Wireless One v. Baltimore City, 198 A.3d 892

Wireless One leased market stall space in Baltimore’s Cross Street Market from the City from 2004 until vacating on February 8, 2017; by 2016 the occupancy was month-to-month.
In late 2016 the City contracted Caves Valley Partners/CSM Ventures to manage and redevelop the Market; CSM was authorized to terminate existing tenancies and solicit new tenants for the redeveloped market.
CSM informed tenants (including Wireless) some existing businesses would not fit redevelopment plans and suggested relocation options; Wireless was told it should pursue other options and left the Market, leaving fixtures behind.
Wireless sued the City (and Baltimore Public Markets Corporation) claiming it was a “displaced person” under Md. Code, Real Property §§ 12-201(e)(1) and entitled to relocation payments under § 12-205(a); it also asserted an unconstitutional taking for denial of relocation compensation.
The City moved to dismiss, arguing § 12-201(e)(2)(iii) excludes persons who lease from the displacing agency after the agency took title; the circuit court dismissed the complaint on that ground and denied Wireless’s motion to alter/amend.
On appeal the Court of Special Appeals affirmed: because the City had owned the Market since 1847, Wireless’s lease (2004) was after the City’s taking of title, so the statutory exemption applied and no relocation payment or compensatory-takings claim lay.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether Wireless is a “displaced person” under RP § 12-201(e)(1)	Wireless: statute covers displacement from government redevelopment and entitles it to relocation benefits	City: § 12-201(e)(2)(iii) excludes persons who lease from the displacing agency after the agency took title; City owned Market since 1847, so Wireless is exempt	Held: Wireless is not a "displaced person" under the statute; exemption applies
Whether denial of relocation payments amounted to an unconstitutional taking	Wireless: wrongful denial of statutory relocation benefits supports a takings claim	City: no statutory entitlement exists, so no compensable taking for denial of payments	Held: No valid takings claim because Wireless was not entitled to relocation payments

Alexander v. United States Department of Housing and Urban Development, 441 U.S. 39 (U.S. 1979) (discusses displacement attribution to government projects)
Pulliam v. Motor Vehicle Admin., 181 Md. App. 144 (Md. Ct. Spec. App. 2008) (standard of review for motion to dismiss; assume truth of well-pleaded facts)
Advance Telecom Process LLC v. DSFederal, Inc., 224 Md. App. 164 (Md. Ct. Spec. App. 2015) (when extraneous documents merely supplement complaint, consideration does not convert dismissal to summary judgment)
URS Corp. v. Fort Myer Constr. Corp., 452 Md. 48 (Md. 2017) (separate-document requirement for judgments may be waived in certain circumstances)
Byrum v. Horning, 360 Md. 23 (Md. 2000) (rationale for separate document rule for judgments)