Angela Glikin v. Major Energy Electric Services, LLC

CourtDistrict Court, D. Maryland
DecidedMarch 31, 2026
Docket1:21-cv-03251
StatusUnknown

This text of Angela Glikin v. Major Energy Electric Services, LLC (Angela Glikin v. Major Energy Electric Services, LLC) is published on Counsel Stack Legal Research, covering District Court, D. Maryland primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Angela Glikin v. Major Energy Electric Services, LLC, (D. Md. 2026).

Opinion

IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF MARYLAND

ANGELA GLIKIN, * * Plaintiff, * * Civ. No.: MJM-21-3251 v. * * MAJOR ENERGY ELECTRIC * SERVICES, LLC, * * Defendant. * * * * * * * * * * * *

MEMORANDUM OPINION Angela Glikin (“Plaintiff”) brings this putative class action against Major Energy Electric Services, LLC (“Major” or “Defendant”), alleging breach of contract and unjust enrichment. This matter is before the Court on Defendant’s Renewed Motion to Dismiss the Amended Complaint, or in the Alternative, Motion to Strike Plaintiff’s Amended Complaint. ECF 93. The motion is fully briefed, and the Court heard oral argument on October 7, 2025. For the reasons stated herein, Defendant’s motion is GRANTED IN PART and DENIED IN PART. I. FACTUAL BACKGROUND1 In 1999, Maryland enacted the Electric Customer Choice and Competition Act, which deregulated the utilities market and allowed customers to purchase their electricity from licensed independent energy service companies (“ESCOs”). Am. Compl. ¶ 41. Defendant is one such ESCO and acts as a “middleman” between the energy producer and the end-user customer, buying energy and reselling it to customers. Id. ¶¶ 1, 42. There is no difference in the electricity that ESCOs

1 The facts outlined herein are drawn from Plaintiff’s Amended Complaint. See ECF 73. provide compared with state-regulated utility companies; the only difference is price. Id. ¶ 6. Plaintiff alleges that a local utility company’s rates, like Baltimore Gas and Electric Company’s (“BGE”), “serves as an ideal indicator of market conditions” for the supply of electricity. Id. ¶¶ 85, 100.

In 2013, Plaintiff enrolled with Entrust Energy (“Entrust”), an ESCO, to receive electricity at a fixed rate of 9.5¢ per kWh (kilowatt-hour). Id. ¶ 82; ECF 73-1. Her agreement with Entrust provided that the plan would eventually go from a fixed rate to a month-to-month variable rate unless she responded to a notice sent 45 days before the change went into effect. Am. Compl. ¶ 83; ECF 73-1. The variable rate was calculated as follows: “The rate per kWh may be adjusted monthly to reflect market conditions, including market pricing of commodity, transportation, profit, and other market price factors.” Am. Compl. ¶ 84; ECF 73-1. Plaintiff alleges, on information and belief, that this provision was the same for all of Defendant’s customers. Am. Compl. ¶ 84. In May 2016, Plaintiff received a letter, informing her that Entrust had assigned her

electricity supply contract to National Gas and Electric (“NGE”).2 Id. ¶ 86; ECF 73-2. In March 2018, Plaintiff received another letter, informing her that NGE would soon assign her electricity supply contract to Defendant. Am. Compl. ¶ 87; ECF 73-3. The letter explained that Defendant would honor Plaintiff’s prior agreement with NGE and that the variable rate calculation would remain the same. Am. Compl. ¶¶ 88–90. In addition, the March 2018 letter stated, “The Major

2 In the May 2016 letter, NGE asserted in bold print that it would “honor [Plaintiff’s] current agreement with Entrust” and that there would be “no changes to the terms and conditions[.].” ECF 73-2. However, the next paragraph informs the consumer that if they are billed under Entrust’s variable rate, their “service would continue under [NGE’s] variable electricity rate.” Id. (emphasis added). Energy team’s experience in deregulated energy markets enables them to offer competitive prices . . . .” ECF 73-3. Plaintiff’s contract with NGE was assigned to Defendant in April 2018.3 Id. ¶ 91. Plaintiff alleges that Defendant, despite providing assurances that it would provide competitive prices, immediately began to “price gouge” her. Id. ¶¶ 89–91, 93. In January 2020,

Plaintiff realized her electric utility rates with Defendant were significantly higher than what BGE, her local utility, was charging, and she cancelled her service with Defendant. Id. ¶ 92. For the 21 months that Defendant supplied electricity to Plaintiff, its rates were on average 151% higher than BGE’s rates. Id. ¶¶ 97–98. Plaintiff argues that a reasonable customer would interpret the statement regarding competitive prices to refer to the market rate and that the rates Defendant charged could not possibly be described as competitive. Id. ¶¶ 94–96, 99. Not only were Defendant’s rates consistently higher than BGE’s, but they were also higher than those of other ESCOs. Id. ¶¶ 111–16. Of the 54 ESCOs that operated in Maryland in 2018, Defendant’s rates were the second highest. Id. ¶ 113. Defendant’s rates were higher than the average rates of its competitor ESCOs every year in Maryland from 2002 through 2019. Id. ¶ 112.

Defendant’s rates also rarely reflected the wholesale market price of electricity; even when the supply costs of electricity decreased, Defendant’s rates would frequently increase. Id. ¶¶ 118–21, 135. Plaintiff contends that Defendant’s conduct contradicted what a reasonable customer would have expected from an electricity supplier that promised competitive prices. ¶¶ 117, 122–23, 136. According to the Amended Complaint, Plaintiff and other customers were induced to buy their energy supply services by Defendant’s representation that its prices would be competitive and would reflect market conditions. Id. ¶ 131. Defendant knew it could charge exorbitant rates

3 The parties do not dispute that NGE used the same method as Entrust to calculate variable rates. They presume that NGE, like Entrust, was obligated to set rates that “reflect market conditions” and that Defendant was similarly bound by its assignment. See ECF 93-1 at 7–8; ECF 97 at 7, 15. because customers would not know such rates were out of line with Defendant’s competitors. Id. ¶¶ 132–34. According to Plaintiff, no interpretation of the phrase “market conditions” could explain or justify the rates that Defendant charged for supplying electricity. Id. ¶¶ 140–45. Thus, Plaintiff alleges, no reasonable customer with adequate knowledge of Defendant’s rates relative to

the market would have chosen to contract with Defendant. Id. ¶¶ 139, 142. Plaintiff sues on behalf of a putative class of Defendant’s customers for Defendant’s “standardized and uniform” conduct. Id. ¶¶ 146–47. The class consists of multi-state and state- specific subclasses. Id. ¶ 148. II. PROCEDURAL HISTORY On January 14, 2021, plaintiff Angela Glikin filed her initial Complaint against Major Energy Electric Services, LLC, in the United States District Court for the Southern District of New York, asserting claims for breach of contract and various unfair and deceptive practices in violation of state law. ECF 1. The case was transferred to this District on December 12, 2021. ECF 42. On October 17, 2023, Plaintiff filed an Amended Complaint, narrowing her claims to breach of

contract (Count I) and unjust enrichment (Count II). ECF 73. (Am. Compl.). Defendant moved to dismiss, arguing that Plaintiff failed to exhaust administrative remedies by not first presenting her claims to the Maryland Public Service Commission (“PSC”). ECF 78-1 at 10–11. Plaintiff opposed, contending that the PSC lacked primary jurisdiction because it cannot provide a comprehensive remedy for breach of contract and unjust enrichment claims. The Court agreed that the PSC had primary jurisdiction over claims asserted in the Amended Complaint and ordered a stay, thus giving Plaintiff an opportunity to present her claims to the PSC. ECF 86. Plaintiff filed a formal complaint with the PSC on November 6, 2024, asserting the same breach of contract and unjust enrichment claims. See ECF 93-1 at 10; ECF 92-2. On February 28, 2025, Major filed a motion to dismiss or, in the alternative, an answer to Glikin’s PSC complaint. See ECF 93-4. On May 19, 2025, the PSC dismissed Plaintiff’s claims for failure to state a claim.

ECF 93-3 (“PSC Decision”).

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Angela Glikin v. Major Energy Electric Services, LLC, Counsel Stack Legal Research, https://law.counselstack.com/opinion/angela-glikin-v-major-energy-electric-services-llc-mdd-2026.