One of the premier family law bloggers, Michael Sherman, wrote an excellent article several months ago discussing this very issue.  He analyzed the different styles that family law attorneys utilize in representing their clients, particularly what he classifies as “the lamb, the pit bull and the fox.” Michael absolutely nailed this issue, and I couldn’t agree more with his assessment of this issue.  His observations of these personas are listed below:

Lamb Lawyer

The lamb is the lawyer that just sort of goes with the flow.  They are reactive, not proactive.  They want to avoid confrontation at all costs and that means they also want to avoid going to court at all costs, even if it means convincing their clients to settle for significantly worse terms than they should.  The lamb may even be afraid to try the divorce case. He will rarely, if ever, tell his client that he should not sign a settlement offer that is being extended from the other side even if that offer is clearly inequitable.  Thankfully, there are not a lot of lambs that last very long as divorce lawyers.

Much more prevalent is the pit bull, who is exactly the opposite.  They hate to settle cases.  In fact, some of them won’t do anything proactive to try to settle their divorce cases.  It is almost as if they take some type of perverse joy in seeing the “blood running in the streets.”

Pit Bull Lawyer

The truth is that often they do this simply to develop and maintain a reputation as “Bad Leroy Brown…baddest man in the whole damn town.”  When a spouse is angry and in the emotional stage of wanting to exact revenge, they want to be the name on everyone’s lips when that aggrieved spouse asks their neighbor who is the meanest SOB in town.  And, so they work hard to maintain that reputation because it makes them a lot of money.

The sad part is that acting like a pit bull is rarely, if ever, in their own client’s best interests.  Of course, the pit bull’s main concern is not their client. If you know anything about pit bulls, you will know that they are very aggressive and vicious. But, they are not thinking animals.  They act only on instinct.  When they fight, they not only destroy the dog they are fighting, but by their own actions hurt themselves and anything else around them (which often includes their own client’s and their client’s children).  The pit bull is aggressive for the sake of being aggressive, not for any long-term benefit it brings their client.  Often people going through divorce will think they need an aggressive lawyer to represent them in their divorce.  They are wrong.  What they need is a lawyer who is assertive.  There is a difference.  It is the difference between the pit bull and the fox.

Wily Fox Lawyer

The fox is wise and cunning.  He sees the big picture.  The fox is assertive when he needs to be, compromising when it benefits his clients’ long-term best interests, and always aware of the many different consequences his actions have on his clients.  He stands on principle. Yet, he is a strong advocate for his client when it promotes his client’s long-term best interests.  He recognizes that reaching a fair settlement is always preferable to trying the case and leaving it up to the judge.  Yet, he also knows that if a fair settlement is not forthcoming, then he must be willing and able to prepare to effectively litigate the case in court.

When choosing a divorce lawyer, you should avoid the lamb and the pit bull at all costs!  Instead, find yourself a fox.

Source:  ”The Style of Your Divoce Lawyer: The Lamb, the Pit Bull, and the Fox“ by Michael Sherman, published at his Alabama Family Law Blog and J. Benjamin Stevens

Related posts:

1. I am No Longer a Family Law Lawyer – I am a Divorce Lawyer, A Custody Lawyer, An Adoption Lawyer, etc., etc., etc.
2. A Plea to Parents from a Divorce Lawyer: Leave Your Kids Out of It!
3. Divorce in Maryland – Generally

This online application program will assist you in completing a Child Support Worksheet. This worksheet estimates the child support obligation that a court may order a parent to pay toward support of the child(ren) on a monthly basis. Under Maryland law, there is a rebuttable presumption that the amount of child support, which would result from the use of these guidelines, is the correct amount of support to be awarded; however, a court may choose to deviate from the guidelines under certain circumstances.

Related posts:

1. It’s All About The Children’s Best Interest – Not The Parents
2. Divorce in Maryland – Generally
3. Paternity in Maryland: Who’s Your Momma?

Evil Eye

It is terrifying for a victim of domestic violence to step outside the vicious cycle their life has become and file the legal documents necessary for a temporary protective order in a court of law.  But studies have shown – and common sense dictates – that the prospect for the victim to present their case while the abuser is virtually standing next to them is unthinkable.  Surely it has given many pause in coming forward.  Bravo to the Montgomery County Family Justice Center and Foundation…may they lead the way across the country with this very significant step.

(ROCKVILLE, Md. — Sept. 28, 2009) Victims of domestic violence who come to the Montgomery County Family Justice Center (here is a great article about the Center) now have safer, easier access to justice. Thanks to a pilot program launched by the Maryland Judiciary, they can now file requests for temporary protective orders directly from the Family Justice Center and have their requests heard by judges at the Montgomery County Circuit or District Court by way of a live video link.

Video conferencing will be provided for temporary protective orders in Montgomery County courts that are ex parte — without notice to or the presence of the other party.

“The Judiciary is offering video conferencing as a way to help protect victims of domestic violence and improve access to and safety in our courthouses for all Marylanders,” said Chief Judge Ben C. Clyburn of the District Court of Maryland. “Victims no longer will have to leave the safety and security of the Family Justice Center to file petitions for protection. This will benefit victims, families and the general public we serve.”

The Montgomery County Family Justice Center opened this past spring in Rockville. Staff from the Montgomery County Sheriff’s Office, Office of State’s Attorney, Department of Health and Human Services, Montgomery County Police, House of Ruth and other private non-profits work together to provide services for domestic violence victims at the center, including help filing temporary protective orders. Protective orders generally apply to people in domestic relationships, and are issued by judges when petitioners have proved one of the following has occurred: an act that caused serious bodily harm or has placed the petitioner in fear of imminent bodily harm; an assault; rape or sexual offense; false imprisonment; or criminal stalking.

Last year, Montgomery County courts granted more than 1,850 temporary protective orders; statewide, more than 18,400 temporary protective orders were granted in Maryland’s courts.

“In addition to easier access to our courts, video conferencing reduces the danger to the victim of encountering the offender at or near the courthouse,” Judge Clyburn said. “This plan also provides more flexibility in scheduling temporary protective order cases, which is a more effective use of court time.” While they are waiting for their video hearing, victims can also receive other critical services at the Family Justice Center.

Video conferencing, which is operating as a pilot program at the Montgomery County courts, was developed in consultation with court officials, District and Circuit Court judges, the Clerk of the Circuit Court, court staff, Montgomery County government, members of the bar, other interested parties, vendors, and providers of video conferencing systems. Private funding for the equipment for this program was provided through a grant from the Verizon Wireless Hopeline Foundation.

The Montgomery County Family Justice Center also has a special room where children can play under the watch of trained volunteers. “Court buildings are not an ideal place for children, and video conferencing has an added benefit of helping to ease the stress on children, as well as reducing the disruption that is often caused by children in the courthouse or courtroom,” said Pam Harris, court administrator for the Montgomery County Circuit Court.

Family Justice Centers are fast becoming an accepted trend as they provide services for domestic violence victims at one location, enhancing their personal safety by reducing the number of places a victim has to go to receive services and minimizing barriers to services victims may face. These barriers include lack of transportation, child care, cultural issues, and language.

“Statistics have shown that the most vulnerable time for domestic violence victims is immediately following the issuance of a temporary protective order,” said Chief Deputy Darren Popkin of the Montgomery County Sheriff’s Office. “Nationwide, jurisdictions that have opened Family Justice Centers have shown a dramatic reduction in domestic related homicides among the victims that have sought services at the centers. By co-locating services, critical safety services can be coordinated by partners at the center.”

About three-quarters of people coming to Family Justice Centers throughout the United States ask for help with filing for a temporary protective order. The Judiciary has acted to improve access to services by including attorneys and advocates for domestic violence victims in courthouses across the state.

# # # # #

(Editor’s Note: For more information, contact the Maryland Judiciary Office of Communications and Public Affairs, (410) 260-1488.

Related posts:

1. Domestic Violence: Legal Steps in Obtaining a Maryland Protective Order
2. Domestic Violence: What Can the Judge Order?
3. Domestic Violence: Facing Abuse

Our country is in moral decay.  Hand in hand with the prevalence of greed, strolls incivility.   La te da. The last few days are prime examples of the many despicable public displays – Serena Williams, Kanye West, and Congressman Wilson.  Unfortunately, in my own profession there is an alarming increase in bad behavior amongst attorneys.  Don’t laugh – it wasn’t always that way…  Many of us were taught that one did not have to be disagreeable to disagree.  But that is a conversation for another day.

However, when one connects the dots of just these two sad realities – greed and incivility – the picture becomes clear – the raging narcissists and insidious sociopaths are running the asylum.  We are in a fight for the very soul of civilization.

The strength of our republic lies in the middle class.  Who else is there….but just us? (Pun intended.)  It is past the time for action.

I digress.  More on that later.  Back to the main story.  In the articles below, note the identity of the eight companies Rep. Charles Schumer found in 1995 that refused to write health, life or disability policies for women who have been abused.  Perhaps a call to your insurance agent or the insurance commissioner of your state would at least serve to let them know we have not been lulled us into complacency; they have not dumbed us down and good and decent people do outnumber the raging lunatics attracting the media attention.  Here are the 2007 insurance company executive salaries, should you need any incentive:

ANNUAL COMPENSATION 2007:

* Ronald A. Williams, Chair/ CEO, Aetna Inc., $23,045,834
* H. Edward Hanway, Chair/ CEO, Cigna Corp, $30.16 million
* David B. Snow, Jr, Chair/ CEO, Medco Health, $21.76 million
* Michael B. MCallister, CEO, Humana Inc, $20.06 million
* Stephen J. Hemsley, CEO, UnitedHealth Group, $13,164,529
* Angela F. Braly, President/ CEO, Wellpoint, $9,094,771
* Dale B. Wolf, CEO, Coventry Health Care, $20.86 million
* Jay M. Gellert, President/ CEO, Health Net, $16.65 million
* William C. Van Faasen, Chairman, Blue Cross Blue Shield of Mass., $3 million plus $16.4 million in retirement benefits
* Charlie Baker, President/ CEO, Harvard Pilgrim Health Care, $1.5 million
* James Roosevelt, Jr., CEO, Tufts Associated Health Plans, $1.3 million
* Cleve L. Killingsworth, President/CEO Blue Cross Blue Shield of Massachusetts, $3.6 million
* Raymond McCaskey, CEO, Health Care Service Corp (Blue Cross Blue Shield), $10.3 million
* Daniel P. McCartney, CEO, Healthcare Services Group, Inc, $1,061,513
* Daniel Loepp, CEO, Blue Cross Blue Shield of Michigan, $1,657,555
* Todd S. Farha, CEO, WellCare Health Plans, $5,270,825
* Michael F. Neidorff, CEO, Centene Corp, $8,750,751

With that, the Young Turks:

The Service Employees International Union “SEIU” initially reported on this story.  They have organized a call to action.  Please heed the call.

Words cannot describe the sheer inhumanity of this claim. It serves as yet further proof that our insurance system is broken, destroyed by the profit-mongering of the very companies whose sole purpose should be to provide Americans with access to care when they need it most. In 1994, an informal survey conducted by the Subcommittee on Crime and Criminal Justice of the United States Senate Judiciary Committee revealed that 8 of the 16 largest insurers in the country used domestic violence as a factor when deciding whether to extend coverage and how much to charge if coverage was extended.

It is clear that insurance companies refuse to police themselves. It’s up to us to call on Congress to take action now to pass health care reform and end discrimination against patients with pre-existing conditions.

Ryan Grim of the Huffington Post writes:

With the White House zeroing in on the insurance-industry practice of discriminating against clients based on pre-existing conditions, administration allies are calling attention to how broadly insurers interpret the term to maximize profits.

How many tears must we shed?

It turns out that in eight states, plus the District of Columbia, getting beaten up by your spouse is a pre-existing condition.

Under the cold logic of the insurance industry, it makes perfect sense: If you are in a marriage with someone who has beaten you in the past, you’re more likely to get beaten again than the average person and are therefore more expensive to insure.

In human terms, it’s a second punishment for a victim of domestic violence.

In 2006, Democrats tried to end the practice. An amendment introduced by Sen. Patty Murray (D-Wash.), now a member of leadership, split the Health Education Labor & Pensions Committee 10-10. The tie meant that the measure failed.

All ten no votes were Republicans, including Sen. Mike Enzi (R-Wyoming), a member of the “Gang of Six” on the Finance Committee who are hashing out a bipartisan bill. A spokesman for Enzi didn’t immediately return a call from Huffington Post.

At the time, Enzi defended his vote by saying that such regulations could increase the price of insurance and make it out of reach for more people. “If you have no insurance, it doesn’t matter what services are mandated by the state,” he said, according to a CQ Today item from March 15th, 2006.

Robert Zirkelbach, a spokesman for an insurance industry trade group, America’s Health Insurance Plans (AHIP), said that the National Association of Insurance Commissioners (NAIC) has proposed ending the discrimination. “The NAIC has a model on this that we strongly supported. That model bans the use of a person’s status as a victim of domestic violence in making a decision on coverage,” he said.

During the last health care reform push, in 1993 and 1994, the industry similarly promised to end discrimination against people with pre-existing conditions.

Murray pushed to include the domestic violence concern in this year’s comprehensive health care bill. “Senator Murray continues to believe that victims of domestic violence should not be punished for the crimes of their abusers. That is why she worked to include language in the Senate HELP Committee’s health insurance reform bill that would ban this discriminatory and harmful insurance company practice,” said spokesman Eli Zupnick.

In 1994, then-Rep. Charles Schumer (D-N.Y.), now a member of Senate leadership, had his staff survey 16 insurance companies. He found that eight would not write health, life or disability policies for women who have been abused. In 1995, the Boston Globe found that Nationwide, Allstate, State Farm, Aetna, Metropolitan Life, The Equitable Companies, First Colony Life, The Prudential and the Principal Financial Group had all either canceled or denied coverage to women who’d been beaten.

The Service Employees International Union asked members to write letters to Congress regarding the exclusion and have quickly generated hundreds, says an SEIU spokeswoman.

The relevant provision:

SEC. 2706. PROHIBITING DISCRIMINATION AGAINST INDIVIDUAL PARTICIPANTS AND BENEFICIARIES BASED ON HEALTH STATUS.

(a) IN GENERAL.–A group health plan and a health insurance issuer offering group or individual health insurance coverage may not establish rules for eligibility (including continued eligibility) of any individual to enroll under the terms of the plan or coverage based on any of the following health status-related factors in relation to the individual or a dependent of the individual:

(1) Health status.

(2) Medical condition (including both physical and mental illnesses)

(3) Claims experience.

(4) Receipt of health care.

(5) Medical history.

(6) Genetic information.

(7) Evidence of insurability (including conditions arising out of acts of domestic violence).

(8) Disability.

(9) Any other health status-related factor determined appropriate by the Secretary.

UPDATE: The eight states that still allow it are Idaho, Mississippi, North Carolina, North Dakota, Oklahoma, South Carolina, South Dakota and Wyoming, according to a report by the National Women’s Law Center.

When you gonna wake up, when you gonna wake up
When you gonna wake up and strengthen the things that remain?

Ryan Grim of the Huffington Post.

In 1979, Bob Dylan wrote this song and it is as true today as it was relevant then:

Bob Dylan

When You Gonna Wake Up?

God don’t make no promises that He don’t keep.
You got some big dreams, baby, but in order to dream you gotta still be asleep.

When you gonna wake up, when you gonna wake up
When you gonna wake up and strengthen the things that remain?

Counterfeit philosophies have polluted all of your thoughts.
Karl Marx has got ya by the throat, Henry Kissinger’s got you tied up in knots.

When you gonna wake up, when you gonna wake up
When you gonna wake up and strengthen the things that remain?

You got innocent men in jail, your insane asylums are filled,
You got unrighteous doctors dealing drugs that’ll never cure your ills.

When you gonna wake up, when you gonna wake up
When you gonna wake up and strengthen the things that remain?

You got men who can’t hold their peace and women who can’t control their tongues,
The rich seduce the poor and the old are seduced by the young.

When you gonna wake up, when you gonna wake up
When you gonna wake up and strengthen the things that remain?

Adulterers in churches and pornography in the schools,
You got gangsters in power and lawbreakers making rules.

When you gonna wake up, when you gonna wake up
When you gonna wake up and strengthen the things that remain?

Spiritual advisors and gurus to guide your every move,
Instant inner peace and every step you take has got to be approved.

When you gonna wake up, when you gonna wake up
When you gonna wake up and strengthen the things that remain?

Do you ever wonder just what God requires?
You think He’s just an errand boy to satisfy your wandering desires.

When you gonna wake up, when you gonna wake up
When you gonna wake up and strengthen the things that remain?

You can’t take it with you and you know that it’s too worthless to be sold,
They tell you, “Time is money” as if your life was worth its weight in gold.

When you gonna wake up, when you gonna wake up
When you gonna wake up and strengthen the things that remain?

There’s a Man up on a cross and He’s been crucified.
Do you have any idea why or for who He died?

Copyright © 1979 Special Rider Music

UPDATE from SEIU:

In eight states, it is legal for insurance companies to deny coverage to victims of domestic violence, classifying it as a “pre-existing condition.”

This week, the U.S. House Subcommittee on Domestic Policy is conducting hearings examining insurance company interference with patient-doctor decisions. We’re asking the Subcommittee Chairman Rep. Dennis Kucinich to question the insurance industry on whether they’ve denied claims based on domestic violence in the past, and to pledge to never discriminate against victims of domestic violence.

Tell Rep. Kucinich: Demand Answers from the Insurance Industry on Claiming Domestic Violence as a “Pre-Existing Condition”

No one should be denied health care coverage, least of all, people who have already endured so much.

Urge Rep. Kucinich to publicly question insurance companies on this practice during his hearings on Sept. 16th & 17th. Go here to participate.

Related posts:

1. Domestic Violence Billboards: Idea! – Maryland Insurance Companies Should Sponsor
2. Domestic Violence is Real
3. Temporary Protective Orders to be Heard via Video in Montgomery County

Grandparent Visitation Rights in Maryland

FAMILY LAW – GRANDPARENTAL VISITATION STATUTE – STATUTE INTERPRETED TO CONTAIN REBUTTABLE PRESUMPTION FAVORING PARENTAL DECISION AS IN CHILD’S BEST INTERESTS

FAMILY LAW – GRANDPARENTAL VISITATION STATUTE – STATUTE INTERPRETED TO REQUIRE THRESHOLD FINDING OF PARENTAL UNFITNESS OR EXCEPTIONAL CIRCUMSTANCES TO TRIGGER BEST INTERESTS INQUIRY

Facts: Glen and Andrea Koshko are the custodial parents of three minor children, Kaelyn, Haley, and Aiden. The couple met and began dating after then-Andrea Haining moved back into her parents’, John and Maureen Hainings’, home in Middletown, New Jersey. Andrea purportedly had left the Hainings’ residence initially to escape the acrimonious environment there, but returned from Florida after a former boyfriend abandoned her when she became pregnant. On 26 September 1994, Andrea gave birth to Kaelyn, who was raised in her grandparents’ home for the first three years of her life. During this time, the Hainings were very involved in Kaelyn’s upbringing. In September 1997, Andrea and Kaelyn moved out of the Hainings’ residence to live with Glen in nearby Point Pleasant, New Jersey. Despite the move, Maureen Haining maintained a close relationship with Kaelyn and visited her often. Eventually, Glen and Andrea became affianced and, contrary to the plans and wishes of the Hainings, eloped in 1998. In June 1999, the newlywed couple and Kaelyn moved to Baltimore County in connection with Glen’s employment. At the time of the move, Kaelyn was nearly five years old. The family has remained in Baltimore County. The couple’s two other children, Haley and Aiden, were born in Maryland on 21 August 1999 and 19 December 2002, respectively.

From the time the Koshkos moved to Maryland until October 2003, the Koshkos and Hainings maintained a regular visitation regimen. The families essentially took turns traveling to one another’s homes once every month. In between visits the grandparents and grandchildren maintained a relationship via correspondence. This visitation regimen abruptly ceased in October 2003 when the adults of the two families became embroiled in a bitter argument over Glen’s approach to his terminally-ill mother’s deteriorating condition. The Hainings perceived Glen to be nonchalant in this regard. Apparently disturbed by the Hainings’ criticism, Glen Koshko asserted that he would no longer permit the Hainings to visit their grandchildren. Despite the Hainings’ repeated attempts over several months to reconcile their dispute with the Koshkos and reestablish visitation, the Koshkos remained largely incommunicado. The Hainings retained an attorney in an effort to facilitate some discussion, which was answered by the Koshkos’ proposal to allow a single visit and the possibility of future visitation. The Hainings refused, declining to accept anything less than a commitment to regular visitation with the grandchildren.

On 19 April 2004 the Hainings filed in the Circuit Court for Baltimore County a grandparent visitation petition pursuant to the Maryland Grandparental Visitation Statute (GVS). The trial court entered an order granting the Hainings’ petition, finding that visitation was in the best interests of the grandchildren. In addition to establishing a rolling schedule of four-hour visits every 45 days and quarterly overnight visits, the trial court directed that the Koshkos and Hainings attend at least four joint, professional counseling sessions to discuss issues relating to the visitation. After an unsuccessful bid for a new trial, the Koshkos appealed the judgment of the Circuit Court.

The Court of Special Appeals affirmed the judgment, holding that the GVS was neither facially unconstitutional nor unconstitutional as applied to the Koshkos as claimed. Koshko v. Haining, 168 Md. App. 556, 897 A.2d 866 (2006). The intermediate appellate court rejected the argument that the GVS violated the Koshkos’ fundamental right to parent, as articulated in Troxel v. Granville, 530 U.S. 57 (2000) (plurality), simply because it failed to contain an express rebuttable presumption that parental decisions are in the best interests of children. Under the principle of constitutional avoidance, the court interpreted the GVS to contain such a presumption. The Court of Special Appeals then disagreed with the Koshkos’ position that there must be a threshold finding of either parental unfitness or exceptional circumstances as a predicate to the statutorily-imposed best interests of the child inquiry. Finally, the court affirmed the visitation award upon a finding that the grandparents had rebutted successfully the presumption in favor of the Koshkos’ decision to terminate visitation. The Koshkos petitioned the Court of Appeals, which granted the petition and issued a writ of certiorari to consider the Koshkos’ substantive due process challenge to the GVS.

Held: The GVS, codified at Maryland Code (1984, 2004 Repl. Vol.), Family Law Article § 9-102, permits a Maryland court to grant grandparents reasonable visitation with their grandchildren upon a finding that to do so was in the children’s best interests. The express terms of the statute, however, do not prescribe that courts apply a presumption in favor of parental decisions relating to third party visitation with their children. The U.S. Supreme Court held in Troxel that substantive due process principles require that court determinations of third party visitation cases under the best interest of the child standard must be informed by a parental presumption. Maryland law also contained a long-settled presumption that parental decisions are in a child’s best interests. Rather than invalidate the Maryland statute on its face, the Court of Appeals, under the principle of constitutional avoidance, interpreted the GVS to contain the presumption, as had the Court of Special Appeals.

The Court, however, concluded, under strict scrutiny analysis, that the GVS was unconstitutionally applied to the Koshkos because the statute lacked sufficiently narrow tailoring to the State’s interest in children’s welfare vis-a-vis the children’s beneficent exposure to grandparents. Strict scrutiny was triggered because the statute implicated the Koshkos’ fundamental right to parent. Specifically, the GVS imposed a “direct and substantial” interference with the Koshkos’ decision regarding visitation by interjecting the State and third parties, without a claim to a constitutional right to visitation, into the custodial parents’ decision-making process. This process is generally left to the discretion of fit parents, who are presumed to act in the best interests of their children. The Court found this direct interference also to be substantial in nature. Although visitation matters may prove to be less weighty an intrusion upon the parental presumption than custody and adoption matters in the non-constitutional realm, for purposes of substantive due process analysis, third party visitation disputes impede just as substantially upon the fundamental right to parent as do custody and adoption disputes. In order to remedy this lack of narrow tailoring in the statute, the Court again employed the principle of constitutional avoidance and applied the GVS with a judicial gloss. This gloss requires a threshold finding of parental unfitness or exceptional circumstances demonstrating the detriment that has or will be imposed on the children absent visitation by their grandparents before the best interests analysis may be engaged. This parental unfitness/exceptional circumstances test was an extension of a third party custody case, McDermott v. Dougherty, 385 Md. 320, 869 A.2d 751 (2005). The Court reasoned that custody and visitation matters generally have been decided under the same standards and that the fundamental right to parent is equally at risk from undue state interference in the context of both custody and visitation determinations. Accordingly, the parental unfitness/exceptional circumstances safeguard imposed in third party custody determinations appropriately should be applied in third party visitation matters as well. The Court thus overruled its precedent in Fairbanks v. McCarter, 330 Md. 39, 622 A.2d 121 (1993), and progeny, that held such threshold findings unnecessary in third party visitation cases. The Court remanded the case for application of the new threshold requirement.

Glen Koshko, et ux. v. John Haining, et ux., 398 Md. 404 (2007). Opinion by Harrell, J.

Related posts:

1. Divorce in Maryland – Generally
2. Paternity in Maryland: Who’s Your Momma?
3. Domestic Violence: Legal Steps in Obtaining a Maryland Protective Order