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Wright v. Willow Lake Apartments (MD) Owner, LLC
8:22-cv-00484
D. Maryland
May 5, 2025
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Background

  • Plaintiff, Tamara L. Wright, was a tenant at Willow Lake Apartments (managed by Morgan Properties) in Laurel, Maryland, from 2016 to 2021.
  • Plaintiff alleged she was harassed by other tenants and experienced incidents she claims interfered with her quiet enjoyment of her apartment.
  • After informing management she would not renew her lease, Plaintiff left the apartment two days early without completing move-out cleaning due to a gunshot incident.
  • Plaintiff received a moveout statement with charges exceeding her security deposit and later was referred to a collections agency, which she claims affected her credit and job prospects.
  • Three claims proceeded to a bench trial: improper withholding of the security deposit under county code, breach of the covenant of quiet enjoyment, and tortious interference with prospective advantage.
  • The court found in favor of Defendants on all counts after evaluating both the evidence and legal standards applied.

Issues

Issue Plaintiff's Argument Defendant's Argument Held
Whether Defendants failed to follow county law in withholding the security deposit Wright did not receive timely notice or itemized damages statement. Statement was mailed to correct address within 45 days. For Defendants; no proof notice wasn't mailed as required.
Whether Defendants breached the covenant of quiet enjoyment Other tenants harassed Wright, management failed to intervene. No substantial interference; Wright did not give management time/opportunity to remedy. For Defendants; no evidence of substantial interference or timely notice to Defendants.
Whether Defendants tortiously interfered with Wright's job prospects by referring her debt to collections Debt was reported to collections before she was informed, causing her to lose jobs due to poor credit. Standard procedure; no malice, no evidence linking credit issue to job losses. For Defendants; no malice, no causal link proven.

Key Cases Cited

  • Bocchini v. Gorn Mgmt. Co., 515 A.2d 1179 (Md. App. 1986) (landlord’s liability for quiet enjoyment breaches depends on notice and opportunity to remedy)
  • Kaser v. Fin. Prof. Mktg., Inc., 831 A.2d 49 (Md. 2003) (elements of tortious interference with prospective advantage)
  • Legg v. Castruccio, 642 A.2d 906 (Md. App. 1994) (other tenants’ actions attributable to landlord only with notice and failure to act)
  • Nationwide Mut. Ins. Co. v. Regency Furniture, Inc., 963 A.2d 253 (Md. App. 2009) (substantial interference requirement for quiet enjoyment)
  • Schuman v. Greenbelt Homes, Inc., 69 A.3d 512 (Md. App. 2013) (quiet enjoyment and contractual obligations)
  • Alexander & Alexander Inc. v. B. Dixon Evander & Assocs., Inc., 650 A.2d 260 (Md. 1994) (defining independently wrongful acts for tortious interference claim)
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Case Details

Case Name: Wright v. Willow Lake Apartments (MD) Owner, LLC
Court Name: District Court, D. Maryland
Date Published: May 5, 2025
Docket Number: 8:22-cv-00484
Court Abbreviation: D. Maryland