Blankford v. McCormick

3 Balt. C. Rep. 540
CourtBaltimore City Court
DecidedApril 2, 1918
StatusPublished

This text of 3 Balt. C. Rep. 540 (Blankford v. McCormick) is published on Counsel Stack Legal Research, covering Baltimore City Court primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Blankford v. McCormick, 3 Balt. C. Rep. 540 (Md. Super. Ct. 1918).

Opinion

BOND, J.-—

Taking up, first, the objection made by the demurrer alone, that the counts in the declaration do not state good causes of action, apart from all question as to their certainty and particularity, I conclude that the first count does not state such a cause of action and that the other two counts do so. The first count rests upon the allegation that the elevator which was maintained and operated by the defendants was “dangerous, defective and of improper construction.” There is no allegation of negligence in having it so, and it might be so without negligence on the defendants’ part, and, therefore, without rendering them liable for resulting injuries.

The allegations in all the counts of the connection of both defendants with the supposed wrong is about as general as it could be made, and only in a limited class of cases would a landlord and a tenant, both, be responsible for loss to a third person’s property on the premisos. The allegation that both united in maintaining and operating the elevator, and that both contributed to bring about the accident seem to me, however, sufficient notice of the fact to be proved.

A question of practice is to be dealt with when we take up the objection that the declaration is not sufficiently specific in its allegations of wrongdoing, of defects and of negligent operation ; and that it leaves defendants without the information they should have on these points. One defendant makes the objection by a demurrer, the other by a demand for particulars. Are both steps proper, or is only one; and if only one, which one? There is uncertainty and doubt on this point in our Maryland practice; and a somewhat extended study of it may be justified. That a demurrer will lie in some cases of vagueness and obscurity in the allegations is settled by the decision in Jeter vs. Schwind Quarry Co., 97 Md. 690, and other eases. And it has long been a rule of pleading that there must be certainty and particularity to some degree in the allegations. Stephen on Pleading, pages 267, et seq.; 1 Poe on Pleading, Section 562. In opposition to the demand for particulars the supposed general rule that particulars may not be required in actions of tort is cited. Mr. Poe refers to the belief that there is such a rule, and refers to two decisions in the lower courts refusing particulars in such actions. Mr. Poe himself doubts the existence of the rule (2 Poe's Pleading [541]*541and Practice, 8ec. 117A). And since the time of the decisions to which lie refers, I am sure there have been several decisions in the courts of the city allowing particulars in such actions.

I have searched, but I have not been able to find, any authoritative source for the supposition that particulars may never be had in tort cases, and I believe it to be a mistake. The Maryland statute on the requirement of particulars makes no distinction between actions ex oonirwcUi and actions ex delicto. Art. 75, Sec. 24, 107, of the Code, after providing that either party in a suit may use the common-law forms or the forms just previously set out in the section, for all the various common-law actions in both tort and contract, says: “And either party may require a bill of particulars where the pleading is so general as not to give sufficient notice to the opposite party of the evidence to be offered in support of it.” So if particulars were ever held not to be permissible in tort actions generally, this statute would seem to have changed that rule. But in Evans’ Practice, p. 210 (1st Ed., 1839), it is said: “The principle to be extracted from these cases is, that whenever a declaration or a plea of set-off, or notice of set-off, does not give the other party sufficient information of the claim attempted to be enforced, to enable him to prepare his defense, lie is entitled to a bill of particulars.” And the cases in which it is allowable, as is noted there, includes suits in ejectment and a great variety of other suits. And if the common-law courts in Maryland should not have the power to require particulars in tort cases where particulars are needed, then they must in some way have, lost a serviceable power which came with the English common-law procedure and which was exercised wherever it could be useful in England and elsewhere in this country. It seems that bills of particulars were first made use of at common law to supplement the general allegations of courts in actions of debt and assumpsit: but as similar need arose, in any other sort of action the judges adopted this resource in their discretion (3 Ency. PI. & Pr.. 518). The bill of particulars when furnished was not a part of the pleadings, accurately speaking; it was not so circumscribed in scope and function. It could never be demurred to. (1 Tidd's Practice. 590; Blunt vs. Cooke, 4 Man & Granger, 458; Dempster vs. Purnell, 3 Man & Granger, 375, 388). So it was allowable later in the history of common-law practice in actions on the case for negligence (Stannard vs. Ullithorne, 5 Dowling P. C. 370). In trespass (Snelling vs. Chennells, 5 Dowling P. C. 80), in which Baron Parke said to the defendant: “Your affidavit ought to state that you do not know what the plaintiff is going for. Such an affidavit is necessary in order to obtain particulars in every action of trespass, trover, or on the ease.”

In an action for assault where defendant was one. of the Manchester Yeomanry and the alleged assault took place where many thousand people were assembled, particulars of the charge were required (Johnson vs. Birley, 5 Barn. & Aid., 540).

It was, as has been said, allowable in ejectment (Doe d. Birch vs. Phillips, 6 T. R. 597; Doe d. Saunders vs. Duke of Newcastle, 7 T. T. 332n; 2 Leigh, Nisi Prius, 917; Evans’ Practice, 210).

In American courts particulars have been required in suits for criminal conversation (Tilton vs. Beecher, 59 N. Y. 176; Gary vs. Eaton, 132 Mich. 105; Vansant vs. Lindsley, 2 App. D. C., 421). In actions on the case for negligence (Hanson vs. Anderson, 90 Wis. 195; McDonald vs. R. R. Co., 25 R. I. 0: Lawrence vs. Keim, 2 Phila. 351). In trover (Robinson vs. Comer, 13 Hun. 291). In trespass (Clarke vs. Ohio River R. R., 39 W. Va. 732; Richmond & Danville R. R. Co. vs. Payne, 86 Va. 481, 483). The requirement of a bill of particulars still maintains, indeed, its character as a step in the exercise of a broad, informal power of a court t o see that trials are conducted fairly: and that power appears to be limited only to the fairness and usefulness of its exercise, in a particular case. Chief Justice Shaw, of Massachusetts (15 Pick. 331), after a review of the decisions at common law, with especial reference to the allowance of particulars in action of tort, said: “The general rule to be extracted from these analogous cases is, that where, in the course of a suit, from any cause, a party is placed in a situation that justice cannot be done in the trial, without the aid of the information to be obtained by means of a specification or bill of particulars, the court, in virtue of the general authority to regulate the conduct of trials, has power to di[542]*542rect such information to be seasonably furnished, and in an authentic form; and that such an order may be effectual and accomplish the purpose intended by it, the party required to furnish a bill of particulars must be confined to the particulars specified.”

Free access — add to your briefcase to read the full text and ask questions with AI

Related

Chesapeake Iron Works v. Hochschield, Kohn & Co.
86 A. 345 (Court of Appeals of Maryland, 1913)
Swan v. Kemp
55 A. 441 (Court of Appeals of Maryland, 1903)
South Baltimore Car Works v. Schaefer
53 A. 665 (Court of Appeals of Maryland, 1902)
State Ex Rel. Jeter v. Schwind Quarry Co.
55 A. 366 (Court of Appeals of Maryland, 1903)
Tilton v. . Beecher
59 N.Y. 176 (New York Court of Appeals, 1874)
Clarke v. Ohio River R.
20 S.E. 696 (West Virginia Supreme Court, 1894)
Richmond & Danville R. R. v. Payne
6 L.R.A. 849 (Supreme Court of Virginia, 1890)
Black v. Woodrow
39 Md. 194 (Court of Appeals of Maryland, 1874)
Baltimore & Ohio Railroad v. Wilson
117 Md. 198 (Court of Appeals of Maryland, 1912)
Gary v. Eaton Circuit Judge
92 N.W. 774 (Michigan Supreme Court, 1902)
Hanson v. Anderson
62 N.W. 1055 (Wisconsin Supreme Court, 1895)

Cite This Page — Counsel Stack

Bluebook (online)
3 Balt. C. Rep. 540, Counsel Stack Legal Research, https://law.counselstack.com/opinion/blankford-v-mccormick-mdcityctbalt-1918.