Housing Authority v. Woodland, 92 A.3d 379

This case tests the good cause exception to the LGTCA written-notice requirement (CJP § 5-304).
Woodland lived at the Residence with her mother and grandmother while HABC owned/managed it.
Elevated Woodland lead levels were detected in 1997; her mother/information was provided to HABC management.
Connor Environmental found chipped paint/stucco at the Residence and recommended relocation; Woodland family moved in November 1997.
Woodland filed suit in April 2009 asserting lead-paint injury and arguing substantial compliance and/or good cause for noncompliance.
Trial court denied summary judgment, found substantial compliance (later deemed moot) and held good cause for noncompliance; jury awarded $690,000.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Was summary judgment proper for lack of written notice?	Woodland contends there was substantial compliance or good cause.	Woodland failed to provide strict written notice within 180 days.	No reversible error in denying summary judgment.
Did the court err by deeming substantial compliance satisfied?	Substantial compliance was shown by events and notice-like actions.	There was no explicit/implicit notice of intent to sue, so not substantial.	Trial court erred in finding substantial compliance.
Did the trial court abuse its discretion in finding good cause for noncompliance?	Good cause existed due to actions/communications by HABC and reliance on those actions.	Good cause was not shown; reliance on HABC actions was not established; and evidence was improperly considered.	No abuse of discretion; however, the non-evidence-based packet consideration was harmless.
Were evidentiary rulings (post-notice conduct evidence and business-records documents) correct?	Post-notice conduct evidence and notices of lead paint were admissible to show reasonableness and notice.	Such evidence was irrelevant or confusing; the Lead Act issues were unsettled; business-records should exclude uncertain authorship.	No reversible error; evidentiary rulings were upheld.

Rios v. Montgomery County, 386 Md. 104 (2005) (good cause for waiver is within trial court discretion)
Heron v. Strader, 361 Md. 258 (2000) (good cause factors guiding waiver discretion)
Moore v. Norouzi, 371 Md. 154 (2002) (good cause to waive notice; substantial justice under varying circumstances)
Basiliko v. Metropolitan Mortgage Fund, Inc., 288 Md. 25 (1980) (abuse-of-discretion review for pretrial summary judgment denial)
Ellis v. Housing Authority of Baltimore City, 436 Md. 331 (2013) (substantial compliance framework for LGTCA notice)
Faulk v. Ewing, 371 Md. 284 (2002) (substantial compliance context and notice purposes)
Jackson v. Dackman Co., 422 Md. 357 (2011) (Lead Act immunity portions; severance of unconstitutional parts)
Moore v. Norouzi, 371 Md. 154 (2002) (good cause determination reserved to trial court)