62 Md. App. 231 - Reed v. Sweeney’s Empirical Analysis
1985
Citation profile
6 district · 22 state decisions
How this case has been cited
Cited by 28 later decisions — most recently May 2014 · most notably Broadwater v. State (1985), Quann v. Whitegate-Edgewater (1986)
6 district · 22 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 Chase Securities Corp. v. Donaldson · New York Central & Hudson River Railroad v. Kinney · New York Cent Co v. Kinney · Doughty v. Prettyman · Walko Corp. v. Burger Chef Systems, Inc.
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 28 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“[U]nder the present rules there is no requirement that process be renewed in order to toll the statute of limitations indefinitely. An action now commences merely upon the filing of a complaint (Rule 2-101) and the statute is automatically tolled thereby. If process is not served within 60 days, it is deemed to be dormant until renewed by the plaintiff. The statute of limitations is similarly dormant, having been tolled for all purposes upon the action’s commencement. Problems which might be caused by a lapse of time between filing and ultimate service are specifically handled by Rule 2-507; the statute of limitations no longer has significance in this area. These significant rule changes represent fundamental departures from the common law and former Rule 112, and seem more in keeping with the policies inherent in the statute of limitations as expressed in this opinion.”
1 later decision quote this exact passage“‘Statutes of limitation find their justification in necessity and convenience rather than in logic. They represent expedients, rather than principles. They are practical and pragmatic devices to spare the courts from litigation of stale claims, and the citizen from being put to his defense after memories have faded, witnesses have died or disappeared, and evidence has been lost....’ Consistent with this spirit of the Supreme Court, the Maryland cases make clear that a statute of limitations is designed to protect a potential defendant from ‘surprise’ actions which inhibit his ability to fashion a defense because of the litigation’s temporal distance from the disputed occurrence.”
1 later decision quote this exact passage“service of process raises jurisdictional issues and focuses on the power of a court to exert its authority over a particular party[. Therefore,] it cannot be waived or ignored simply because the defendant had actual notice of the action____ The statute of limitations, on the other hand, is a “practical and pragmatic device” which protects a defendant from stale and untimely suits by forcing a plaintiff to file by a known deadline. Where a suit has been timely filed and the defendant is aware of its existence and basic substance, use of the statute to defeat the claim would be improper, with no purpose being served.”
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.