Hiob v. Progressive American Insurance

KRAUSER, C J.

The Court of Appeals held, in Houghton v. County Commissioners of Kent County, 305 Md. 407, 504 A.2d 1145 (1986), that the voluntary dismissal by the plaintiffs of the only remaining defendant in that case, amounted to a final judgment under Maryland Rule 2-601 and therefore triggered the thirty-day period for filing a notice of appeal. Eleven years after that decision, Rule 2-601(a) was amended. It now requires that “[e]ach judgment shall be set forth on a separate document.” This appeal presents the question of whether the holding of Houghton retains any precedential value,…