mutuality requirement (Maryland) · Go Syfert
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mutuality requirement in Maryland

7 Maryland opinions name it 2 courts 1969–2018 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
Rourke v. Amchem Products, Inc.green
md · 2004 · cited in 2 Maryland opinions naming this issue, 2016–2018
2 sentences

2018See Rourke [, 384 Md. at 349 , 863 A.2d at 938 (2004) ].

2018See Rourke [, 384 Md. at 349 , 863 A.2d at 938 (2004) ].

22
Parklane Hosiery Co. v. Shoregreen
scotus · 1979 · cited in 3 Maryland opinions naming this issue, 2003–2007
2 sentences

2007Thus, the Court of Appeals holding was based on conflict of laws considerations rather than on the merits of offensive nonmutual collateral estoppel as a rule of law. 3 The Court did include, however, the following comment: The Supreme Court, as an aspect of Federal law, has departed from the mutuality requirement, although in Parklane Hosiery Co., Inc., v. Shore, 439 U.S. 322 , 99 S.Ct. 645 , 58 L.Ed.2d 552 , it expressed some concerns about, and refrained from blessing the broad application of, offensive non-mutuality.

2007Thus, the Court of Appeals holding was based on conflict of laws considerations rather than on the merits of offensive nonmutual collateral estoppel as a rule of law. 3 The Court did include, however, the following comment: The Supreme Court, as an aspect of Federal law, has departed from the mutuality requirement, although in Parklane Hosiery Co., Inc., v. Shore, 439 U.S. 322 , 99 S.Ct. 645 , 58 L.Ed.2d 552 , it expressed some concerns about, and refrained from blessing the broad application of, offensive non-mutuality.

13

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 (4)

CaseCitedYears
Pat Perusse Realty Co. v. Lingo green
md · 1968
2 sentences

2004Like the rules to which it is corollary, the theory of mutuality is also: “based upon policy and practical necessity and justice ... and on the same grounds of policy and justice there would be no objection to departing from it where the party affected has been given an adequate opportunity to be heard either personally or by representation.” Pat Perusse, 249 Md. at 42 , 238 A.2d at 106 .

2004Like the rules to which it is corollary, the theory of mutuality is also: “based upon policy and practical necessity and justice ... and on the same grounds of policy and justice there would be no objection to departing from it where the party affected has been given an adequate opportunity to be heard either personally or by representation.” Pat Perusse, 249 Md. at 42 , 238 A.2d at 106 .

12004–2004
Blonder-Tongue Laboratories, Inc. v. University of Illinois Foundation green
scotus · 1971
2 sentences

2004Another policy consideration was identified by the Supreme Court: “whether it is any longer tenable to afford a litigant more than one full and fair opportunity for judicial resolution of the same issue.” Blonder-Tongue Laboratories, Inc. v. University of Illinois Foundation, 402 U.S. at 328 , 91 S.Ct. at 1442 , 28 L.Ed.2d at 799 . 2 Fueled by the criticism of the mutuality principle and policy and justice concerns, the principle of non-mutual collateral estoppel 3 relatively recently has developed, as an exception to the mutuality principle.

2004Another policy consideration was identified by the Supreme Court: “whether it is any longer tenable to afford a litigant more than one full and fair opportunity for judicial resolution of the same issue.” Blonder-Tongue Laboratories, Inc. v. University of Illinois Foundation, 402 U.S. at 328 , 91 S.Ct. at 1442 , 28 L.Ed.2d at 799 . 2 Fueled by the criticism of the mutuality principle and policy and justice concerns, the principle of non-mutual collateral estoppel 3 relatively recently has developed, as an exception to the mutuality principle.

12004–2004
Standefer v. United States green
scotus · 1980
2 sentences

1992That limited exemption from the mutuality requirement of collateral estoppel “promoted judicial economy and conserved private resources without unfairness to the litigant against whom estoppel was invoked." 447 U.S. at 21 , 100 S.Ct. at 2007 .

1992That limited exemption from the mutuality requirement of collateral estoppel “promoted judicial economy and conserved private resources without unfairness to the litigant against whom estoppel was invoked." 447 U.S. at 21 , 100 S.Ct. at 2007 .

11992–1992
Ugast v. Lafontaine green
md · 1947
2 sentences

1969Kaplan urges that collateral estoppel without mutuality is still available to him as a defense under the indemnitor-indemnitee exception to the mutuality rule, citing Ugast v. LaFontaine, 189 Md. 227 , 55 A. 2d 705 (1947) and Restatement, Judgments § 97 (1942).

1969Kaplan urges that collateral estoppel without mutuality is still available to him as a defense under the indemnitor-indemnitee exception to the mutuality rule, citing Ugast v. LaFontaine, 189 Md. 227 , 55 A. 2d 705 (1947) and Restatement, Judgments § 97 (1942).

11969–1969

Where else courts name it

MI 44 (1943–2026) IL 32 (1956–2024) OH 21 (1983–2025) VA 18 (1974–2023) CT 16 (1988–2020) FL 13 (1976–2022) CA 10 (1978–2022) NC 10 (1983–2025) SC 8 (2008–2023) MD 7 (1969–2018) AR 7 (1974–2009) NJ 7 (1967–1993) WA 7 (1970–2019) NY 6 (1926–1989) MN 6 (1902–2012) NM 6 (1974–2002) AL 6 (1994–2024) CO 5 (1987–2017) VT 5 (1932–2018) AZ 5 (1981–2019) IN 5 (1984–2023) TX 5 (1970–1993) TN 5 (2006–2026) AK 4 (1970–1992) WI 4 (1986–1996) MO 4 (1920–2018) IA 3 (1975–2021) PA 3 (1977–1986) KS 3 (1986–2004) ND 3 (1992–2019) WY 2 (1984–2020) DE 2 (1991–2020) GA 2 (1974–1975) OR 2 (1952–2007) MA 2 (1954–1995) HI 2 (1975–2004) DC 2 (1980–1984) KY 2 (1964–2018)

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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