Knight v. Princess Builders, Inc., 393 Md. 31

Summary

The Maryland Court of Appeals held that Princess Builders, a contract purchaser of estate property, qualified as a party entitled to appeal an Orphans' Court order under Maryland Courts and Judicial Proceedings Article § 12-502. The court also held that the buyer's building-permit contingency was not drafted for Diana Knight's benefit, so she could not invoke it to invalidate the contracts between the estate and Princess Builders. The court affirmed the decision of the Court of Special Appeals.

Holdings

1. A contract purchaser whose interests are directly and adversely affected by an Orphans' Court decision is a party entitled to appeal under Maryland Code § 12-502, even if the purchaser was not a party of record in the Orphans' Court proceeding.
2. A nonparty to a contract may not use the nonperformance of a contingency that was not included for the nonparty's benefit to render the contract void, particularly where the nonparty was not prejudiced by enforcement.

Questions Presented

1. Whether Princess Builders, a contract purchaser whose contractual and equitable interests were adversely affected by an Orphans' Court order, qualified as a party entitled to appeal under Maryland Code § 12-502.
2. Whether Knight, who was not a party to the contracts between the estate and Princess Builders, could challenge their enforceability based on Princess Builders' failure to satisfy a building-permit contingency that was not included for Knight's benefit.

Disposition

affirmed