Koste v. Town of Oxford, 431 Md. 14

Oxford introduced Resolution 1001 to annex 142 acres of submerged lands adjacent to the town.
A referendum petition was circulated after notice but before the public hearing on the resolution.
The petition contained signatures before and after the public hearing but before final enactment.
Board of Elections verified 177 valid signatures; 62 were obtained after final enactment and 115 before final enactment.
The deadline to petition was 45 days after final enactment; the petition was filed 42 days after final enactment.
Court decisions below split on whether pre-final-enactment signatures could count toward the 20% threshold.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether pre-enactment signatures may count toward the 20% threshold	Koste argues pre-enactment signatures are valid under §19(g).	Oxford argues only post-enactment petitioning within 45 days may count.	Pre-enactment signatures may not be counted.
Whether the 45-day period governs petition timing and circulation	The period begins after final enactment; circulation may occur earlier.	The period governs the entire petition process after enactment to referendum.	The 45-day period acts as a restriction on circulation; petitioning must occur within that window.

Koste v. Town of Oxford, 427 Md. 606 (Md. 2012) (central dispute over validity of pre-enactment signatures)
Town of Oxford v. Koste, 50 A.3d 606 (Md. 2012) (appeals through multiple courts; interpretation of §19(g))
Mayor and Town Council of Oakland v. Mayor and Town Council of Mountain Lake, 392 Md. 301 (Md. 2006) (referral timing after final enactment; referendum period purposes)
Whitley v. Maryland State Board of Elections, 429 Md. 132 (Md. 2012) (statutory interpretation favoring access to information in referenda)
Doe v. Montgomery County Bd. of Elections, 406 Md. 697 (Md. 2008) (statutory construction guiding reading within statutory scheme)