Maryland
How American Pipe & Construction Co. v. Utah applies in Maryland: state-specific rules, key cases, and bar exam notes for Other.
Maryland follows the tolling principles established in American Pipe & Construction Co. v. Utah for class action litigations. Under Maryland law, the filing of a class action tolls the statute of limitations for all members of the class until they can opt out of the class or until the class action is resolved.
In Maryland, the statute of limitations is tolled for all putative class members when a class action is filed, provided that those members are adequately represented.
The Maryland court held that a class action's filing tolled the statute of limitations for claims brought by absent class members.
In this case, the court reaffirmed that the tolling effect applies uniformly to all members of a certified class when a class action is pending.
The court ruled that only when class certification is denied does the tolling cease to apply, allowing claims to be pursued individually afterward.
Maryland's approach mirrors the federal standard established in American Pipe & Construction Co. v. Utah, particularly in allowing the tolling of claims for absent class members. However, Maryland may emphasize state procedural nuances in class certification that differ slightly from federal interpretations in certain contexts.
Understanding the tolling of the statute of limitations in class actions, as established in American Pipe & Construction Co. v. Utah, is pertinent for Maryland bar exam candidates, especially under the civil procedure section.