holder privilege in Maryland

2026Contested administrative hearings under IN § 27-303 are capable of creating collateral estoppel In Maryland, the keystone case on administrative collateral estoppel is Batson v. Shiflett, 325 Md. 684 (1992).

2019Offen v. Brenner , 402 Md. 191 , 199, 935 A.2d 719 (2007). 21 *588 Consistent with the Court's " 'broad view' of the scope of th[is] privilege," the Court has extended it to statements made in connection with "administrative and other quasi-judicial proceedings." *507 Imperial v. Drapeau , 351 Md. 38 , 45, 716 A.2d 244 (1998) (quoting Keys v. Chrysler Credit Corp. , 303 Md. at 404 , 494 A.2d 200 ).

2019Offen v. Brenner , 402 Md. 191 , 199, 935 A.2d 719 (2007). 21 *588 Consistent with the Court's " 'broad view' of the scope of th[is] privilege," the Court has extended it to statements made in connection with "administrative and other quasi-judicial proceedings." *507 Imperial v. Drapeau , 351 Md. 38 , 45, 716 A.2d 244 (1998) (quoting Keys v. Chrysler Credit Corp. , 303 Md. at 404 , 494 A.2d 200 ).

2019Offen v. Brenner , 402 Md. 191 , 199, 935 A.2d 719 (2007). 21 *588 Consistent with the Court's " 'broad view' of the scope of th[is] privilege," the Court has extended it to statements made in connection with "administrative and other quasi-judicial proceedings." *507 Imperial v. Drapeau , 351 Md. 38 , 45, 716 A.2d 244 (1998) (quoting Keys v. Chrysler Credit Corp. , 303 Md. at 404 , 494 A.2d 200 ).

2019Offen v. Brenner , 402 Md. 191 , 199, 935 A.2d 719 (2007). 21 *588 Consistent with the Court's " 'broad view' of the scope of th[is] privilege," the Court has extended it to statements made in connection with "administrative and other quasi-judicial proceedings." *507 Imperial v. Drapeau , 351 Md. 38 , 45, 716 A.2d 244 (1998) (quoting Keys v. Chrysler Credit Corp. , 303 Md. at 404 , 494 A.2d 200 ).

2019Offen v. Brenner , 402 Md. 191 , 199, 935 A.2d 719 (2007). 21 *588 Consistent with the Court's " 'broad view' of the scope of th[is] privilege," the Court has extended it to statements made in connection with "administrative and other quasi-judicial proceedings." *507 Imperial v. Drapeau , 351 Md. 38 , 45, 716 A.2d 244 (1998) (quoting Keys v. Chrysler Credit Corp. , 303 Md. at 404 , 494 A.2d 200 ).

2019Offen v. Brenner , 402 Md. 191 , 199, 935 A.2d 719 (2007). 21 *588 Consistent with the Court's " 'broad view' of the scope of th[is] privilege," the Court has extended it to statements made in connection with "administrative and other quasi-judicial proceedings." *507 Imperial v. Drapeau , 351 Md. 38 , 45, 716 A.2d 244 (1998) (quoting Keys v. Chrysler Credit Corp. , 303 Md. at 404 , 494 A.2d 200 ).

2012Court, 111 Nev. 345 , 891 P.2d 1180 ,1186 (1995) (“[W]aiver occurs when the holder of the privilege pleads a claim or defense in such a way that eventually he or she will be forced to draw upon the privileged communication at trial in order to prevail, and such a waiver does not violate the policies underlying the privilege.” (emphasis added)); Arnold v. City of Chattanooga, 19 S.W.3d 779, 787 (Tenn.Ct.App. 1999) (quoting Wardleigh, 111 Nev. 345 , 891 P.2d 1180 ). 49 Landlords disagree with these authorities, urging us to be guided by a footnote in our own decision in Ehrlich v. Grove, where w

2012Court, 111 Nev. 345 , 891 P.2d 1180 ,1186 (1995) (“[W]aiver occurs when the holder of the privilege pleads a claim or defense in such a way that eventually he or she will be forced to draw upon the privileged communication at trial in order to prevail, and such a waiver does not violate the policies underlying the privilege.” (emphasis added)); Arnold v. City of Chattanooga, 19 S.W.3d 779, 787 (Tenn.Ct.App. 1999) (quoting Wardleigh, 111 Nev. 345 , 891 P.2d 1180 ). 49 Landlords disagree with these authorities, urging us to be guided by a footnote in our own decision in Ehrlich v. Grove, where w

2012Court, 111 Nev. 345 , 891 P.2d 1180 ,1186 (1995) (“[W]aiver occurs when the holder of the privilege pleads a claim or defense in such a way that eventually he or she will be forced to draw upon the privileged communication at trial in order to prevail, and such a waiver does not violate the policies underlying the privilege.” (emphasis added)); Arnold v. City of Chattanooga, 19 S.W.3d 779, 787 (Tenn.Ct.App. 1999) (quoting Wardleigh, 111 Nev. 345 , 891 P.2d 1180 ). 49 Landlords disagree with these authorities, urging us to be guided by a footnote in our own decision in Ehrlich v. Grove, where w

2012Court, 111 Nev. 345 , 891 P.2d 1180 ,1186 (1995) (“[W]aiver occurs when the holder of the privilege pleads a claim or defense in such a way that eventually he or she will be forced to draw upon the privileged communication at trial in order to prevail, and such a waiver does not violate the policies underlying the privilege.” (emphasis added)); Arnold v. City of Chattanooga, 19 S.W.3d 779, 787 (Tenn.Ct.App. 1999) (quoting Wardleigh, 111 Nev. 345 , 891 P.2d 1180 ). 49 Landlords disagree with these authorities, urging us to be guided by a footnote in our own decision in Ehrlich v. Grove, where w

2000It begins with a far more general statement, taken from an earlier case, that the holder of the privilege "will not be permitted to `absolve himself from liability and at the same time assert the privilege in order to prevent the other party from ascertaining the truth of the claim.'" Id. at 926 (quoting Clark v. District Court, 668 P.2d 3, 8 (Colo.1983)).

2000It begins with a far more general statement, taken from an earlier case, that the holder of the privilege “will not be permitted to ‘absolve himself from liability and at the same time assert the privilege in order to prevent the other party from ascertaining the truth of the claim.’ ” Id. at 926 (quoting Clark v. District Court, 668 P.2d 3, 8 (Colo.1983)).

1976A similar waiver was before the United States District Court for the District of Maryland in General Cigar Co. v. Lancaster Leaf Tobacco Co., 323 F. Supp. 931 (1971).

1904That would be an acknowledgment of an existing debt, which under our decisions would clearly remove *92 the bar of the statute, such as Keplinger v. Griffith, 2 G. & J. 296 ; Beeler v. Clarke, 90 Md. 221 , and Babylon v. Duttera, 89 Md. 444 .

1904That would be an acknowledgment of an existing debt, which under our decisions would clearly remove *92 the bar of the statute, such as Keplinger v. Griffith, 2 G. & J. 296 ; Beeler v. Clarke, 90 Md. 221 , and Babylon v. Duttera, 89 Md. 444 .

1904That would be an acknowledgment of an existing debt, which under our decisions would clearly remove *92 the bar of the statute, such as Keplinger v. Griffith, 2 G. & J. 296 ; Beeler v. Clarke, 90 Md. 221 , and Babylon v. Duttera, 89 Md. 444 .