CRITZOS v. MARQUIS

No. 293, Sept. Term, 2022.

287 A.3d 1281 (2023)

256 Md. App. 684

John CRITZOS, II v. David MARQUIS, et al.

Appellate Court of Maryland.

January 3, 2023.


Attorney(s) appearing for the Case

Argued by: Peter G. Byrnes, Jr. (Byrnes Law Group, Millersville, MD), on the brief, for Appellant.

Argued by: Carolyn Marquis & David Marquis, Pro Se Litigates, for Appellee.

Panel: Kehoe, Berger, Arthur, JJ.


This case presents the issue of whether the COVID-19 pandemic and associated executive orders limiting business operations throughout the State of Maryland rendered performance under a commercial lease for a brewery/pub legally impossible or so frustrated the purpose of the contract as to excuse the tenant's performance. Commercial landlord...

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