Legal Opinion

Bailey v. Happer

Court of Special Appeals of Maryland

Decided February 25, 2026No. 0685/24Published

1Opinion of the Court

William Bailey, Sr. v. Jamia Happer, No. 0685, September Term, 2024. Opinion by Getty, Joseph M., J. HEADNOTES: SAFE ACT – RETROACTIVE APPLICATION The SAFE Act may not be applied retroactively. However, a statute does not operate retroactively merely because it is applied in a case arising from conduct antedating the statute’s enactment. Therefore, a court is permitted to consider an alleged exploiter’s entire course of conduct, including conduct which occurred before the effective date of the statute, when evaluating a SAFE Act claim. SAFE ACT – BURDEN OF PROOF A claim of financial…

2Cases cited20 opinions

  1. Landgraf v. USI Film ProductsSupreme Court of the United States · 1994
  2. Cox v. HartSupreme Court of the United States · 1923
  3. Cunningham v. FeinbergCourt of Appeals of Maryland · 2015
  4. Walter v. GunterCourt of Appeals of Maryland · 2002
  5. Langston v. RiffeCourt of Appeals of Maryland · 2000

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