law collateral order doctrine in Maryland

2010See also Nnoli v. Nnoli, 389 Md. 315, 324 , 884 A.2d 1215 (2005); Shoemaker v. Smith, 353 Md. 143, 165 , 725 A.2d 549 (1999).

2008Id.; Frase v. Barnhart, 379 Md. 100, 109-10 , 840 A.2d 114 (2003); Shoemaker v. Smith, 353 Md. 143, 165 , 725 A.2d 549 (1999).

2018"Those three exceptions are: appeals from interlocutory orders specifically allowed by statute; [ 10 ] immediate appeals permitted under Rule 2-602; [ 11 ] and appeals from interlocutory rulings allowed under the common law collateral order doctrine." FINALITY OF JUDGMENTS, at 47 (citing *61 Wash. Suburban Sanitary Comm'n v. Bowen , 410 Md. 287 , 295, 978 A.2d 678 (2009) ). *418 Applying the final-judgment rule in bifurcated circuit court proceedings, we can assume that unless one of the limited exceptions apply, an aggrieved litigant may not appeal until the circuit court enters a judgment th

2018"Those three exceptions are: appeals from interlocutory orders specifically allowed by statute; [ 10 ] immediate appeals permitted under Rule 2-602; [ 11 ] and appeals from interlocutory rulings allowed under the common law collateral order doctrine." FINALITY OF JUDGMENTS, at 47 (citing *61 Wash. Suburban Sanitary Comm'n v. Bowen , 410 Md. 287 , 295, 978 A.2d 678 (2009) ). *418 Applying the final-judgment rule in bifurcated circuit court proceedings, we can assume that unless one of the limited exceptions apply, an aggrieved litigant may not appeal until the circuit court enters a judgment th

2014Id. at 313-14, 22 A.3d 886 . (footnote, quotation marks, and citations omitted).

2013See, e.g., Kurstin v. Bromberg, 420 Md. 466, 480 , 24 A.3d 88 (2011); Harris v. State, 420 Md. 300, 312-13 , 22 A.3d 886 (2011).

2010The exceptions are: “ ‘appeals from interlocutory orders specifically allowed by statute; immediate appeals permitted under Maryland Rule 2-602;[ 7 ] and appeals from interlocutory *176 orders allowed under the common law collateral order doctrine.’ ” 392 Md. at 84 , 896 A.2d at 309 (quoting Salvagno v. Frew, 388 Md. 605, 615 , 881 A.2d 660, 666 (2005)).

2010The exceptions are: “ ‘appeals from interlocutory orders specifically allowed by statute; immediate appeals permitted under Maryland Rule 2-602;[ 7 ] and appeals from interlocutory *176 orders allowed under the common law collateral order doctrine.’ ” 392 Md. at 84 , 896 A.2d at 309 (quoting Salvagno v. Frew, 388 Md. 605, 615 , 881 A.2d 660, 666 (2005)).

2009The first two exceptions to the final judgment rule do not apply here; only the collateral order doctrine might justify Rios’s interlocutory appeal. *364 The Court of Appeals explained the collateral order doctrine in Hudson v. Housing Authority, 402 Md. 18, 25-26 , 935 A.2d 395 (2007): The collateral order doctrine permits a reviewing appellate court to treat as final, without consideration of the procedural posture of a case, a “narrow” class of interlocutory orders in “extraordinary circumstances.” Ehrlich v. Grove, 396 Md. 550, 561-62 , 914 A.2d 783, 791 (2007); In re Foley, 373 Md. 627, 6

2009The first two exceptions to the final judgment rule do not apply here; only the collateral order doctrine might justify Rios’s interlocutory appeal. *364 The Court of Appeals explained the collateral order doctrine in Hudson v. Housing Authority, 402 Md. 18, 25-26 , 935 A.2d 395 (2007): The collateral order doctrine permits a reviewing appellate court to treat as final, without consideration of the procedural posture of a case, a “narrow” class of interlocutory orders in “extraordinary circumstances.” Ehrlich v. Grove, 396 Md. 550, 561-62 , 914 A.2d 783, 791 (2007); In re Foley, 373 Md. 627, 6

2009Mary’s County v. Lacer, supra, 393 Md. at 424-425 , 903 A.2d at 383-384 .

2009Mary’s County v. Lacer, supra, 393 Md. at 424-425 , 903 A.2d at 383-384 .

2007The collateral order doctrine, recognized by the Supreme Court in Cohen v. Beneficial Industrial Loan Corporation, 337 U.S. 541 , 69 S.Ct. 1221 , 93 L.Ed. 1528 (1949), permits the prosecution of an appeal from a “narrow class of orders, referred to as collateral orders, which are offshoots of the principal litigation in which they are issued and which are immediately appealable as ‘final judgments’ without regard to the posture of the case.” Harris v. David S. Harris, P.A, 310 *154 Md. 310, 315, 529 A.2d 356 (1987).

2007The collateral order doctrine, recognized by the Supreme Court in Cohen v. Beneficial Industrial Loan Corporation, 337 U.S. 541 , 69 S.Ct. 1221 , 93 L.Ed. 1528 (1949), permits the prosecution of an appeal from a “narrow class of orders, referred to as collateral orders, which are offshoots of the principal litigation in which they are issued and which are immediately appealable as ‘final judgments’ without regard to the posture of the case.” Harris v. David S. Harris, P.A, 310 *154 Md. 310, 315, 529 A.2d 356 (1987).

2019App. at 662 , 94 A.3d 264 ), we must dismiss the appeal unless some exception to the final judgment rule applies. 1 "[T]here are only three exceptions to that final judgment requirement: appeals from interlocutory orders specifically allowed by statute; immediate appeals permitted under Maryland Rule 2-602 ; and appeals from interlocutory rulings allowed under the common law collateral order doctrine." Salvagno v. Frew , 388 Md. 605 , 615, 881 A.2d 660 (2005).

2018"Those three exceptions are: appeals from interlocutory orders specifically allowed by statute; [ 10 ] immediate appeals permitted under Rule 2-602; [ 11 ] and appeals from interlocutory rulings allowed under the common law collateral order doctrine." FINALITY OF JUDGMENTS, at 47 (citing *61 Wash. Suburban Sanitary Comm'n v. Bowen , 410 Md. 287 , 295, 978 A.2d 678 (2009) ). *418 Applying the final-judgment rule in bifurcated circuit court proceedings, we can assume that unless one of the limited exceptions apply, an aggrieved litigant may not appeal until the circuit court enters a judgment th

2018"Those three exceptions are: appeals from interlocutory orders specifically allowed by statute; [ 10 ] immediate appeals permitted under Rule 2-602; [ 11 ] and appeals from interlocutory rulings allowed under the common law collateral order doctrine." FINALITY OF JUDGMENTS, at 47 (citing *61 Wash. Suburban Sanitary Comm'n v. Bowen , 410 Md. 287 , 295, 978 A.2d 678 (2009) ). *418 Applying the final-judgment rule in bifurcated circuit court proceedings, we can assume that unless one of the limited exceptions apply, an aggrieved litigant may not appeal until the circuit court enters a judgment th

2017Bd. of Physicians v. Geier, 451 Md. 526, 546 , 154 A.3d 1211 (2017).

2017Bd. of Physicians v. Geier, 451 Md. 526, 546 , 154 A.3d 1211 (2017).

2015The standard of review utilized in considering the appealability of a court’s order denying a motion to withdraw was outlined by this Court in In re Franke, 207 Md.App. 679 , 55 A.3d 713 (2012): [T]he exercise of appellate jurisdiction in Maryland is normally dependent upon a final judgment rendered by the trial court[.] [However,] there are three exceptions to that rule: appeals from interlocutory orders specifically allowed by statute; immediate appeals permitted under Maryland Rule 2-602; and appeals from interlocutory rulings allowed *394 under the common law collateral order doctrine. [In

2015The standard of review utilized in considering the appealability of a court’s order denying a motion to withdraw was outlined by this Court in In re Franke, 207 Md.App. 679 , 55 A.3d 713 (2012): [T]he exercise of appellate jurisdiction in Maryland is normally dependent upon a final judgment rendered by the trial court[.] [However,] there are three exceptions to that rule: appeals from interlocutory orders specifically allowed by statute; immediate appeals permitted under Maryland Rule 2-602; and appeals from interlocutory rulings allowed *394 under the common law collateral order doctrine. [In

2015Addison v. Lochearn Nursing Home, LLC, 411 Md. 251, 273-74 , 983 A.2d 138 (2009); Hiob, 440 Md. at 475 n. 5.

2011Those exceptions are: “appeals from interlocutory orders specifically allowed by statute; immediate appeals permitted under Maryland Rule 2-602; 15 and appeals from interlocutory orders allowed under the common law collateral order doctrine.” Falik, 413 Md. at 175-76 , 991 A.2d at 1242 (quoting St.

2011Those exceptions are: “appeals from interlocutory orders specifically allowed by statute; immediate appeals permitted under Maryland Rule 2-602; 15 and appeals from interlocutory orders allowed under the common law collateral order doctrine.” Falik, 413 Md. at 175-76 , 991 A.2d at 1242 (quoting St.

2011Anne Arundel County v. Cambridge Commons, 167 Md.App. 219, 225 , 892 A.2d 593 (2005) (quoting Board of Education v. Bradford, 387 Md. 353, 382-83 , 875 A.2d 703 (2005) (further citations omitted)), cert. denied, 393 Md. 242 , 900 A.2d 749 (2006) .

2011Anne Arundel County v. Cambridge Commons, 167 Md.App. 219, 225 , 892 A.2d 593 (2005) (quoting Board of Education v. Bradford, 387 Md. 353, 382-83 , 875 A.2d 703 (2005) (further citations omitted)), cert. denied, 393 Md. 242 , 900 A.2d 749 (2006) .

2011Anne Arundel County v. Cambridge Commons, 167 Md.App. 219, 225 , 892 A.2d 593 (2005) (quoting Board of Education v. Bradford, 387 Md. 353, 382-83 , 875 A.2d 703 (2005) (further citations omitted)), cert. denied, 393 Md. 242 , 900 A.2d 749 (2006) .

2011Anne Arundel County v. Cambridge Commons, 167 Md.App. 219, 225 , 892 A.2d 593 (2005) (quoting Board of Education v. Bradford, 387 Md. 353, 382-83 , 875 A.2d 703 (2005) (further citations omitted)), cert. denied, 393 Md. 242 , 900 A.2d 749 (2006) .