Urquhart v. Simmons

CHASANOW, Judge.

We are called upon in this case to determine the scope of a trial court’s authority to transfer a case based on the doctrine of forum non conveniens as codified in Maryland Rule 2-327(c). For the reasons discussed below, we hold that a trial court may not sua sponte transfer a case on the grounds of forum non conveniens. Nevertheless, because the defendants in the instant case adequately raised that issue by filing their motion to dismiss or to transfer, we hold that the trial judge did not abuse his discretion in transferring this case to Montgomery County.

I

This appeal arises…