and Brown Hotel Company v. Marx, supra, the doctrine of res ipsa was applied when an injury to a guest in a hotel was caused by the breaking of a handle of

11975–1975
Strasburger v. Vogel green
md · 1906
2 sentences

1970Such was the holding of this court, speaking through Chief Judge McSherry, in Strasburger v. Vogel, 103 Md. 85 , 63 A. 202 .

1970Such was the holding of this court, speaking through Chief Judge McSherry, in Strasburger v. Vogel, 103 Md. 85 , 63 A. 202 .

11970–1970

Where else courts name it

MO 58 (1931–2004) CA 37 (1934–2013) TX 34 (1972–2025) IL 27 (1926–2026) IA 25 (1915–2026) NY 22 (1943–2019) NJ 18 (1950–2026) FL 16 (1946–2017) LA 14 (1942–2017) PA 12 (1979–2023) MN 12 (1921–2023) AZ 9 (1955–2008) MD 9 (1970–2011) OH 8 (1929–2008) NC 7 (1906–2013) TN 7 (1946–2011) MT 6 (1918–1983) ME 5 (1946–2021) OR 5 (1951–2011) IN 5 (1928–2007) UT 4 (1984–1996) KY 4 (1944–1957) WI 4 (1975–2022) CO 4 (1960–2009) ID 3 (1949–1979) CT 3 (1947–1999) DC 3 (1970–2026) OK 3 (1952–1997) NM 3 (1992–1996) MS 3 (1970–2022) AR 3 (1968–2001) SD 2 (1975–1981) SC 2 (1958–1984) GA 2 (1958–1975) KS 2 (1934–2000) MA 2 (1996–2010)

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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