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