Md. Code Ann., Cts. & Jud. Proc. § 6-103

Section 6-103(b)(1) permits jurisdiction for business activity culminating in purposeful activity in Maryland, without requiring physical presence; § 6-103(b)(3) requires the tortious act and injury to occur in Maryland, or, if only the injury occurs there, other significant Maryland contacts.

A Love of Food I, LLC v. Maoz Vegetarian USA, Inc. · filed 2012-06-29(b)(1), (b)(3)

Section 6-103(b)(1) authorizes jurisdiction when a person “[t]ransacts any business or performs any character of work or service in the state.” ... “Transacting business pursuant to subsection (b)(1) ‘requires actions that culminate in purposeful activity within the state.’” ... “Subsection (b)(1) does not require the defendant to have been present physically in Maryland.” ... These isolated mailings, however, do not rise to the level of transacting business in the state. ... Accordingly, Maoz cannot be said to have transacted any business in Maryland. ... Section 6-103(b)(3) applies to any person who “[c]auses tortious injury in the State by an act or omission in the State.” ... The Fourth Circuit has interpreted subsection (b)(3) as “requiring either (1) that both the act and the injury occur in Maryland, or (2) that if only the injury occurred in Maryland, the non-resident have some other significant contacts with Maryland.” ... Accordingly, personal jurisdiction may not be based on § 6-103(b)(3).

Section 6-103 permits Maryland courts to exercise personal jurisdiction over nonresident defendants to the full extent allowed by the Fourteenth Amendment’s Due Process Clause.

Gogel v. Maroulis · filed 2019-10-30

Maryland’s long-arm statute, Md. Code Ann., Cts. & Jud. Proc. § 6-103 (2018), authorizes the exercise of personal jurisdiction to the limits permitted by the Due Process Clause of the Fourteenth Amendment. ... Rather, it merely reflects that, “to the extent that a defendant’s activities are covered by the statutory language, the reach of the statute extends to the outermost boundaries of the due process clause.”

Section 6-103 authorizes Maryland courts to exercise personal jurisdiction over nonresident defendants to the limits of Fourteenth Amendment due process when their activities fall within the statute.

Big Birds, LLC v. Vanity Online · filed 2020-08-28

Maryland’s long-arm statute, Md. Code Ann., Cts. & Jud. Proc. § 6-103 (2018), authorizes the exercise of personal jurisdiction to the limits permitted by the Due Process Clause of the Fourteenth Amendment.

Section 6-103(b)(1) permits a court to exercise personal jurisdiction over a person who transacts business or performs any character of work or service in Maryland.

Hearn v. Edgy Bees Inc. · filed 2023-04-25(b)(1)

“Actions Mr. Kaplan took in his role as CEO of Edgy Bees are insufficient to establish personal jurisdiction, as the court looks to Mr. Kaplan’s contacts with Maryland in his individual capacity, not his corporate capacity. ... Plaintiff has not identified any actions Mr. Kaplan personally took in Maryland that form the basis for the claims against him. ... Therefore, Plaintiff has failed to make a prima facie showing that the Maryland long-arm statute authorizes the court to exercise personal jurisdiction over Mr. Kaplan.”

Maryland’s long-arm statute reaches the limits of due process only when the defendant’s activities fall within the statute, and specific jurisdiction requires the claim to arise from an act enumerated in the statute.

Hampton v. Wells Fargo Bank, N.A. · filed 2023-09-22(a), (b)

Maryland’s long-arm statute limits specific jurisdiction to cases where the cause of action “aris[es] from any act enumerated in the statute itself.” Md. Code Ann., Cts. & Jud. Proc. § 6-103(a). ... The first and fourth statutory bases for specific jurisdiction seem like the closest fits, but Hampton does not plead the elements of either. ... In the absence of any specific allegation that Scharf or Santomassimo had any contact with Maryland or engaged in any conduct in Maryland, the complaint does not establish specific jurisdiction over them.

Section 6-103(a) limits specific jurisdiction to causes of action arising from an act enumerated in the statute, while § 6-103(b)(1) and (b)(4) authorize jurisdiction over parties conducting business or causing tortious injury in Maryland subject to the statute’s stated conditions.

Alston v. Resurgent Capital Services, L.P. · filed 2023-12-27(a), (b)(1), (b)(4)

Alston’s proposed second amended complaint includes factual allegations sufficient to establish personal jurisdiction under Maryland’s long-arm statute. The statute limits specific jurisdiction to cases where the cause of action “aris[es] from any act enumerated in the statute itself.” Md. Code Ann., Cts. & Jud. Proc. § 6-103(a). As relevant here, the statute authorizes jurisdiction over a party who directly or by an agent “(1) [t]ransacts any business or performs any character of work or service in the State” or “(4) [c]auses tortious injury in the State . . . by an act or omission outside the State,” provided that the party “regularly does or solicits business, engages in any other persistent course of conduct in the State or derives substantial revenue from goods, food, services, or manufactured products used or consumed in the State.” Id. § 6-103(b). ... Those allegations satisfy the first and fourth prongs of the long-arm statute. ... As to the fourth: An injury caused by a violation of a statute counts as a “tortious injury.” ... Alston’s proposed second amended complaint also satisfies the second element of § 6-103(b)(4), because he alleges that RCS regularly collects and attempts to collect debts in Maryland. ECF 17-1, ¶¶ 4–7.

Section 6-103(b) reaches to the outer limits of due process, but courts must still separately analyze whether the defendant's conduct falls within the statute.

Alston v. Absolute Resolutions Investments, LLC · filed 2023-12-27(b)

Maryland’s long-arm statute, Md. Code Ann., Cts. & Jud. Proc. § 6-103(b), reaches as far as the Due Process Clause permits, see Carefirst, 334 F.3d at 396 (citing Mohamed v. Michael, 370 A.2d 551, 553 (Md. 1977)). Even so, the Maryland Supreme Court has clarified that it is not “permissible to simply dispense with analysis under the long-arm statute.” Mackey v. Compass Mktg., Inc., 892 A.2d 479, 493 n.6 (Md. 2006). The fact that the long-arm statute extends as far as due process permits does not mean that the inquiry has only one step.

Section 6-103(b)'s personal-jurisdiction reach is coextensive with the federal Due Process Clause, so the statutory and constitutional inquiries merge.

DeBellis v. Woodit · filed 2024-04-01(b)

While “the long-arm and constitutional due process requirements are distinct, they can be evaluated in tandem.” Jones, 639 F. Supp. 3d at 547-58; see also Beyond Sys., 878 A.2dat576 (noting the “statutory inquiry merges with [the] constitutional examination”); Stover v. O’Connell Assoes., Inc., 84 F.3d 132, 135-36 (4th Cir. 1996) (“Because the limits of Maryland’s statutory authorization for the exercise of personal jurisdiction are coterminous with the limits: of the Due Process Clause, the statutory inquiry necessarily merges with the.constitutional inquiry, and the two inquiries essentially become one.”); Toombs v. Lowe’s Home Ctrs., LLC, Civ. No. GLS-22-2244, 2023 WL 4593372, at *4 (D. Md. July 18, 2023). As such, the Court considers whether the exercise of personal jurisdiction over OBS comports with due process.

Section 6-103(a) limits specific jurisdiction to claims arising from an act listed in the statute; under § 6-103(b)(1), transacting business must be more than tangentially connected to the claim, § 6-103(b)(2) concerns contracts to supply goods or services in Maryland, and § 6-103(b)(4) requires extensive, continuous, and systematic contacts when the injury occurred outside Maryland.

Phillips v. British Airways PLC · filed 2024-08-05(a), (b)(1), (b)(2), and (b)(4)

Maryland’s long-arm statute limits specific jurisdiction to cases where the cause of action “aris[es] from any act enumerated in the statute itself.” Md. Code Ann., Cts. & Jud. Proc. § 6-103(a). ... Section 6-103(b)(1) “authorizes jurisdiction over a party who directly or by an agent . . . [t]ransacts any business or performs any character of work or service in the State.” ... “Maryland courts have construed the phrase ‘transacting business’ narrowly, requiring, for example, significant negotiations or intentional advertising and selling in the forum state.” ... Section 6-103(b)(2) of the long-arm statute secures specific jurisdiction over a party who “[c]ontracts to supply goods, food, services, or manufactured products in the State.” ... This section “has been interpreted to apply only to “contracts to supply goods and services in Maryland, irrespective of where the contract was negotiated.” ... This section “has been construed as a general jurisdiction statute.” ... When, as here, the plaintiff’s claims do not arise from tortious injury inside Maryland, “the defendant’s contacts to the forum must be extensive, continuous, and systematic.”

Section 6-103(b)(1) covers in-state business or services narrowly, while § 6-103(b)(2) covers contracts to supply goods or services in Maryland regardless of where negotiated, and the claim must arise from an enumerated act.

Choice Pain & Rehabilitation Center, LLC v. Optum, Inc. · filed 2025-03-28(b)(1)–(2)

Maryland’s long-arm statute limits specific jurisdiction to cases where the cause of action “aris[es] from any act enumerated in the statute itself.” Md. Code, Cts. & Jud. Proc. § 6-103(a). The statute authorizes jurisdiction over a party who, directly or by an agent, acts in one of six ways, two of which Choice Pain relies on: “(1) [t]ransact[ing] any business or perform[ing] any character of work or service in the State; (2) [c]ontract[ing] to supply goods, food, services, or manufactured products in the State.” Id. § 6-103(b)(1)–(2). ... Section 6-103(b)(1) authorizes “jurisdiction over a person, who directly or by an agent . . . [t]ransacts any business or performs any character of work or service in the State.” “Maryland courts have construed the phrase ‘transacting business’ narrowly, requiring, for example, significant negotiations or intentional advertising and selling in the forum state.” ... Section 6-103(b)(2) of the long-arm statute authorizes specific jurisdiction over a party who “[c]ontracts to supply goods, food, services, or manufactured products in the State.” This section has been interpreted to apply only to “contracts to supply goods and services in Maryland, irrespective of where the contract was negotiated.” ... Consequently, Choice Pain has not established personal jurisdiction over Optum, Inc., under Maryland’s long-arm statute.

Section 6-103(b) authorizes personal jurisdiction over a party who, directly or through an agent, engages in any of six specified acts, including transacting business or causing tortious injury in Maryland.

LaRue v. Chase · filed 2025-04-14(b)

The statute authorizes jurisdiction over a party who, directly or by an agent, acts in one of six ways: ... Cts. & Jud. Proc. § 6-103(b). LaRue’s conclusory assertion of personal jurisdiction in her amended complaint is insufficient to establish jurisdiction under Maryland’s long-arm statute.

Section 6-103(a) requires a plaintiff relying on Maryland’s long-arm statute to identify the specific statutory provision authorizing jurisdiction, and § 6-103(b)(3) can reach out-of-state trademark infringement when the resulting deception and confusion occurs in Maryland.

Gilead Sciences, Inc. v. Meritain Health, Inc. · filed 2025-04-19(a), (b)(3)

Maryland’s long-arm statute requires Plaintiffs to identify the section of the long-arm statute on which they rely. Id. § 6-103(a); see Ottenheimer Publishers, Inc. v. Playmore, Inc., 158 F. Supp. 2d 649, 652 (D. Md. 2001) (explaining that “[i]t is nonetheless necessary first to identify a specific Maryland statutory provision authorizing jurisdiction . . . .”). This requirement can be met through a complaint or in opposition to a Rule 12(b)(2) motion. Hausfeld v. Love Funding Corp., 16 F. Supp. 3d 591, 597 (D. Md. 2014). ... Importantly, with respect to § 6-103(b)(3), the “tortious wrong of trademark infringement takes place in either the place where the infringer commits acts of infringement or in the place where customers are likely to be deceived and confused.” Planet Techs., Inc. v. Planit Tech. Grp., LLC, 735 F. Supp. 2d 397, 404 (D. Md. 2010). Therefore, a court may assert personal jurisdiction in a Lanham Act case in the state where the deception and confusion took hold (here, in Maryland) notwithstanding that the alleged bad actor remained physically outside state lines while undertaking the infringement.

Section 6-103(a) requires at least one of the jurisdictional bases in subsection (b) to be satisfied; subsection (b)(1) requires purposeful activity in Maryland, subsection (b)(3) requires an act in Maryland, and the other listed bases require the specified Maryland contacts.

Mosisa v. Perry · filed 2025-06-02(a), (b)(1)-(6)

Perry does not fall within section 6—103(b)(1) because “[t]ransacting business pursuant to section (b)(1) of the long-arm statute requires actions [that] culminate in purposeful activity within the State.” ... Section 6—103(b)(3) likewise does not apply because it requires that Perry engaged in an act in Maryland. There are no allegations that Perry actually engaged in any activities within Maryland, relating to the claims or otherwise. Finally, sections 6—103(b)(2), (4), (5), and (6) do not apply because Perry has provided a sworn declaration stating that he has no contacts with the State of Maryland and that he does not own property or conduct business in the State of Maryland, and Mosisa has not alleged otherwise.

Section 6-103 permits personal jurisdiction only for claims arising from specified Maryland contacts, and the court held that general business contacts, communications sent into Maryland, and limited allegedly defamatory communications did not satisfy the applicable provisions.

Brown v. Washington University School of Law · filed 2025-08-01(a), (b)(1), (b)(3), and (b)(4)

The Court also finds that it lacks personal jurisdiction over Brown’s claims because the allegations are insufficient to bring Defendants under the ambit of the Maryland long-arm statute, Md. Code Ann., Cts. & Jud. Proc. § 6-103 (West 2020). ... As to section 6—103(b)(1), the only alleged conduct that arguably constitute the transacting of business or the performance of work within Maryland consists of WashU’s general activities relating to contracts with Maryland universities or federal government agencies. As discussed above, however, Brown’s claim do not arise from these contacts, see supra part II.B.2, so they cannot satisfy the requirements of the long-arm statute. ... Section 6—103(b)(3) likewise does not apply because it requires that Defendants engaged in an act in Maryland. The only contacts with Maryland related to Brown’s claims consist of communications, whether by mail or electronically, sent into Maryland. Such contacts do not qualify as “an act or omission in the State” for purposes of section 6—103(b)(3). ... To the extent that Brown asserts that her claims fall under section 6—103(b)(4), the primary out-of-state conduct that could arguably have caused tortious injury in Maryland is the alleged transmission of unspecified false or defamatory statements to the Maryland Bar. Case law, however, demonstrates that this allegedly defamatory communication is insufficient to meet the requirements of section 6—103(b)(4) under the present record. ... Accordingly, where Brown has not established the requirements for personal jurisdiction over Defendants under either the Due Process Clause of the Fourteenth Amendment or the Maryland long-arm statute, the Court finds that this case is subject to dismissal for a lack of personal jurisdiction over Defendants.

Section 6-103(b) authorizes specific personal jurisdiction based on listed Maryland contacts, including transacting business, contracting to supply goods or services, or causing specified tortious injury in or connected to Maryland.

Bowman · filed 2025-11-04(b)(1), (b)(3)

Maryland’s long-arm statute permits the exercise of specific personal jurisdiction when, among other things, the defendant transacts business in Maryland, contracts to supply goods, food, services, or manufactured products in Maryland, causes tortious injury in the State, or has an interest in real property in Maryland. Md. Code Ann., Cts. & Jud. Proc. § 6-103(b)(1)-(6). ... But, the Plaintiff does not allege that Health First caused any tortious injury in the State of Maryland by an act or omission in the State of Maryland or that Health First regularly does, or solicits business, engages in other persistent conduct in Maryland, or derives substantial revenue from goods, food, services, or manufactured products used or consumed in the State to satisfy the requirements of the Maryland’s long-arm statute.

Section 6-103(b) authorizes specific personal jurisdiction over a nonresident only when the defendant's conduct falls within one of the statute's enumerated categories.

Harvin · filed 2025-12-22(b)

Harvin does not allege that any defendant transacts business, works, or provides services in Maryland or that they have contracted to supply any goods or services in Maryland. Harvin also does not allege that any defendant caused him tortious injury in Marland by an act or omission committed in Maryland. Nor does he allege that any defendant “regularly does or solicits business, engages in any other persistent course of conduct in the State or derives substantial revenue from goods, food, services, or manufactured products used or consumed in the State,” which is a prerequisite for § 6-103(b)(4). Finally, Harvin does not allege that any defendant has or uses real property in Maryland or insures or acts as a surety for anyone or anything in Maryland. The long-arm statute does not authorize specific jurisdiction over any of the defendants.

Section 6-103(b)(4) reaches as far as the Constitution allows, so its statutory personal-jurisdiction inquiry merges with due-process analysis.

Birara v. Kelel · filed 2019-07-16(b)(4)

Because courts have interpreted the Maryland long-arm statute to reach as far as the Constitution allows, the statutory and due process components of the personal jurisdiction analysis merge.

Section 6-103(b)(1) permits jurisdiction for transacting business or performing work or services in Maryland, while § 6-103(b)(4) requires greater, continuing Maryland contacts when the tortious act occurs outside the State.

Contiem v. Gullion · filed 2024-09-30(b)(1), (b)(4)

Accordingly, the Court does not find that either Gullion or WRL has transacted any business or performed any work or service in Maryland sufficient to confer personal jurisdiction under § 6-103(b)(1). ... Accordingly, the Court does not find that Defendants’ contacts with Maryland are sufficient to confer specific jurisdiction over them in Maryland under § 6-103(b)(4).

Subsection (b)(3) permits jurisdiction over an out-of-state person only when the tortious injury occurs in Maryland and the injury-causing act or omission occurs in Maryland.

Stover v. O'Connell Associates · filed 1996-05-14(b)(3)

Section 6-103(b)(3) of Maryland's long-arm statute provides that a Maryland court may exercise jurisdiction over a person outside the state who "[c]auses tortious injury in the State by an act or omission in the State." (Emphasis added). While Stover may be able to establish that O'Connell caused injury in Maryland, he cannot sustain his claim that O'Connell's injury-causing acts occurred in the state.

Section 6-103(b)(3) requires both the tortious injury and the tortious act or omission to occur in Maryland; out-of-state online defamation merely accessible in Maryland does not satisfy it.

LaRue · filed 2025-12-22(b)(3)

These allegations are insufficient, on their own, to satisfy § 6-103(b)(3). Section 6-103(b)(3) requires “a tortious injury in Maryland” and “an act or omission in Maryland” that caused the injury. Hart v. Carver, No. JRR-23-3499, 2024 WL 4025837, at *4 (D. Md. Sept. 3, 2024) (quoting Craig v. Gen. Fin. Corp., 504 F. Supp. 1033, 1036 (D. Md. 1980)). Thus, “both the tortious injury and the tortious act must have occurred in Maryland.”

Section 6-103(b)(3) permits personal jurisdiction for tortious injury in Maryland only when both the injury and the act causing it occurred and originated in Maryland.

Hagerstown Recovery LLC d/b/a The Valley v. New Spirit Recovery LLC, et al. · filed 2026-03-18(b)(3)

To satisfy § 6-103(b)(3), “both the injury itself and the act giving rise to the injury must have occurred and originated within Maryland.” Pandit, 808 F. App’x at 186 (citing Zinz v. Evans & Mitchell Indus., 22 Md.App. 126, 130-31 (Md.Ct.Spec.App. 1974)).

Section 6-103(b)(1) authorizes personal jurisdiction over a party that transacts any business or performs any work or service in Maryland.

Aerovation, Inc. v. Airtec, Inc. · filed 2019-08-16(b)(1)

Aerovation has made a prima facie showing that Aery is subject to specific jurisdiction in Maryland. Section 6-103(b) of the Maryland long-arm statute grants jurisdiction over corporations which have “[t]ransact[ed] business” in the state, and Aery may fairly be viewed as having done so. ... By submitting multiple contract proposals to Airtec, a Maryland company, executing a multimillion dollar contract with Airtec, and visiting Maryland six different times as part of the execution of that contract, Aery has conducted business in the state of Maryland to. an equal or greater degree than the defendants in the cases outlined above and thus transacted business within the meaning of the Maryland long-arm statute.

Section 6-103(b)(1) permits personal jurisdiction over a defendant who transacts business or performs work or services in Maryland, even without physical presence, when the defendant's conduct culminates in purposeful activity in the State.

NABAS Group, INC. v. NanoClear, LLC · filed 2019-11-20(b)(1)

Pursuant to the long-arm statute, personal jurisdiction exists for any defendant “who directly or through an agent . . . [t]ransacts any business or performs any character of work or service in the State.” Md. Code Ann., Cts. & Jud. Proc. § 6-103(b)(1). Notably, the defendant need not be “physically present” within the state for there to be personal jurisdiction on this basis. ... Rather, when a defendant’s actions “culminate in purposeful activity” in Maryland, personal jurisdiction under the statute is conferred. ... Thus, by virtue of the Agreement, H20 plainly conducted business in Maryland. See Md. Code Ann., Cts. & Jud. Proc. § 6-103(b)(1).

Section 6-103(b)(1) permits personal jurisdiction over a defendant who transacts business or performs work or services in Maryland, even without physical presence, and a single purposeful contact may suffice.

Cherdak v. McKirdy · filed 2020-07-27(b)(1)

Cherdak asserts personal jurisdiction under the first of these categories, which applies when the defendant “[t]ransacts any business or performs any character of work or service in the State.” ... “Transacting business pursuant to section (b)(1) of the long-arm statute requires actions [that] culminate in purposeful activity within the State.” ... This subsection, however, “does not require the defendant to have been physically present in Maryland.” ... “[E]ven a single contact with the forum can satisfy the transaction of business standard in subsection (b)(1).” ... Similarly, Defendants repeatedly discussed the Works, over the phone and by email, with Cherdak, a Maryland resident, and entered into multiple contracts with him. On at least one occasion, McKirdy traveled to Maryland to meet with Cherdak and engaged in negotiations that led to one of the contracts, the Settlement Agreement, which McKirdy later executed and sent to Cherdak in Maryland. Under these circumstances, the Court finds that Defendants have transacted business within Maryland for purposes of section 6-103(b)(1).

Under § 6-103(b)(1), a single purposeful contact with Maryland can constitute transacting business, even without a profit motive and even when made during a personal trip.

Tusha v. Greenfield · filed 2021-04-19(b)(1)

The Court disagrees. “[E]ven a single contact with the forum can satisfy the transaction of business standard in subsection (b)(1).” ... Under Maryland law, “a defendant need not even engage in ‘commerce or transactions for profit’ to come within the scope of § 6-103(b)(1) as long as the party’s conduct represents purposeful activity in the forum State.” ... This Court declines to create such an exception. ... Accordingly, the Court will not dismiss this case on the basis that it lacks personal jurisdiction.

Subsection (b)(1) authorizes personal jurisdiction over a person who transacts business or performs work or services in Maryland; the court construed “transacting business” narrowly, typically requiring significant negotiations or intentional advertising.

Anne Arundel County, Maryland v. Express Scripts, Inc. · filed 2025-01-21(b)(1)

Under subsection (b)(1), the relevant inquiry is whether the defendant conducts business in Maryland. ... “The phrase ‘transacting business’ does not require commerce or transactions for profit; it is, however, construed narrowly and typically requires significant negotiations or intentional advertising.” ... Thus, the County fails to make a prima facie showing that personal jurisdiction is proper under § 6-103(b)(1).

Section 6-103(b)(1) permits Maryland courts to exercise specific personal jurisdiction over a person who, directly or through an agent, transacts business or performs work or services in Maryland, based on purposeful Maryland-directed activities related to the claim.

OHI Asset HUD Delta v. Reit Solutions II · filed 2026-01-28(b)(1)

We conclude that the circuit court did not err in determining that the appellees did not transact business in Maryland within the meaning of the long-arm statute. The appellees have no offices, do not solicit business, and have no registered agents in Maryland. Although CSE was based in Maryland when the sale and leaseback took place, there is no evidence that the appellees engaged in any activities in Maryland to solicit, initiate, or negotiate the sale and leaseback of the nursing facilities or the corresponding execution of the Promissory Notes. Additionally, there is no indication that the appellees signed these documents in Maryland or visited the State in connection with these agreements.

Section 6-103(a) requires a cause of action to arise from an act enumerated in the statute; under § 6-103(b)(1), the cause of action may arise from a Maryland business transaction even when the specific tortious act or contractual violation occurred outside Maryland, and the transactions here also satisfied § 6-103(b)(2).

Melton v. Select Portfolio Services, Inc. · filed 2019-12-12(a), (b)(1), (b)(2)

Sterling has identified no authority supporting its position that section 6-103(b)(1) requires that the specific, charged tortious act occur in Maryland. The statute requires only that the cause of action “arise” from a business transaction in Maryland, not that the specific, operative tortious action or contractual violation occur in Maryland.

Section 6-103(b) permits Maryland courts to exercise personal jurisdiction over a nonresident defendant for specified Maryland contacts, and because Maryland's long-arm statute reaches the limits of due process, the statutory and constitutional inquiries merge.

Artis v. T-Mobile USA, Inc. · filed 2020-02-27(b)

Maryland’s long-arm statute allows a district court to exercise personal jurisdiction over a nonresident defendant if it finds that the defendant inter alia: (1) transacts any business or performs any character of work or service in Maryland; (2) contracts to supply goods, food, services, or manufactured products in Maryland; (3) causes tortious injury in Maryland by an act or omission in Maryland; (4) causes tortious injury in Maryland or outside Maryland by an act or omission outside Maryland if it regularly does or solicits business, engages in any other persistent course of conduct in Maryland or derives substantial revenue from goods, food, services, or manufactured products used or consumed in Maryland. Md. Code Ann., Cts. & Jud. Proc. § 6-103(b). ... Because “Maryland courts have consistently held that the state's long-arm statute is coextensive with the limits of personal jurisdiction set by the due process clause of the Constitution,” the “statutory inquiry merges with [the] constitutional inquiry.”

Section 6-103(b) permits personal jurisdiction over a nonresident defendant only when the defendant's conduct falls within the statute's listed categories, and conclusory allegations that the defendant shipped goods to Maryland or acted through a conspirator are insufficient to establish jurisdiction.

Alkali Scientific, Inc. v. Wang · filed 2022-09-27(b)

Indeed, Alkali alleges only that, “[u]pon information and belief, some of the masks were shipped from that warehouse to WANG’s warehouse in Baltimore, Maryland.” ... This is insufficient to demonstrate personal jurisdiction. ... Accordingly, Alkali has failed to show that the Court has personal jurisdiction under Maryland’s long-arm statute or under the conspiracy theory and the Amended Complaint is subject to dismissal under Rule 12(b)(2).

Section 6-103(b)(4) permits personal jurisdiction over an out-of-state defendant whose out-of-state act or omission causes tortious injury in or outside Maryland when the defendant regularly conducts or solicits business, maintains a persistent course of conduct, or derives substantial revenue from services in Maryland.

Water Justice for Puerto Rico B.V. v. Moonshot Missions, Inc., et al. · filed 2026-01-22(b)(4)

In this case, the complaint fails to allege facts that show that Section 6-103(b)(4) of the Maryland long-arm statute applies to the Xylem Defendants, based upon a conspiracy claim theory, for two reasons. First, a careful reading of the complaint shows that the Plaintiff fails to allege facts to show that the Xylem Defendants conspired with the Moonshot Defendants to tortiously interfere with its business interest in connection with the RFP. ... Second, the complaint fails to allege specific facts to show that one of the alleged co-conspirators committed an overt action in Maryland in furtherance of the alleged conspiracy to interfere with the Plaintiff’s business relationship during RFP process. ... Because the allegations in the complaint, taken as true, are not sufficient to show that the Moonshot Defendants and the Xylem Defendants conspired to interfere with the Plaintiff’s business relationship with the P3 Authority in Maryland, the Court GRANTS-in-PART the Xylem Defendants’ motion to dismiss (ECF No. 30) and DISMISSES the claims brought against the Xylem Defendants in this case for lack of personal jurisdiction.

Section 6-103(b) authorizes personal jurisdiction over nonresident defendants to the outermost limits of Fourteenth Amendment due process when their activities fall within the statute.

Blackstone International, Ltd. v. Zhejiang Mikia Lighting Co., Ltd. · filed 2020-03-30(b)

Maryland’s long-arm statute, Md. Code Ann., Cts. & Jud. Proc. § 6-103 (2018), authorizes the exercise of personal jurisdiction to the limits permitted by the Due Process Clause of the Fourteenth Amendment. ... That broad reach does not suggest that analysis under the long-arm statute is irrelevant. Rather, it merely reflects that, “to the extent that a defendant’s activities are covered by the statutory language, the reach of the statute extends to the outermost boundaries of the due process clause.”

Section 6-103(b)(1) authorizes personal jurisdiction over a party that transacts business or performs work or services in Maryland, and Maryland courts treat the statute's reach as coextensive with constitutional due process.

Sant v. Marriott International, Inc. · filed 2023-02-24(b)(1)

Maryland’s long-arm statute provides that courts may exercise personal jurisdiction over a party who “[t]ransacts any business or performs any character of work or service in the State.” Md. Code Ann., Cts. & Jud. Proc. § 6-103(b)(1). ... Courts in Maryland have “consistently held that the state’s long-arm statute is coextensive with the limits of personal jurisdiction set by the due process clause of the Constitution,” and thus, the “statutory inquiry merges with [the] constitutional inquiry.”

When personal jurisdiction rests solely on Maryland’s long-arm statute, the claim must arise from an enumerated act the defendant performed in Maryland.

Rogers v. Senk · filed 2020-05-28(a)

However, under Maryland’s long-arm statute, the lynchpin of a plaintiff’s assertion of specific jurisdiction is that the plaintiff’s claims arise out of acts that the defendant performed in Maryland. See MJCP § 6-103(a) (“If jurisdiction over a person is based solely upon this section, he may be sued only on a cause of action arising from any act enumerated in this section.”). The only act Plaintiff alleges Fr. Senk performed in Maryland is the filing of a proceeding in Maryland state court, which is described more fully below. Because Plaintiff’s causes of action against Fr. Senk do not relate to the state court proceeding he filed, Maryland’s long-arm statute does not provide a basis for the exercise of personal jurisdiction.

Section 6-103(b)(1) permits personal jurisdiction over a person who transacts business or performs work or services in Maryland, including meetings and work performed there related to a contract formed elsewhere.

Knickerbocker v. AvePoint, Inc. · filed 2021-03-11(b)(1)

Although the initial contract for the services performed at the New Carrollton office may have occurred in Virginia, the court concludes that the meetings conducted and the work performed at the New Carrollton office, as detailed in plaintiff’s affidavits, fall within the long-arm statute’s definition of “transact[ing] any business or perform[ing] any character of work or service.” Md. Code Ann., Cts. & Jud. Proc. § 6-103(b)(1).

Section 6-103(b)(1) permits personal jurisdiction over a person who performs work or services in Maryland through purposeful, claim-related conduct even without physical presence in the State; out-of-state telephone pharmaceutical counseling can qualify.

Savu v. Purolite Company · filed 2023-02-21(b)(1)

Thus, Savu has made a prima facie showing that Hopkinton engaged in “some purposeful act in Maryland in relation to one or more of the elements of [the] cause of action,” satisfying subsection (b)(1) of the long-arm statute. Aphena, 912 F. Supp. 2d at 315.

Section 6-103(b)(1) permits personal jurisdiction when a defendant transacts business or performs work in Maryland through actions culminating in purposeful activity; physical presence is unnecessary, and even a single contact may suffice.

Yao v. Chen · filed 2024-03-11(b)(1)

The Court, however, finds that Robert Chen “transacted business” in Maryland within the meaning of the Maryland long-arm statute. Under section 6—103(b)(1), the defendant need not have been physically present in the state but must have engaged in actions that “culminate in purposeful activity within the State.” ... Thus, where Robert Chen contacted, negotiated an agreement with, received money from, and mailed a contract to known Maryland residents, and the contract was signed in Maryland and governed the conduct of a company that operated in Maryland, the Court finds that Robert Chen has transacted business within the meaning of section 6—103(b)(1).

Section 6-103(b)(1) permits personal jurisdiction over a person who directly or through an agent transacts business or performs work or services in Maryland, and transacting business requires purposeful activity culminating in the State.

Original Dells, Inc. v. Soul 1 Entertainment Group · filed 2024-09-05(b)(1)

Maryland’s long-arm statute provides that a court may exercise personal jurisdiction “over a person, who directly or by an agent . . . [t]ransacts any business or performs any character of work or service in the State.” Md. Code Ann., Cts. & Jud. Proc. § 6-103(b)(1) (West 2024). “Transacting business” under Maryland’s long-arm statute “requires ‘actions [that] culminate in purposeful activity within the State.’” ... As discussed below, Plaintiffs have made a prima facie showing that Defendants, by arranging and conducting live musical performances at venues in Maryland, have transacted business in Maryland, thus bringing their conduct within the scope of Maryland’s long-arm statute.

Section 6-103(b)(1) permits personal jurisdiction over a defendant who transacted business or performed work in Maryland giving rise to the alleged liability.

Butler v. The Avenue K&B LLC · filed 2025-07-28(b)(1)

Furthermore, Plaintiff alleges in the Complaint that Couser transacted business and performed work in Maryland that gave rise to his liability, satisfying requirements for personal jurisdiction under Maryland’s long-arm statute. Md. Code Ann., Cts. & Jud. Proc. § 6-103(b)(1); see also Carefirst of Maryland, Inc. v. Carefirst Pregnancy Centers, Inc., 334 F.3d 390, 396 (4th Cir. 2003) (“When, however, as here, a district court decides a pretrial personal jurisdiction motion without conducting an evidentiary hearing, the plaintiff need only make a prima facie showing of personal jurisdiction. . . . In deciding whether the plaintiff has made the requisite showing, the court must take all disputed facts and reasonable inferences in favor of the plaintiff.”) (citations omitted). Plaintiff’s allegations establish a prima facie basis for personal jurisdiction.

Section 6-103(b)(1) permits Maryland courts to exercise personal jurisdiction over a person who directly or through an agent transacts business or performs work or service in Maryland, even without the person's physical presence in Maryland.

Tsai · filed 2025-11-24(b)(1)

Under the Maryland long-arm statute, a court “may exercise personal jurisdiction over a person, who directly or by an agent . . . [t]ransacts any business or performs any character of work or service” in Maryland. Md. Code Ann., Cts. & Jud. Proc. § 6—-103(b)(1). Where section 6—-103(b)(1) provides personal jurisdiction over someone who transacts business in Maryland through an agent, it “does not require the defendant to have been physically present in Maryland in order to have ‘transacted business’ within the meaning of the statute.” Hausfeld v. Love Funding Corp., 16 F. Supp. 3d 591, 599 (D. Md. 2014). Where the Amended Complaint alleges that Kleger personally manages Inspire’s business operations in Maryland and personally directed Tsai’s Maryland business activities, which included attending AstraZeneca meetings in Gaithersburg, Maryland and developing business from Maryland-based client relationships, the Court finds that he has, through an agent, engaged in work in Maryland.

Section 6-103(b)(1) permits personal jurisdiction over a person who directly or through an agent transacts business or performs work or services in Maryland.

Ronald Milor, Jr., et al. v. Oasis Hotels & Resorts, S.A. de C.V., et al. · filed 2026-03-30(b)(1)

Plaintiffs offer no facts to suggest that either Defendant “[t]ransacts any business or performs any character of work or service in [Maryland,]” “[c]ontracts to supply goods, food, services, or manufactured products in the State[,]” or “[h]as an interest in, uses, or possesses real property in the State[.]” Md. Code Ann., Cts. & Jud. Proc. §§ 6-103(b)(1), (2), and (5).

Section 6-103(b) permits Maryland to exercise personal jurisdiction over a person who causes tortious injury in Maryland through an agent, and treats a co-conspirator who acts in furtherance of the conspiracy as an agent for that purpose.

Jien v. Perdue Farms, Inc. · filed 2022-07-19(b)

Maryland’s long-arm statute confers personal jurisdiction “over a person, who directly or by an agent . . . [c]auses tortious injury in the State by an act or omission in the State.” Md. Code Ann., Cts. & Jud. Proc. § 6-103(b) (emphasis added). The State’s highest court has determined that a co-conspirator falls within the definition of an “agent” for purposes of its long-arm statute. Mackey v. Compass Mktg., Inc., 391 Md. 117, 142, 892 A.2d 479, 493 (2006) (“a conspirator who performs an act in furtherance of the conspiracy does so as an agent for his co-conspirators.”). This “conspiracy theory” of personal jurisdiction recognizes that certain acts of a co-conspirator done in furtherance of a conspiracy may be attributed to another co-conspirator for purposes of a jurisdictional analysis. Id.

Section 6-103(b)(1) permits jurisdiction based on business transacted in Maryland through an agent acting on a defendant’s behalf and at its direction.

Bradley v. Dentalplans.com · filed 2022-07-27(b)(1)

And by calling Bradley, DentalPlans “performed acts in Maryland on behalf of, and at the direction of, [Cigna]” which constitutes “transacting business” under the long-arm statute.

Section 6-103 permits a subsidiary’s Maryland contacts to be attributed to a nonresident parent for personal jurisdiction only when circumstances warrant piercing the corporate veil.

Burns & Russell Co. of Baltimore v. OLDCASTLE · filed 2002-05-02(b)

To assert jurisdiction over a parent company based on the conduct of a subsidiary, the court must find circumstances warranting it to "pierce the corporate veil." Forum state law determines whether the corporate veil should be pierced to establish personal jurisdiction over a nonresident defendant.