The Maryland Court of Special Appeals decision last week, in Choudhry v. Fowlkes 2019 WL 5677904 (Md. App., Nov. 1, 2019) is probably the most significant new development in Maryland personal injury law in 2019. Choudhry articulates a new 3-part rule for when plaintiffs in wrongful death cases can recover economic damages for loss of “household services.”
I love this case because it is a virtual treatise about how to put together a loss of household services case in Maryland. I don’t love the case because I think it raises the bar higher for making such a claim than most Maryland Circuit Court judges have been applying.