Justia Maryland Supreme Court Opinion Summaries

Janice Hollabaugh authorized her attorney to request her medical records from a health care provider for a personal injury claim. The provider contracted with MRO Corporation to fulfill the request. MRO sent a "Cancellation Invoice" to Hollabaugh’s attorney, stating that the request was canceled and charged a $22.88 fee for searching for the records, even though no records were produced. Hollabaugh reimbursed her attorney for the fee and subsequently filed a class action lawsuit against MRO, alleging that the fee violated the Confidentiality of Medical Records Act.The Circuit Court for Baltimore County determined that Hollabaugh had standing but concluded that the Act authorized MRO’s fee, leading to the dismissal of the case. The Appellate Court of Maryland affirmed the standing decision but also upheld the fee's authorization under the Act. Hollabaugh then petitioned the Supreme Court of Maryland, which granted certiorari to review the case.The Supreme Court of Maryland held that Hollabaugh had standing to sue because she reimbursed her attorney for the fee, creating a reasonable inference of injury. The Court further held that the Confidentiality of Medical Records Act does not permit a health care provider to charge a preparation fee for a search that does not result in the production of any medical records. The Court reasoned that the statutory language and context imply that fees are only authorized for the retrieval and preparation of existing records. Consequently, the Court affirmed the lower court's decision on standing but reversed the decision regarding the fee's authorization, remanding the case for further proceedings consistent with its opinion. View "Hollabaugh v. MRO Corporation" on Justia Law

Estefany Martinez, a former Amazon employee, worked as a Fulfillment Associate at the Baltimore Fulfillment Center from June 2017 to November 2021. She and other employees were required to clock out before undergoing a post-shift security screening process, for which they were not compensated. Martinez brought a backpack into the work area, which required her to use the bag scan lane during the security screening, often resulting in delays. Data showed that the time taken to exit the facility after clocking out varied, with some instances exceeding five minutes.Martinez filed a lawsuit against Amazon in the Circuit Court for Baltimore City, which was later removed to federal court. The United States District Court for the District of Maryland certified a question to the Supreme Court of Maryland regarding the applicability of the de minimis doctrine to claims under the Maryland Wage Payment and Collection Law and the Maryland Wage and Hour Law. The district court granted Martinez’s Motion for Class Certification and stayed the case pending the resolution of the certified question.The Supreme Court of Maryland held that the de minimis doctrine, as described in Anderson v. Mt. Clemens Pottery Company, applies to claims brought under the Maryland Wage and Hour Law and the Maryland Wage Payment and Collection Law. The court concluded that the doctrine, which disregards negligible periods of work time, is consistent with the legislative intent of the Maryland Wage Laws, which are patterned after the Fair Labor Standards Act. The court answered the certified question in the affirmative, confirming that the de minimis rule applies to the Maryland Wage Laws. View "Martinez v. Amazon" on Justia Law

The case involves two homebuyers, Wynton Sanders and Tosha Lindsey, who entered into contracts with SM Landover, LLC and SM Parkside, LLC, respectively, for the purchase of new homes. Both contracts included provisions for deferred water and sewer charges and a one-year statute of limitations for bringing any claims related to the contracts. The homebuyers later filed class action complaints alleging that the sellers failed to disclose required information about the deferred charges, as mandated by Maryland law.The Circuit Court for Prince George’s County consolidated the cases for pretrial purposes and dismissed the complaints with prejudice. The court found that the sellers did not need to register as home builders because Stanley Martin Companies, LLC, a registered home builder, was also a party to the contracts. The court also concluded that the homebuyers’ claims accrued at the time of contracting, making them time-barred under the one-year contractual limitations period.The Appellate Court of Maryland affirmed in part and reversed in part. It held that the one-year contractual limitations period was reasonable and that the homebuyers’ claims accrued at the time of settlement, not contracting. Therefore, the claims were timely. However, the court also held that the sellers did not need to register as home builders because a registered home builder was a party to the contracts.The Supreme Court of Maryland reviewed the case and held that the homebuyers’ claims accrued at the time of contracting. The court also held that the sellers were required to register as home builders under Maryland law, even though a registered home builder was a party to the contracts. Consequently, the sellers could not enforce the one-year contractual limitations period, making the homebuyers’ claims timely. The court affirmed in part and reversed in part the judgment of the Appellate Court of Maryland. View "SM Landover LLC v. Sanders" on Justia Law

The Supreme Court of Maryland has ruled that the term "rent" under Real Property § 8-401, as applied to residential leases, refers to the fixed, periodic payments a tenant is required to make for use or occupancy of a rented premises. This definition excludes additional charges such as late fees, attorney’s fees, and court costs. The court also ruled that any provision in a residential lease that allows a landlord to allocate payments of "rent" to other obligations, thereby subjecting a tenant to eviction proceedings based on failure to pay "rent", violates Real Property § 8-208(d)(2). Further, penalties for late payment of rent, capped at 5% of the monthly amount of rent due, are inclusive of any costs of collection other than court-awarded costs. Finally, the court ruled that the Circuit Court erred in declining to review the merits of the tenants’ second renewed motion for class certification. The case has been remanded for further proceedings in line with these holdings. View "Westminster Management v. Smith" on Justia Law

The Court of Appeals affirmed the judgment of the circuit court ruling that Baltimore City had breached its contract with two out of three sub-classes of police officers and firefighters and finding that Ordinance 10-306 retrospectively divested the members of those sub-classes of benefits they had earned, holding that there were no factual or legal errors in the circuit court's rulings.Baltimore City maintained a Fire and Police Employees' Retirement System (the Plan) to provide pension benefits to members of the City's police and fire departments. In 2010, the City enacted Ordinance 10-306, under which the City changed some of the key terms of the Plan. Plaintiffs commenced a class action lawsuit alleging claims for declaratory relief and breach of contract. The circuit court certified a class of plaintiffs and three sub-classes: a retired sub-class, a retirement-eligible sub-class, and an active sub-class. The circuit court granted judgment for all but the active sub-class, ruling that, as to currently employed members who had not yet reached retirement eligibility, Ordinance 10-306 did not affect vested benefits. The Court of Appeals affirmed, holding that the Ordinance retrospectively divested retired and retirement-eligible members of the benefits they had earned. View "Cherry v. Mayor & City Council of Baltimore" on Justia Law

In this two putative class action cases concerning the applicable statute of limitations for claims filed by consumer debtors against a consumer debt buyer, Midland Funding, LLC, the Court of Appeals held that Petitioners' claims for unjust enrichment and statutory claims for money damages were subject to the three-year statute of limitations established by Md. Code Cts. & Jud. Proc. 5-101.Petitioner Clifford Cain and Petitioner Tasha Gambrell each filed a putative class action complaint against Midland, alleging improper debt collection activities in connection with money judgments that Midland obtained against the plaintiffs during a time when Midland was not licensed as a collection agency under Maryland law. In Cain's case, the circuit court granted summary judgment to each party in part and a separate declaratory judgment declaring the rights of the parties. In Gambrell's case, the circuit court granted Midland's motion to dismiss. The court of appeals held (1) Petitioners were not entitled to injunctive relief, and (2) Petitioners' claims seeking restitution under an unjust enrichment theory and money damages for statutory claims were barred by CJ 5-101's three-year statute of limitations. The Court of Appeals affirmed the judgment as to Gambrell in its entirety and reversed the judgment in part as to Cain, holding that Cain's individual claims were timely filed. View "Cain v. Midland Funding, LLC" on Justia Law

The Court of Appeals vacated the judgment of the court of special appeals and remanded with directions to reverse the judgment of the circuit court certifying a settlement class and approving a settlement reached by the parties with respect to that class, holding that the circuit court erred in approving the proposed settlement.The class-action lawsuit was filed on behalf of 100 individuals who had assigned structured settlement annuity benefits they were entitled to receive from certain tortfeasors to Petitioner or its affiliates or designees based on allegations that the assignments were the product of fraud. Ultimately, the circuit court approved the proposed settlement. The court of special appeals reversed. The Court of Appeals vacated the judgment below and concluded that the circuit court erred in approving the proposed settlement under the facts and circumstances of this case. View "Linton v. Consumer Protection Division" on Justia Law

The circuit court’s order denying Appellant’s petition to compel arbitration was not a final, appealable judgment under Md. Code Ann. Cts. & Jud. Proc. 12-301.Appellees were individuals who each purchased vehicles from the automobile dealership operated by Appellant. Appellees filed a class action lawsuit against Appellant, challenging Appellant’s practice of providing customers with an alleged free lifetime limited warranty for their vehicles conditioned on the consumer’s continued use of and payment for other services provided by Appellant. Appellant filed an independent action seeking to compel arbitration in the class action case. The circuit court concluded that Appellees’ claims were not subject to binding arbitration. Appellant appealed. Appellees filed a motion to dismiss on the basis that the order denying arbitration was not an appealable final judgment. The court of special appeals denied the motion. The Court of Appeals vacated the judgment of the court of special appeals and remanded to that court with instructions to dismiss the appeal, holding that the circuit court’s order denying Appellant’s petition to compel arbitration was not a final, appealable judgment, depriving the court of special appeals of jurisdiction to hear an appeal of that order. View "Deer Automotive Group, LLC v. Brown" on Justia Law

The Fangmans sought to represent a class of approximately 4,000 to 5,000 individuals who, from 2009 to 2014, retained Genuine Title for settlement and title services and utilized various lenders for the purchase and/or refinancing of their residences, allegedly as a result of referrals from the lenders. All of the lenders are servicers of federally related mortgage loans. The complaint alleges an illegal kickback scheme and that “sham companies” that were created by Genuine Title to conceal the kickbacks, which were not disclosed on the HUD-1 form. After dismissing most of the federal claims, the federal court certified to the Maryland Court of Appeals the question of law: Does Md. Code , Real Prop. [(1974, 2015 Repl. Vol.) 14-127 imply a private right of action?” The statute prohibits certain consideration in real estate transactions. That court responded “no” and held that RP 14-127 does not contain an express or implied private right of action, as neither its plain language, legislative history, nor legislative purpose demonstrates any intent on the General Assembly’s part to create a private right of action. View "Fangman v. Genuine Title, LLC" on Justia Law

Respondents, three married couples, obtained home equity lines of credit from Petitioners, a bank and its loan officer. Approximately four years later, Petitioners filed a putative class action alleging that these transactions were part of an elaborate “buy-first-sell-later” mortgage fraud arrangement carried out by Petitioners and other defendants. Petitioners alleged numerous causes of action, including fraud, conspiracy, and violations of Maryland consumer protection statutes. The circuit court granted summary judgment for Petitioners, concluding that the statute of limitations barred several of Respondents’ claims and that no Petitioner violated the Maryland Secondary Mortgage Loan Law as a matter of law. The Court of Special Appeals reversed. The Court of Appeals reversed, holding that the Court of Special Appeals (1) erred in concluding that Respondents stated a claim upon which relief could be granted under the Maryland Secondary Mortgage Loan Law; and (2) erred in concluding that it was a question of fact to be decided by the jury as to whether Respondents’ claims against Petitioners were barred by the relevant statute of limitations. View "Windesheim v. Larocca" on Justia Law