100 Md. App. 512 - Warner v. German’s Empirical Analysis
1994
Citation profile
6 district · 65 state decisions
How this case has been cited
Cited by 71 later decisions — most recently December 2017 · most notably Bagwell v. Peninsula Regional Medical Center (1995), Hartford Accident & Indemnity Co. v. Scarlett Harbor Associates Ltd. Partnership (1996)
6 district · 65 state decisions
Later decisions citing this case, by decade. The current decade is in progress, and our corpus holds fewer opinions from the most recent years, so the latest bars are undercounted — not a real decline.
Relationships
Relies on King v. Bankerd · Heat & Power Corp. v. Air Products & Chemicals, Inc. · State v. Frye · Cheney v. Bell National Life Insurance · MPC, Inc. v. Kenny
Most-quoted passages
The sentences later courts lift from this opinion, ranked by how many decisions quote each — the parts of the opinion doing the work. These counts are smaller than the citation total above because most of the 71 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“[F]or the purpose of the application of the rule of res judicata, the term “parties” includes all persons who have a direct interest in the subject matter of the suit, and have a right to control the proceedings, make defense, examine the witnesses, and appeal if an appeal lies .... So, where persons, although not formal parties of record, have a direct interest in the suit, and in the advancement of their interest take open and substantial control of its prosecution, or they are so far represented by another that their interests receive actual and efficient protection, any judgment recovered therein is conclusive upon them to the same extent as if they had been formal parties.”
4 later decisions quote this exact passage““[A] judgment between the same parties and their privies is a final bar to any other suit upon the same cause of action, and is conclusive, not only as to all matters that have been decided in the original suit, but as to all matters which with propriety would have been litigated in the first suit.””
2 later decisions quote this exact passage“[WJhen analyzing the lower court’s decision, we ordinarily are confined to the basis relied on by that court and may not otherwise explain its conclusion by introducing new legal theories. See Cheney v. Bell Nat’l Life Ins. Co. 315 Md. 761, 764 , 556 A.2d 1135 (1989) (“[Ojrdinarily we will not affirm the granting of summary judgment for a reason not relied upon by the trial judge.”); Geisz v. Greater Baltimore Medical Center, 313 Md. 301 , 314 n. 5, 545 A.2d 658 (1988) (“[TJhe appellate court 'will not ordinarily undertake to sustain the judgment by ruling on another ground, not ruled upon by the trial court, if the alternative ground is one as to which the trial court had a discretion to deny summary judgment”).”
1 later decision quote this exact passage
How this case has been treated — in progress
Whether each later court followed, distinguished, criticized, or overruled this decision. The treatment classification (task #35) runs highest-cited cases first and lights up here as it reaches this one.