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Barclay v. Castruccio
Court of Appeals of Maryland · 2020-06-30 · cited 16×
The case concerned whether Maryland recognizes a tort claim for intentional interference with an inheritance or gift. Darlene Barclay, the residuary beneficiary of Dr. Peter Castruccio’s estate, alleged that his widow Sadie had maliciously depleted the estate by filing groundless lawsuits and other actions after Peter’s death, forcing the estate to incur substantial attorney’s fees. The Court of Appeals held that Maryland does recognize the tort and adopts the elements set forth in Section 19 of the Restatement (Third) of Torts: Liability for Economic Harm. It further ruled that the tort requires the alleged interference to occur before the testator’s death, because the claim protects the relationship between the testator and a potential beneficiary. The court noted that existing probate remedies, including fee-shifting for bad-faith litigation, provide an alternative avenue for recovery in this situation.
torts & liability
Baltimore Cnty. v. Quinlan
Court of Appeals of Maryland · 2019-08-26
The case concerned whether Michael Quinlan, a paramedic/firefighter employed by Baltimore County for 24 years, could recover workers’ compensation benefits for degenerative meniscal tears in his right knee as an occupational disease under Labor and Employment § 9-502(d). The Court of Appeals held that the tears were compensable and that sufficient evidence supported a jury finding in Quinlan’s favor. The majority reasoned that the nature of paramedic/firefighter work exposed employees to knee-stressing activities—such as repetitive kneeling, squatting, and heavy lifting—at a greater rate than faced by the general public, that Quinlan performed those duties extensively, and that the record showed no concomitant preexisting condition that would disqualify the claim. The decision affirmed that an occupational disease need not be unique to the job if the employment hazards are distinctive in degree and the employee’s duties connect the condition to the work.
labor & employment
Baltimore Cnty. v. Quinlan
Court of Appeals of Maryland · 2019-08-26 · cited 7×
The case involved a workers’ compensation claim by Michael Quinlan, a paramedic and firefighter employed by Baltimore County for 24 years, seeking benefits for degenerative meniscal tears in his right knee, which he alleged qualified as an occupational disease under Maryland Labor and Employment Article § 9-502(d). The Court of Appeals held that the condition was compensable as an occupational disease and that sufficient evidence supported the jury’s award. The majority reasoned that the nature of Quinlan’s job exposed him to repetitive knee-stressing activities—such as heavy lifting, squatting, and climbing—that created a greater risk of degenerative knee conditions than faced by the general public, that he performed those activities over a long period, and that no preexisting condition was shown to account for the tears. The court therefore concluded that the statutory requirements were met as a matter of law.
labor & employment
MAS Associates v. Korotki
Court of Appeals of Maryland · 2019-08-08 · cited 9×
The case concerned whether three individuals running a mortgage lending business had formed a general partnership, even though they had attempted but failed to acquire membership interests in an existing LLC (MAS Associates). The trial court ruled that a partnership existed based on factors including payments made, shared management, and profit distributions. The Court of Appeals reversed, holding that the record lacked competent material evidence of intent to form a partnership. It found legal errors in treating certain payments as capital contributions rather than loans or wages, in applying a presumption of partnership from profit sharing, and in overlooking the parties’ concurrent and unfulfilled efforts to join the LLC along with one party’s resistance to joint liability. The case was remanded for adjustment of the damages award.
business & regulatory
MAS Associates v. Korotki
Court of Appeals of Maryland · 2019-08-08
The case involved whether three individuals working in mortgage lending, including Harry Korotki, had formed a general partnership through their business dealings and payments, even though they had attempted but failed to acquire membership interests in an existing LLC called MAS Associates. The trial court found that a partnership existed, but the Court of Appeals of Maryland reversed that determination. The court held that Korotki failed to meet his burden of producing competent material evidence showing the parties’ intent to create a partnership, as their conduct—including treating payments as wages or loans rather than profit shares or capital contributions, their ongoing efforts to join the LLC instead, and Korotki’s resistance to personal liability—did not support such a conclusion under the Revised Uniform Partnership Act. The opinion emphasized that any presumption from profit sharing was rebutted by these facts and the parties’ express intent to form a different entity.
business & regulatory
State v. Thomas
Court of Appeals of Maryland · 2019-06-24 · cited 15×
The case involved whether a heroin distributor could be convicted of gross negligence involuntary manslaughter after selling four bags of heroin to a young buyer who later fatally overdosed. The Maryland Court of Appeals held that the evidence was sufficient to support such a conviction. It reasoned that, although the State must prove a grossly negligent mens rea beyond a reasonable doubt, the underlying distribution of heroin is inherently dangerous, and the specific facts here—including the buyer’s desperation and youth, the seller’s experience with the drug, and the lack of any safety measures—demonstrated a wanton and reckless disregard for human life. The court further concluded that the sale was both the actual and proximate cause of death because the buyer would not have overdosed but for the heroin supplied and because ingestion was reasonably foreseeable.
criminal law