Eastern Shore Title Co. v. Ochse

Eastern Shore Title Company v. Steven J. Ochse, et al., No. 16, September Term, 2016. Opinion by Getty, J. TORTS — NEGLIGENCE — DAMAGES — COLLATERAL LITIGATION DOCTRINE — Maryland follows the “American Rule,” which provides that the costs and expenses of litigation, other than the usual and ordinary court costs, are not recoverable in an action for damages. However, the American Rule is not an absolute bar and, in Maryland, the collateral litigation doctrine is an exception to the American Rule. The collateral litigation doctrine permits the recovery of attorney’s fees incurred by the…