GARRITY v. STATE BD. OF PLUMBING

No. 35, Sept. Term, 2015.

135 A.3d 452 (2016)

447 Md. 359

Wayne GARRITY, Sr. v. MARYLAND STATE BOARD OF PLUMBING.

Court of Appeals of Maryland.

April 26, 2016.


Attorney(s) appearing for the Case

Harvey K. Maizels, Baltimore, MD, on brief, for petitioner.

Jessica B. Kaufman, Asst. Atty. Gen. (Brian E. Frosh, Atty. Gen. of Maryland, Baltimore, MD), on brief, for respondent.

Argued before BARBERA, C.J., BATTAGLIA, GREENE, ADKINS, McDONALD, WATTS, GLENN T. HARRELL, JR. (Retired, Specially Assigned), JJ.


To date, Maryland has not adopted formally the doctrine of offensive non-mutual collateral estoppel. We are asked to decide in the present case whether the doctrine is permissible in this State and, further, whether it can be invoked to grant preclusive effect to an administrative order. We hold that offensive non-mutual collateral...

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