50 Md. App. 414 - Umans v. PWP Services, Inc.’s Empirical Analysis

Citation profile

5 federal appellate · 10 district · 4 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 22 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.

1. “In the instant case, all of the facts before the court showed that [the individual defendant’s] only contacts in Maryland were those as a corporate officer. Although the precise point has not been presented to the Maryland courts it appears that such acts do not subject one to personal jurisdiction. The rule seems to be all but universal. See Quinn v. Bowmar Publishing Co., 445 F.Supp. 780, 786 (D.Md.1978): “The Court need not reach the question of whether Campbell’s contacts with Maryland are sufficient in number under the statute, since Campbell was acting on corporate business during those meetings. Contacts as a corporate representative on corporate business do not give rise to personal jurisdiction over the individual. Wilshire Oil Co. of Texas v. Riffe, 409 F.2d 1277 (10th Cir.1969); accord, Lehigh Valley Industries, Inc. v. Birenbaum, 389 F.Supp. 798 (S.D.N.Y.1975), aff'd, 527 F.2d 87 (2d Cir.1975).” See also, Shaffer v. Heitner, 433 U.S. 186 , 97 S.Ct. 2569 , 53 L.Ed.2d 683 (1977); Escude Cruz v. Ortho Pharmaceutical Corp., 619 F.2d 902 (1st Cir.1980); Weller v. Cromwell Oil Company, 504 F.2d 927 (6th Cir.1974); Wilshire Oil Company of Texas v. Riffe, 409 F.2d 1277 (10th Cir.1969); Spelling-Goldberg Productions v. Bodek & Rhodes, 452 F.Supp. 452 (E.D.Pa.1978); Quinn v. Bowmar Publishing Company, supra; Idaho Potato Commission v. Washington Potato Commission, 410 F.Supp. 171 (D.Idaho 1976); Lehigh Valley Industries, Inc. v. Birenbaum, 389 F.Supp. 798 (S.D.N.Y.1975); Bu”

   1 later decision quote this exact passage · from the majority
   e.g. 137 Md. App. 367 - Christian Book Distributors, Inc. v. Great Christian Books, Inc.

2. “The court did not expressly address the applicability of the fiduciary [shield] doctrine in situations in which an individual defendant has committed a tort in Maryland. However, the suit at issue included claims for defamation and intentional interference with contractual arrangements. The court noted that plaintiffs claimed three bases for personal jurisdiction over the individual defendant, including Md. Ann.Code Cts. & Jud. Proc. § 6-103(b)(3), which provides for personal jurisdiction over any person who “causes tortious injury in the state by an act or omission in the state.” Referring to all three claimed bases of jurisdiction, the court held that there was no need to examine the extent of the defendant’s contacts with Maryland, since his only contacts were those as a corporate officer. If the court had believed that there was an exception to the general rule when the defendant has committed a tort, the court presumably would have so stated and then proceeded to examine the sufficiency of defendant’s contacts with Maryland under § 6-103(b)(3). In light of these developments, an individual’s acts in Maryland on behalf of his corporation 3 do not subject him to personal jurisdiction in Maryland, even when those acts are tortious.”

   1 later decision quote this exact passage · from the majority
   e.g. 137 Md. App. 367 - Christian Book Distributors, Inc. v. Great Christian Books, Inc.