(1997)

Dear Mr. Coates:

On behalf of the Town of Berlin, you have requested our opinion on an issue concerning municipal annexation under Article 23A, § 19 of the Maryland Code. Under § 19(a)(1), a municipal corporation may enlarge its boundaries by annexing land "[w]hich is contiguous and adjoining to the existing corporate area."

Our opinion is as follows: Because Maryland courts have never interpreted the requirement that annexed land be "contiguous and adjoining," and because the case law in other states interpreting similar requirements is sharply divided, we cannot offer a definitive answer to…