Maryland
How Eastern Air Lines v. Gulf Oil Corp. applies in Maryland: state-specific rules, key cases, and bar exam notes for Other.
Maryland law recognizes the principles established in 'Eastern Air Lines v. Gulf Oil Corp.' regarding liability for economic loss, particularly in cases without an accompanying physical injury. Courts tend to examine the relationship between the parties and the presence of any contractual duties or tortious conduct that might modify the general rule against recovery for pure economic loss.
In Maryland, the economic loss doctrine generally prohibits recovery for purely economic losses unless there is a contractual relationship between the parties or a tortious act that inflicts physical harm.
The court held that economic losses were not recoverable in tort when the parties had a contractual relationship governing the transaction.
The court emphasized that damages for lost profits in a real estate transaction are typically categorized as economic losses not recoverable in tort.
The ruling reiterated that a duty of care must be established to claim damages for economic loss resulting from negligence.
Maryland's approach aligns with the federal standard that also limits recovery for economic loss without accompanying physical harm. However, Maryland courts may weigh the specific facts of the relationships between parties more heavily than federal courts, which can sometimes focus on broader policy implications.
Understanding the application of the economic loss doctrine in Maryland is crucial for the bar exam, particularly in tort and contract questions where economic damages arise.