eNotes: Liability – June 2022 – Maryland
June 02, 2022
SIGNIFICANT CASE SUMMARIES
MD CASE SUMMARY
Murphy v. Liberty Mut. Ins. Co.
Maryland Court of Appeals
No. 5, 2022 Md. LEXIS 166
Decided: April 27, 2022
The Administrative Order tolling Maryland’s statute of limitations due to the Covid-19 pandemic is valid and within the authority of Maryland’s judiciary.
On July 2, 2020, Liberty Mutual commenced a legal action against Murphy Enterprises in the United States District Court of Maryland, asserting claims of breach of contract. Murphy Enterprises moved to dismiss the action, arguing that the Federal Court lacked jurisdiction because the majority of the contract’s payments were made more than three years before the Complaint was filed, which is outside of Maryland’s statute of limitations period. On July 2, 2021, the Federal District Court transmitted a certified question of law to the Court of Appeals of Maryland to determine whether “the Chief Judge of the Court of Appeals of Maryland act[ed] within her authority under Maryland law when, in response to the Covid-19 pandemic, she issued Administrative Orders that tolled statutes of limitations related to civil cases?”
The Court of Appeals of Maryland held that the Administrative Orders tolling Maryland’s statute of limitations in civil cases are valid. First, the Court highlighted that there “was ample and explicit authority under Article IV of the State Constitution and the Maryland Rules for the Chief Judge to issue the administrative tolling order.” The Court then moved to whether the Administrative Orders violated Article 8 of the Maryland Declaration of Rights, which is focused upon the principal of separation of powers. The Court found that the Administrative Orders did not violate Article 8 because the “rules on which that [Administrative] order was based fell within the Court’s ‘practice and procedure’ and administrative functions under the Maryland Constitution. The order was not an expression of a Judicial policy preference for a period of limitations different from that set by the Legislature.” Last, the Court found that the Administrative Orders did not violate Article 9 of the Maryland Declaration of Rights which states “no power of suspending Laws or the execution of Laws, unless by, or derived from the Legislature, ought to be exercised, or allowed.” The Court found that the Administrative Order did not violate Article 9 because “the State Constitution specifically assigns to the Judiciary the power to make rules and regulations to govern the practice and procedure and judicial administration in the courts of the State.”
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