Apenyo v. Apenyo

As Judge Lowe philosophized for this Court in Schwartz v. Schwartz, 26 Md.App. 427, 428, 338 A.2d 386 (1975), “Conflicts among courts of the States cannot be avoided when litigants are jurisdictional nomads.” A perennial problem with jurisdictional nomads is that they inevitably produce jurisdictional collisions. It is to avoid such collisions that we invoke what is at best loosely referred to as “comity.” In Hilton v. Guyot, 159 U.S. 113, 163-64, 16 S.Ct. 139, 40 L.Ed. 95 (1895), the Supreme Court discussed its essential meaning:

Although the phrase has been often criticized, no satisfactory…