Sandler v. Executive Management Plus, 38 A.3d 478

lease entered Aug. 26, 2008 for a single-family home in Potomac; renewal dispute whether appellants properly exercised renewal clause; appellee claimed modification created counter-offer not accepted; Sept. 29, 2009 notice to vacate; Nov. 4, 2009 THO complaint filed in District Court; Dec. 9, 2009 written jury trial demand submitted; Dec. 16, 2009 cases transferred to circuit court for jury trials; May 12–13, 2010 trials culminated in directed verdicts for appellee; appeals consolidated and court held jury demands timely but harmless error.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether circuit court erred by striking the jury trial demand	Sandler argues demand timely; cases mixed equity and law	Executive Management asserts no jury right due to purely equitable relief	Harmless error; judgments affirmed despite error

Martin v. Howard County, 349 Md. 469 (1998) (landlord ejectment is an action at law entitling jury trial when amount in controversy suffices)
Carroll v. Housing Opportunities Commission, 306 Md. 515 (1986) (tenants may obtain jury trial if amount in controversy exceeds threshold; value of possession matters)
Purvis v. Forrest Street Apartments, 286 Md. 398 (1979) (value of possession considered with initial monetary demand to determine amount in controversy)
Nationwide Mut. Ins. Co. v. Regency Furniture, Inc., 183 Md.App. 710 (2009) (rent escrow remedies; breach of quiet enjoyment/warranty may support damages)
Pak v. Hoang, 378 Md. 315 (2003) (rent escrow statute supports remedies enhancing habitability protections)
Bringe v. Collins, 274 Md. 338 (1975) (landlord-tenant jury rights hinge on damages or value of possession exceeding threshold)
Higgins v. Barnes, 310 Md. 532 (1987) (federal analogy used to determine amount in controversy in jury demand)