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Supreme Court of Maryland Holds that Inner Harbor Promenade Does Not Fall Within Purview of Maryland's Recreational Use Statute and the City Assumes Common Law Duties of Care to Individuals Using the Promenade

  Mayor and City Council of Baltimore v. Jamie Wallace , No. 12, September Term, 2024. Opinion by Gould, J.           On June 19, 2018, Jamie Wallace was riding her bike home from work through the promenade part of the Inner Harbor Park (the “Promenade”) when her bike became lodged between the bricks and granite bulkhead running along the water’s edge, causing her to fall and sustain injuries. Ms. Wallace brought suit against the Mayor and City Council of Baltimore (the “City”) for claims of negligence, stating that the City breached the duty owed to Ms. Wallace by negligently causing, allowing to remain, and/or failing to warn her of the condition in the Promenade of which the City had actual and/or constructive knowledge. On a motion for summary judgment, and twice at trial, the City argued that they were not liable as a matter of law, citing the “Maryland Recreational Use Statute,” which essentially relieves an owner of land from civil liability if ...

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