Maryland

Circuit City Stores, Inc. v. Adams in Maryland Law

How Circuit City Stores, Inc. v. Adams applies in Maryland: state-specific rules, key cases, and bar exam notes for Arbitration (FAA).

State Approach

Maryland supports the enforceability of arbitration agreements but emphasizes the need for fairness and voluntary consent. State courts are attentive to issues of unconscionability in arbitration clauses, ensuring that such agreements are not only clear but also equitable.

State Rule
In Maryland, arbitration agreements are generally enforceable under the Federal Arbitration Act and Maryland state law, provided that they are entered into voluntarily and do not contain unconscionable terms.
Significant State Cases

Sullivan v. Finkelstein

The court held that procedural and substantive unconscionability must be evaluated before enforcing an arbitration clause.

Wesleyan Church v. Buehler

The court found an arbitration provision unenforceable due to unconscionable terms affecting the balance of power between the parties.

Cannon v. Confidential Settlement Program

The court reaffirmed that arbitration agreements must be fair and not detrimental to one party's rights in order to be enforceable.

Comparison to Federal Law

Maryland courts align closely with the federal standard set by the FAA, which promotes the enforcement of arbitration agreements. However, Maryland places a more pronounced focus on assessing fairness and consent, making it more vigilant against potentially unconscionable clauses than some federal courts.

Bar Exam Note

This case and its principles are significant for the Maryland bar exam, particularly regarding the enforceability of arbitration agreements and the assessment of unconscionability.

Practice Pointers
  • Always review arbitration agreements for clarity, fairness, and the presence of any unconscionable terms before advising clients.
  • Consider Maryland's specific standards for enforceability when drafting or contesting arbitration clauses.
  • Be prepared to analyze issues of procedural versus substantive unconscionability in the context of arbitration agreements.
  • Stay updated on evolving case law regarding arbitration in Maryland to ensure compliance with both state and federal standards.

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