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December 1, 2025

Pennsylvania – eNotes: Liability – December 2025

SIGNIFICANT CASE SUMMARIES Pennsylvania Case Summaries Wunderly v. Saint Luke’s Hosp. of Bethlehem, Pa. Pennsylvania Supreme Court No. 119 MAP 2023 Decided: October 23, 2025 Section 114 of the Mental Health Procedures Act extends to physical injuries that are coincident to involuntary mental health commitments. Background Decedent Kenneth E. Wunderly

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Maryland – eNotes: Liability – December 2025

SIGNIFICANT CASE SUMMARY Maryland Case Summary Lyles v. Santander Consumer USA Inc. Maryland Supreme Court No. 2, Sept. Term, 2025 Decided: November 25, 2025 An arbitration agreement contained in a separate document was not part of the agreement between Plaintiff and Defendant. Background In October 2015, Plaintiff, Jabari Morese Lyles,

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Washington, DC – eNotes: Liability – December 2025

SIGNIFICANT CASE SUMMARY Washington, DC Case Summary Eckington House Mental Health Servs., LLC v. Office of Wage-Hour District of Columbia Court of Appeals No. 23-AA-0194 Decided: November 13, 2025 Contractual language identifying an individual as an “Independent Contractor” was not adequate to overcome the classification of that worker as an

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Virginia – eNotes: Liability – December 2025

SIGNIFICANT CASE SUMMARY Virginia Significant Case Summary Tessema v. Moulthrop Virginia Court of Appeals No. 0865-24-2 Decided: September 30, 2025 When curing a misnomer, Plaintiff must provide timely notice of the institution of the action to the proper defendant within the statute of limitations. Background In April of 2017, Plaintiff

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