Eleanor T. Chung, Associate in the Health Care & Life Sciences practice, in the firm’s Washington, DC, office, co-authored the book, Pleading Causes of Action in Maryland, Seventh Edition, published by the Maryland State Bar Association.

Following is a summary:

An essential guide for all Maryland practitioners and judges—Pleading Causes of Action in Maryland, Seventh Edition, is THE starting point for drafting and analyzing pleadings in Maryland. Sandler, Archibald and Chung’s practical organization of each chapter and section with a sample pleading immediately followed by their authoritative commentary of the elements of the claim and the issues to be considered, make this an exceptionally easy-to-use practitioner’s and judge’s tool.  The authors’ analysis and advice help the reader develop an acute awareness of the strengths and weaknesses of a case, making this an invaluable reference manual. The treatise is quoted in judicial opinions and is considered the foremost authority on pleading in Maryland. 

Expansive scope: The scope of the Seventh Edition is even more comprehensive than prior editions. While retaining its concise individual treatment of causes of actions—including citations to over 2,600 cases, 380 sections of the Maryland Code Annotated, and 200 provisions of the Maryland Rules, all meticulously catalogued in the Table of Cases and Table of Authorities, and carefully referenced to the elements of each sample pleading—it also discusses recent developments in the law, including two new causes of action: breach of fiduciary duty and intentional interference with an inheritance or gift.  It adds and amends causes of action and model complaints based on statutory enactments and amendments and case law on various causes of action. The Seventh Edition also includes two new chapters: Complaints to Enforce Arbitration, and Interpleader.

Up-to-date: The Seventh Edition adds references to and/or discussion of nearly 200 pertinent court decisions issued since the Sixth Edition by the Court of Appeals of Maryland, the Court of Special Appeals of Maryland, and the U.S. District Court for the District of Maryland, and is current as of December 31, 2021. While including discussions from prior editions, it picks up where the Sixth Edition left off.  It examines and analyzes cases, statutes, treatises and other reference sources on Maryland law and pleading. The complaints in the book have been updated to reflect the great diversity of the Maryland bar.

Praise from the Maryland judiciary:

“Mr. Sandler, Mr. Archibald, and Ms. Chung . . . ensure that no lawyer practicing in a Maryland court is left searching in darkness when considering how to identify, understand, and plead a recognized cause of action.”  —Hon. Matthew J. Fader, Chief Judge, Court of Appeals of Maryland

“More than three decades after the first edition was published, Pleading Causes of Action in Maryland remains an indispensable resource.  Smart lawyers will consult this book before drafting any cause of action in Maryland.”  —Hon. Andrea M. Leahy, Court of Special Appeals of Maryland. 

“Understanding the elements of a cause of action, and expressing them clearly, are critical to a well-drafted complaint.  This book is an invaluable aid to practitioners who seek to achieve those ends.”  —Hon. W. Michael Pierson (Ret.), Prior Circuit Administrative Judge, Baltimore City Circuit Court.

Pleading Causes of Action in Maryland has been an indispensable resource for Maryland lawyers and judges for more than 30 years.  Through its Seventh Edition, it remains the standard reference for pleading the elements and proper form of all causes of action in Maryland courts.”  —Hon. Keith R. Truffer, Associate Judge, Baltimore County Circuit Court.

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