Waterkeeper Alliance, Inc. v. Maryland Department of Agriculture
439 Md. 262
| Md. | 2014Background
- WKA sought certain nutrient management plans and related records from the MDA under the Maryland Public Information Act, and the MDA denied disclosure citing a statute exemption.
- WKA and eight environmental groups filed the WKA action; MFB and others filed a related action (MFB action I) against the MDA; the two actions were consolidated in the Anne Arundel Circuit Court with a lead case designated.
- The court granted cross-motions for summary judgment in 2009, issuing an order that partially denied MFB and granted disclosure with redactions; this 2009 Order did not address all claims in the consolidated actions.
- Subsequently, Coastkeeper sought similar records; MFB action II and related proceedings led to further filings and venue transfers; a 2011 Order clarified the 2009 Order and addressed additional redaction issues but did not resolve WKA’s constitutional claim.
- WKA appealed the 2011 Order; the Court of Special Appeals affirmed, and Maryland Court of Appeals granted certiorari to consider jurisdiction and finality.
- The Court dismissed the appeal for lack of jurisdiction, concluding that neither the 2009 Order nor the 2011 Order was a final judgment, and no applicable interlocutory appeal exception applied.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Was the 2009 Order a final judgment? | MFB contends the 2009 Order disposed of all claims in the consolidated case. | WKA/MDA argue the 2009 Order resolved only part of the consolidated claims, not all. | Not a final judgment; did not adjudicate all claims. |
| Can the 2011 Order be a final judgment for appeal purposes? | 2011 Order restated 2009 Order conclusions and could be final. | 2011 Order did not resolve WKA’s pending constitutional claim, so not final. | Not a final judgment; not appealable as such. |
| Are there exceptions permitting interlocutory review of the 2011 Order? | Rule 2-602(b)/8-602(e) allow certification when appropriate to avoid piecemeal appeals. | The case does not meet the stringent criteria for certification and the constitutional claim remains pending. | No applicable exception; appellate jurisdiction lacking. |
Key Cases Cited
- Rohrbeck v. Rohrbeck, 318 Md. 28 (1989) (final judgment must be a complete adjudication recorded on the docket)
- East v. Gilchrist, 293 Md. 453 (1982) (grouping related claims for final judgment purposes)
- Yarema v. Exxon Corp., 305 Md. 219 (1986) (consolidated actions treated as separate unless court intends joint judgment)
- Evander (Medical Mut. Liability Ins. Soc. of Maryland v. B. Dixon Evander and Assocs.), 331 Md. 301 (1993) (finality and piecemeal appeal policy guidance)
- Falls Road Cmty. Ass’n, Inc. v. Baltimore County, 437 Md. 115 (2014) (declaratory judgments vs. ancillary relief considerations)
- Shenasky v. Gunter, 339 Md. 636 (1995) (certification and interlocutory appeal standards guidance)