7222 Ambassador Road v. Nat. Ctr. on Insts.

233 A.3d 124, 470 Md. 66
CourtCourt of Appeals of Maryland
DecidedJuly 27, 2020
Docket66/19
StatusPublished
Cited by4 cases

This text of 233 A.3d 124 (7222 Ambassador Road v. Nat. Ctr. on Insts.) is published on Counsel Stack Legal Research, covering Court of Appeals of Maryland primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
7222 Ambassador Road v. Nat. Ctr. on Insts., 233 A.3d 124, 470 Md. 66 (Md. 2020).

Opinion

7222 Ambassador Road, LLC v. National Center on Institutions and Alternatives, Inc. No. 66, September Term 2019

Limited Liability Companies – Forfeiture of Right to do Business – Appeals. A limited liability company (“LLC”) organized under the Maryland Limited Liability Company Act must file certain reports and make required tax payments and unemployment insurance contributions upon pain of losing the right to do business in Maryland. A Maryland LLC that failed to file a required report, thereby forfeiting the right to do business in Maryland, was precluded from continuing to prosecute an action in the Maryland courts against a non- profit entity that was a former tenant of an office building owned by the LLC. Accordingly, the LLC’s appeal of a decision adverse to the LLC in the Circuit Court was dismissed because the appeal was not permitted by law. Maryland Code, Corporations & Associations Article, §4A-901 et seq.; Maryland Rule 8- 602(b)(1). IN THE COURT OF APPEALS Circuit Court for Baltimore County OF MARYLAND Case No. 03-C-16-008404 Argument: May 12, 2020 No. 66

September Term, 2019

7222 AMBASSADOR ROAD, LLC

V.

NATIONAL CENTER ON INSTITUTIONS AND ALTERNATIVES, INC.

_____________________________________

Barbera, C.J., McDonald Watts Hotten Getty Booth, Biran,

JJ.

______________________________________

Opinion by McDonald, J. Biran, J., concurs.

Filed: July 27, 2020

Pursuant to Maryland Uniform Electronic Legal Materials Act (§§ 10-1601 et seq. of the State Government Article) this document is authentic.

Suzanne Johnson 2020-11-17 14:09-05:00

Suzanne C. Johnson, Clerk The issue initially raised in this appeal concerned a discovery sanction imposed in

a civil case. However, an unfortunate thing happened on the way to this forum. It turned

out that the party that initiated this appeal had been delinquent in maintaining its status as

a limited liability company (“LLC”) authorized to do business in Maryland. As a result,

the dispositive issue on this appeal concerns compliance with the law governing Maryland

LLCs.

Petitioner 7222 Ambassador Road, LLC (“Ambassador Road LLC”) initiated this

action against Respondent National Center for Institutions and Alternatives, Inc. (“NCIA”)

in the Circuit Court for Baltimore County. NCIA prevailed in the Circuit Court and in the

Court of Special Appeals. After the Court of Special Appeals issued its opinion, but before

Ambassador Road LLC filed its petition for certiorari with this Court, it forfeited its right

to do business in Maryland because it had failed to file the annual report required of every

Maryland LLC. It later failed to reverse that forfeiture by rectifying that delinquency

within a statutory 60-day grace period. Ambassador Road LLC took no action to comply

with the Maryland LLC law until after NCIA filed a motion to dismiss this appeal based

on the forfeiture of Ambassador Road LLC’s right to do business.

We hold that, in the particular circumstances of this case, this appeal must be

dismissed. I

Background

A. Limited Liability Companies

The Maryland Limited Liability Company Act (“LLC Act”) is codified at Maryland

Code, Corporations & Associations Article (“CA”), §4A-101 et seq. A limited liability

company, or LLC, is a form of business organization that has characteristics of both a

partnership and a corporation. While a corporation is owned by its shareholders and a

partnership is owned by its partners, an LLC is owned by its members. CA §4A-601 et

seq. Like shareholders of a corporation, but unlike partners in a general partnership, the

members of an LLC have the shield of limited liability. CA §4A-301. However, an LLC

may be treated like a partnership for tax purposes, thus avoiding the second level of taxation

that occurs in a corporation. See Internal Revenue Service, Taxation of Limited Liability

Companies, Publication 3402 (rev. March 2020). In addition, the inherent flexibility of an

LLC may make that form of organization more attractive to business planners than other

types of hybrid business organization that have characteristics of both corporations and

partnerships, such as limited partnerships or Subchapter S corporations. See R.M. Ercole,

et al., Maryland Limited Liability Company Forms and Practice Manual (1999 ed., 2019

Supp.) at 1-3; P. Molk, Protecting LLC Owners While Preserving LLC Flexibility, 51 U.C.

Davis L. Rev. 2129, 2132 (2018) (governance flexibility of LLCs “can be especially

attractive” compared to other forms of business organization).

To form an LLC in Maryland and reap the benefits of this form of business

organization, its organizers must execute articles of organization and file them with the

2 State Department of Assessment and Taxation (“SDAT”). CA §4A-202. Among other

general powers, an LLC may sue and be sued. CA §4A-203(2). The members of an LLC

may enter into an operating agreement that further elaborates the management, control, and

operation of the LLC. CA §4A-402.

The LLC Act limits the right of an LLC to do business in the State if the LLC fails

to make certain filings and payments required by law. CA §4A-911. In particular, each

year the Comptroller is to certify to SDAT a list of LLCs that have failed to pay by October

1 of that year a tax that is due; the Comptroller is to simultaneously notify each of those

LLCs that its right to do business in Maryland is in jeopardy. CA §4A-911(a). Similarly,

each year the Secretary of Labor is to certify to SDAT a list of LLCs that have not made a

required unemployment insurance contribution before October 1 of that year and

simultaneously warn each of those LLCs that its right to do business in Maryland is in

jeopardy. CA §4A-911(b). SDAT itself is to certify a list of LLCs that have failed to file

a required annual report with SDAT by October 1 each year.1 CA §4A-911(c).

After the lists of delinquent LLCs are certified, SDAT issues a proclamation that

each of those LLCs has forfeited the right to do business in Maryland and to use the LLC’s

name in Maryland. CA §4A-911(d). Within 10 days of that proclamation, SDAT is to

mail notice of the proclamation to each LLC that is the subject of the proclamation. CA

§4A-912. To regain the right to do business in Maryland, an LLC must make any required

1 Under Maryland Code, Tax-Property Article, §11-101(a), an LLC must file a personal property report with SDAT by April 15 each year.

3 filings, pay delinquent taxes and unemployment insurance contributions, and file articles

of reinstatement with SDAT. CA §4A-915 through §4A-917. If an LLC cures the

deficiencies in its filings and payments within 60 days of forfeiture, its right to do business

and to use its name in Maryland is retroactively restored as of the date of forfeiture. CA

§4A-912.2 The statute provides that it is a misdemeanor punishable by a fine for anyone

to knowingly transact business on behalf of an LLC while the LLC’s right to do business

in Maryland is forfeited. CA §4A-919.

Upon forfeiture of its right to do business, the LLC is not completely disabled. A

savings provision in the LLC Act recognizes the validity of certain actions of the LLC and

allows the LLC to defend itself in litigation. It provides:

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233 A.3d 124, 470 Md. 66, Counsel Stack Legal Research, https://law.counselstack.com/opinion/7222-ambassador-road-v-nat-ctr-on-insts-md-2020.