Caruso Builder Belle Oak v. Sullivan

Summary

The Supreme Court of Maryland held that a seller’s noncompliant disclosure under RP § 14-117(a)(3)(i) creates a statutory cause of action when the contract is executed, while RP § 14-117(b)(2)(i)–(iii) provides remedies rather than separate causes of action. Because the purchaser had inquiry notice of the alleged disclosure deficiency and could pursue at least one statutory remedy on the contract date, the three-year limitations period began then and barred her 2019 claim. The court reversed the appellate judgment and remanded with instructions to affirm dismissal; no separate opinions were issued.