anti-assignment clause (Maryland) · Go Syfert
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anti-assignment clause in Maryland

7 Maryland opinions name it 2 courts 1967–2025 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 (7)

CaseFollowedCited
Credible Behavioral Health v. Johnsongreen
md · 2019 · cited in 4 Maryland opinions naming this issue, 2024–2025
2 sentences

2025Health, 466 Md. at 393 (quoting Ocean Petroleum, Co. v. Yanek, 416 Md. 74, 86 (2010)).

2024Health, Inc. v. Johnson, 466 Md. 380, 393 (2019).

34
Orkin v. Jacobsongreen
md · 1975 · cited in 3 Maryland opinions naming this issue, 2024–2024
2 sentences

2024See Orkin v. Jacobson, 274 Md. 124, 130 (1975) (likening contract interpretation to statutory interpretation, including that a statute is to be read “so that no word, clause, sentence or phrase shall be rendered . . . meaningless”).

2024See Orkin v. Jacobson, 274 Md. 124, 130 (1975) (likening contract interpretation to statutory interpretation, including that a statute is to be read “so that no word, clause, sentence or phrase shall be rendered . . . meaningless”).

33
Trubowitch v. Riverbank Canning Co.green
cal · 1947 · cited in 2 Maryland opinions naming this issue, 1967–1990
2 sentences

1990Quoting from Chief Justice Traynor’s opinion for the court in Trubowitch v. Riverbank Canning Co., 30 Cal.2d 335, 344-45 , 182 P.2d 182, 188 (1947), we said that: “ ‘[I]f an assignment results merely from a change in the legal form of ownership of a business, its validity depends upon wheth *566 er it affects the interests of the parties protected by the nonassignability of the contract.’ ” 248 Md. at 104 , 234 A.2d at 879 (emphasis in original omitted).

1990Quoting from Chief Justice Traynor’s opinion for the court in Trubowitch v. Riverbank Canning Co., 30 Cal.2d 335, 344-45 , 182 P.2d 182, 188 (1947), we said that: “ ‘[I]f an assignment results merely from a change in the legal form of ownership of a business, its validity depends upon wheth *566 er it affects the interests of the parties protected by the nonassignability of the contract.’ ” 248 Md. at 104 , 234 A.2d at 879 (emphasis in original omitted).

22
Ocean Petroleum, Co. v. Yanekgreen
md · 2010 · cited in 1 Maryland opinions naming this issue, 2025–2025
1 sentence

2025Health, 466 Md. at 393 (quoting Ocean Petroleum, Co. v. Yanek, 416 Md. 74, 86 (2010)).

11
Central Collection v. Columbia Medicalgreen
md · 1984 · cited in 1 Maryland opinions naming this issue, 2025–2025
1 sentence

2025The same principle was also confirmed in State of Maryland, Central Collection Unit v. Columbia Medical Plan, where we held that an insured made a valid assignment of her right to hospital benefits under her health insurance policy. 300 Md. 318, 331-32 (1984).

11
Reese v. State Farm Mutual Automobile Insurancegreen
md · 1979 · cited in 1 Maryland opinions naming this issue, 1999–1999
2 sentences

1999Co., 285 Md. 548, 553 , 403 A.2d 1229, 1232 (1979). 2 The District Court entered judgment in favor of GEICO, holding that “the anti-assignment clause between Brenda Smith and [GEICO] was valid, enforceable and not waived.” That court reasoned “that Brenda Smith had no contractual right to assign any interest she had under her policy to anyone else without GEICO’s consent.

1999Co., 285 Md. 548, 553 , 403 A.2d 1229, 1232 (1979). 2 The District Court entered judgment in favor of GEICO, holding that “the anti-assignment clause between Brenda Smith and [GEICO] was valid, enforceable and not waived.” That court reasoned “that Brenda Smith had no contractual right to assign any interest she had under her policy to anyone else without GEICO’s consent.

11
Ruberoid v. GLASSMAN CONSTRUCTION COMPANY, INC.green
md · 1967 · cited in 1 Maryland opinions naming this issue, 1990–1990
2 sentences

1990Quoting from Chief Justice Traynor’s opinion for the court in Trubowitch v. Riverbank Canning Co., 30 Cal.2d 335, 344-45 , 182 P.2d 182, 188 (1947), we said that: “ ‘[I]f an assignment results merely from a change in the legal form of ownership of a business, its validity depends upon wheth *566 er it affects the interests of the parties protected by the nonassignability of the contract.’ ” 248 Md. at 104 , 234 A.2d at 879 (emphasis in original omitted).

1990Quoting from Chief Justice Traynor’s opinion for the court in Trubowitch v. Riverbank Canning Co., 30 Cal.2d 335, 344-45 , 182 P.2d 182, 188 (1947), we said that: “ ‘[I]f an assignment results merely from a change in the legal form of ownership of a business, its validity depends upon wheth *566 er it affects the interests of the parties protected by the nonassignability of the contract.’ ” 248 Md. at 104 , 234 A.2d at 879 (emphasis in original omitted).

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 (3)

CaseCitedYears
Dwayne Clay, M.D., P.C. v. Government Employees Insurance green
md · 1999
2 sentences

2025F Travelers and the MIA argue that, under both Michaelson v. Sokolove, 169 Md. 529 (1936), and Dwayne Clay, M.D., P.C. v. Government Employees Insurance Co., 356 Md. 257 (1999), the Assignment is subject to the anti-assignment clause in the policy.

2025Michaelson dealt with an anti-assignment clause in a life insurance policy, 169 Md. at 530 ; Clay involved a health insurance policy, 356 Md. at 261 .

42024–2025
Michaelson v. Sokolove green
md · 1936
2 sentences

2025F Travelers and the MIA argue that, under both Michaelson v. Sokolove, 169 Md. 529 (1936), and Dwayne Clay, M.D., P.C. v. Government Employees Insurance Co., 356 Md. 257 (1999), the Assignment is subject to the anti-assignment clause in the policy.

2025Michaelson dealt with an anti-assignment clause in a life insurance policy, 169 Md. at 530 ; Clay involved a health insurance policy, 356 Md. at 261 .

42024–2025
Consolidated Real Estate & Fire Insurance v. Cashow green
· 1874
2 sentences

2024Id. at 70 , 78–79.

2024Id. at 79–80.

32024–2024

Statutes the citing opinions construe

MD § Md. Code Ann., Ins. § 10-401 (3) MD § Md. Code Ann., Ins. § 2-210 (3) MD § Md. Code Ann., Ins. § 2-215 (3) MD § Md. Code Ann., Ins. § 27-102 (3) MD § Md. Code Ann., Ins. § 27-301 (3) MD § Md. Code Ann., Ins. § 27-303 (3)

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

MI 27 (2016–2020) TX 15 (1994–2020) DE 7 (2009–2022) MD 7 (1967–2025) NJ 7 (1997–2021) NY 6 (1952–2023) OR 5 (2006–2017) CO 5 (1987–2011) PA 5 (1984–2021) AZ 4 (1997–2025) IL 4 (1986–2020) NE 4 (2006–2016) MN 4 (2008–2024) NH 3 (2007–2022) NM 3 (1999–2009) FL 3 (2007–2015) CT 2 (2000–2002) NC 2 (1993–2021) UT 2 (2001–2013) CA 2 (2003–2003) SD 2 (2002–2007) GA 2 (2010–2024)

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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