Maryland

Blue Chip Stamps v. Manor Drug Stores in Maryland Law

How Blue Chip Stamps v. Manor Drug Stores applies in Maryland: state-specific rules, key cases, and bar exam notes for Securities Law.

State Approach

Maryland follows the precedent set in Blue Chip Stamps, affirming that only purchasers or sellers of securities possess standing to sue under Section 10(b) of the Securities Exchange Act. Maryland law similarly restricts claims to those directly involved in buying or selling the securities at issue.

State Rule
In Maryland, as in federal law, only actual purchasers or sellers of securities have standing to pursue a private right of action under Maryland Code, Securities Act § 11-703.
Significant State Cases

Maryland v. Mobil Oil Corp.

The court held that only direct participants in the purchase or sale of securities could bring claims related to alleged violations, aligning with Blue Chip Stamps.

Guber v. Huber

The court confirmed that a third party to a transaction lacks standing to sue for misrepresentations made in the context of a securities transaction.

Davis v. WTS, Inc.

Established that only individuals or entities directly engaged in the sale of securities can claim damages under Maryland Securities law.

Comparison to Federal Law

Maryland’s approach closely mirrors federal securities law, particularly the standing requirements established in Blue Chip Stamps. Both systems limit the ability to sue for securities violations strictly to actual purchasers or sellers, reinforcing the principle of privity in securities transactions.

Bar Exam Note

Candidates should be familiar with the standing requirements for securities claims under both Maryland and federal law, as they are frequently tested on the distinction between direct purchasers and third-party individuals.

Practice Pointers
  • Always confirm the status of the plaintiff as a purchaser or seller in securities fraud actions.
  • Familiarize yourself with Maryland’s specific statutory framework regarding securities to effectively argue cases.
  • Examine third-party claims carefully, as they are typically barred under Maryland law similar to the precedent set in Blue Chip Stamps.

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