Driven by Service. Defined by Results.

February 2, 2026

Pennsylvania – eNotes: Liability – February 2026

SIGNIFICANT CASE SUMMARIES Pennsylvania Case Summaries Mack v. Pa. State Police Pennsylvania Commonwealth Court No. 9 M.D. 2021 Decided November 25, 2025 Private right of action for H&L Act beneficiaries to recover funds paid to an employer after a wrongful assertion of subrogation lien recognized by Commonwealth Court. Background Martin

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Maryland – eNotes: Liability – February 2026

SIGNIFICANT CASE SUMMARY Maryland Case Summary Jabbi v. Adventist Healthcare, Inc. Maryland Appellate Court No. 2071, Sept. Term, 2023 Decided: March 5, 2025 Expert witness testimony in suits dealing with complex medical issues may rely on a combination of medical experience and scientific literature as the required factual basis under

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New Jersey – eNotes: Liability – February 2026

SIGNIFICANT CASE SUMMARY New Jersey Case Summary McDermott v. Guaranteed Rate, Inc. New Jersey Superior Court, Appellate Division Nos. A-0921-24, A-1568-24 Decided: December 26, 2025 Appellate Division concludes that the EFAA renders pre-dispute arbitration agreements unenforceable as to all claims in a multi-claim dispute involving sexual harassment. Background The Plaintiff,

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Washington DC – eNotes: Liability – February 2026

SIGNIFICANT CASE SUMMARY Washington DC Case Summary Zajac v. Finnegan, Henderson, Farabow, Garrett & Dunner, LLP D.C. Court of Appeals No. 2023-CAB-001468 Decided: November 13, 2025 Denying a motion to file an amended complaint on the basis that it contradicted Plaintiff’s original complaint constituted abuse of discretion. Background Pro se

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Virginia – eNotes: Liability – February 2026

SIGNIFICANT CASE SUMMARY Virginia Case Summary Brooks-Buck v. Wahlstrom Virginia Court of Appeals No. 250246 Decided: October 16, 2025 School board members may not be covered by legislative, sovereign, or statutory immunity for certain actions taken while performing their school board duties. Background Plaintiff, an educator and former school administrator,

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