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Federal – eNotes: General Liability – April 2026

SIGNIFICANT CASE SUMMARIES Federal Case Summaries Berk v. Choy United States Supreme Court No. 24-440, 607 U.S. ____ Decided: January 20, 2026 United States Supreme Court holds that state law Affidavit/Certificate of Merit requirements do not apply to federal court proceedings because they conflict with Rule 8 of the Federal

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Pennsylvania – eNotes: General Liability – April 2026

SIGNIFICANT CASE SUMMARIES Pennsylvania Case Summaries Commonwealth of Pennsylvania v. Fitzpatrick Pennsylvania Supreme Court 349 A.3d 835 Decided: January 21, 2026 Pennsylvania Supreme Court holds that, even when not required, expert testimony presented at trial must still comply with Pennsylvania’s admissibility standards. Background This action arose from the drowning death

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Maryland – eNotes: General Liability – April 2026

SIGNIFICANT CASE SUMMARY Maryland Case Summary OHI Asset HUD Delta, LLC v. REIT Solutions II, LLC Maryland Appellate Court No. 1720, Sept. Term, 2022 Decided: January 28, 2026 The Appellate Court of Maryland reaffirms the “sufficient contacts” test to determine specific personal jurisdiction under Maryland’s “long-arm” statute. Background In 2006,

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Washington, DC – eNotes: General Liability – April 2026

SIGNIFICANT CASE SUMMARY Washington, DC Case Summary Woodley v. Woodberry Vill. Apt. District of Columbia Court of Appeals No. 23-CV-0965 Decided: March 16, 2026 A tenant has no duty to mitigate damages for a landlord’s breach of the warranty of habitability, by vacating the rental unit, absent landlord’s compliance with

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Virginia – eNotes: General Liability – April 2026

SIGNIFICANT CASE SUMMARY Virginia Case Summary Davis v. Christy Virginia Court of Appeals No. 1124-24-4 Decided: March 10, 2026 When curing the spoilation of evidence, adverse inference jury instructions are only permissible upon a finding of reckless or intentional spoliation. Background Plaintiffs and Defendant were involved in an extended neighborhood

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Pennsylvania – eNotes: Workers’ Compensation – March 2026

SIGNIFICANT CASE SUMMARY Pennsylvania Case Summary Parrish v. Yeager Supply, Inc. 2026 LX 44730 Commonwealth Court of Pennsylvania Decided: Feb. 5, 2026 Commonwealth Court holds that the Security Fund, designed to cover claims of insolvent insurers, is not liable for attorney fees in utilization review disputes. Facts The Workers’ Compensation

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