MAS Assoc. v. Korotki, 257 A.3d 553

Background

At a 2015 bench trial Korotki won a declaratory-judgment finding of a partnership and monetary damages; the trial court entered judgment for defendants on counts for unjust enrichment and Maryland Wage Payment & Collection Law (wage claim).
The Court of Special Appeals affirmed the partnership finding; this Court granted certiorari and in 2019 reversed the partnership finding for lack of competent evidence and remanded to adjust damages “consistent with this opinion.”
Korotki did not file a cross-appeal or cross-petition seeking review of the earlier unfavorable judgments on unjust enrichment and wage claims; those judgments remained entered in favor of MAS, Saralee, and others.
On remand the circuit court interpreted the mandate to permit reopening the unjust enrichment and wage counts, vacated the prior favorable judgments for defendants, and entered new monetary judgments for Korotki (against MAS and Saralee).
MAS and Saralee petitioned for review; the Court of Appeals held the circuit court exceeded the mandate and lacked authority to reopen or enter those judgments because the unjust enrichment and wage judgments were final/enrolled and Korotki never sought appellate review of them; the Court reversed and ordered reinstatement of the original judgments for defendants.

Issues

Issue	Plaintiff's Argument (Korotki)	Defendant's Argument (MAS/Saralee)	Held
1) Could the trial court on remand reopen unjust enrichment and wage claims that were adjudicated against Korotki and not appealed?	Mandate to "adjust the damage award" and this Court’s discussion of wages/loans implied those counts could be reopened to adjust Korotki’s recovery.	Final judgments on those counts were entered at trial and not appealed; absent an appeal/cross-appeal they could not be reopened.	Held for defendants: counts were final/enrolled; reopening without an appeal or Rule-based relief was impermissible.
2) Did the Court of Appeals’ mandate authorize broader "further proceedings" reopening other counts?	The mandate’s generic remand language and opinion findings authorized the circuit court to address any damages-related consequences.	The mandate must be read with the opinion and the scope was limited to adjusting the partnership-related damages; it did not purport to reopen unrelated, unappealed judgments.	Held for defendants: mandate did not authorize reopening; remand only contemplated adjustment of partnership damages.
3) Could the circuit court enter judgment against Saralee (a party who prevailed at trial and did not participate in the appeals)?	Saralee remained a named defendant in the case and could be subject to relief on remand.	Saralee had final favorable judgments, did not participate in appellate proceedings, and the court lacked authority to subject her to new liability on remand.	Held for defendants: circuit court lacked authority to enter new judgment against Saralee on remand.
4) Were the trial-court rulings on unjust enrichment and wage claims final/enrolled such that only limited revisory relief was available?	Korotki contended those were interlocutory and not final, so no cross-appeal was needed.	The trial entries, docket records, and post-trial practice show the rulings were final and enrolled; post-30-day revisory power exhausted absent fraud/mistake/irregularity.	Held for defendants: the rulings were final/enrolled judgments; they could not be modified on remand without proper appellate or Rule-based procedures.

Key Cases Cited

Taylor v. Wahby, 271 Md. 101 (1974) (an unappealed judgment cannot be reversed for the benefit of a non‑appellant)
Paolino v. McCormick & Co., 314 Md. 575 (1989) (party seeking to modify a judgment must appeal or cross‑appeal)
Popham v. State Farm Mut. Ins. Co., 333 Md. 136 (1993) (definition and effect of a final judgment)
LVNV Funding LLC v. Finch, 463 Md. 586 (2019) (enrolled judgments and narrow grounds for post‑enrollment revision)
Carpenter Realty Corp. v. Imbesi, 369 Md. 549 (2002) (if a mandate is ambiguous, interpret it in light of the opinion and circumstances)
Smith v. Lead Indus. Ass’n, Inc., 386 Md. 12 (2005) (attributes required for a ruling to be a final judgment)
Kunda v. Morse, 229 Md. App. 295 (2016) (absence of a timely cross‑appeal limits appellate review to issues raised by the appellant)