In Mayor of Baltimore City v. Prime Realty Assocs., L.L.C., the Court of Appeals of Maryland addressed the constitutional issue of notice and the opportunity to be heard.
Let me give you a quick summary and then we will dive deeper into it. The court addressed notice as it pertains to whether or not the method of substituted service upon the State Department of Assessments and Taxation (SDAT) prescribed by Maryland Rule 3-124(o) satisfies a litigant’s due process rights. The court held that Prime Realty’s failure to update its resident agent’s address with the SDAT didn’t invalidate the City’s attempts of service or the City’s use of substituted service upon the SDAT, as prescribed in Rule 3-124(o).
Accordingly, the court found that Maryland Rule 3- 124(o) provides due process of law, and the circuit court erred in invalidating the order ratifying the sale of Prime Realty’s vacant building.