Nodeen v. Sigurdsson’s Empirical Analysis

Citation profile

17 state decisions

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 17 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.

1. “(a) Civil actions.—Subject to the provisions of §§ 6-202[ 6 ] and 6-203[ 7 ] of this subtitle and unless otherwise provided by law, a civil action shall be brought in a county where the defendant resides, carries on a regular business, is employed, or habitually engages in a vocation. In addition, a corporation also may be sued where it maintains its principal offices in the State. (b) Multiple defendants.—If there is more than one defendant, and there is no single venue applicable to all defendants, under subsection (a), all may be sued in a county in which any one of them could be sued, or in the county where the cause of action arose.”

   2 later decisions quote this exact passage
   e.g. Burnside v. Wong · 203 Md. App. 452 - Dinapoli v. Kent Island, LLC

2. ““A party who moves to transfer an action to an alternate forum under Maryland Rule 2-327, has the burden of demonstrating that the transfer to that forum better serves the interests of justice. Odenton Development v. Lamy, 320 Md. 33, 40 , 575 A.2d 1235, 1238 (1990). When a trial court considers the motion, the court must employ a balancing test whereby it weighs the convenience of the parties and witnesses along with the interests of justice. Id. Although the court generally has wide discretion in deciding whether to grant the motion, it is an abuse of that discretion for the court to disturb a plaintiffs choice of venue when the balance does not weigh strongly in favor of the proponents of the transfer. See Leung, 354 Md. at 224 , 729 A.2d at 959-60 (‘Commentators on Rule 2-327(c) have recognized that “due consideration must ... be given to the plaintiffs selection of forum, and this selection will not be altered solely because it is more convenient for the party moving to be in another forum.” ’) (quoting P.V. Niemeyer & L.M. Schuett, Maryland Rules Commentary, 215-16 (2d ed.)); see also Cobrand v. Adventist, 149 Md.App. 431, 439 , 816 A.2d 117, 121 (2003) (‘To simply call it a balancing test ... is in some regards ... misleading because [our decisions] make it clear that “a motion to transfer should only be granted when the balance weighs strongly in favor of the moving party.” ’) (quoting Odenton, 320 Md. at 40 , 575 A.2d at 1238 ; Urquhart v. Simmons, 339 Md. 1 , 18 n. ”

   1 later decision quote this exact passage
   e.g. Scott v. Hawit

3. ““[W]e note that there can be more than one appropriate venue in which an action may be filed. When this is the case, a plaintiff is entitled to select the forum in which to bring his or her action. Leung v. Nunes, 354 Md. 217, 224-25 , 729 A.2d 956, 959-60 (1999); Wilde v. Swanson, 314 Md. 80, 93-94 , 548 A.2d 837, 843-44 (1988).””

   1 later decision quote this exact passage
   e.g. Scott v. Hawit