Irwin Industrial Tool v. Pifer

Irwin Industrial Tool Company v. Christine Pifer, et al., No. 49, September Term, 2021 AUTHENTICATION THROUGH CIRCUMSTANTIAL EVIDENCE UNDER MARYLAND RULE 5-901(b)(4) – “REASONABLE JUROR” TEST – ALTERNATIVE GROUNDS FOR SUMMARY JUDGMENT – Court of Appeals held that items purchased on eBay that purportedly contained defendant’s product contaminated with asbestos were authenticated as exemplars of product, as there was sufficient circumstantial evidence for reasonable juror to find by preponderance of evidence that substance within containers was defendant’s product. Court of Appeals concluded…