Koste v. Town of Oxford

This case presents the novel question of whether a petition seeking to bring a municipal annexation resolution to referendum may be circulated and signed by members of the relevant electorate before final enactment of the targeted resolution. Depending on the answer to that question, there may lurk an additional related query: may the petition be circulated before the commencement of the public hearing on the resolution?

Our story begins with the legislative body of the Town of Oxford, Maryland (“Oxford”), introducing a resolution that proposes to annex a sizable number of acres of submerged…