Khan v. Howard County Bd. of Appeals (July 20, 2026)

Case details
Full caption
LUBNA KHAN v. HOWARD COUNTY BOARD OF APPEALS
Country
United States
Jurisdiction
Maryland (MD)
Court
Supreme Court of Maryland
Decided
July 20, 2026
LUBNA KHAN v. HOWARD COUNTY BOARD OF APPEALS, ET AL., Not Reported in Atl. Rptr. (2026) WESTLAW   © 2026 Thomson Reuters. No claim to original U.S. Government Works.12026 WL 2085160Only the Westlaw citation is currently available.UNREPORTED*Appellate Court of Maryland.LUBNA KHANv.HOWARD COUNTY BOARD OF APPEALS, ET AL.No. 968, September Term, 2025,No. 1060, September Term, 2025|Filed: July 20, 2026Editor's Note: This document contains discussion ofunverified citations, likely generated by AI tools used by aparty or counsel. These citations are not attributable to theCourt. The unverified citations have been preserved as part ofthe official record, but links are unavailable.Circuit Court for Howard County Case No. C-13-CV-25-000106Case No. C-13-CV-24-000579Graeff, Friedman, Zic JJ.OpinionOpinion by Zic, J.*1 This consolidated appeal arises from a 2022 noise disputeand ensuing administrative and civil proceedings betweenLubna Khan, appellant, and a neighboring pet day careand kennel. In August 2024, Ms. Khan filed an amendedpetition for judicial review of the Howard County Boardof Appeals’ (“Board”) administrative ruling.1 In February2025, Ms. Khan filed a separate complaint alleging, amongother things, civil conspiracy, defamation per se, false lightdefamation, and infringement of her Fourteenth Amendmentrights to due process and equal protection.2,3QUESTIONS PRESENTEDCumulatively, Ms. Khan presents 21 questions for our review,which we have recast and rephrased as follows:41. Did the circuit court err in granting the motion todismiss?2. Did the circuit court err in affirming the Departmentof Public Service and Zoning Administration's (“DPZ”)decision?For the following reasons, we answer both questions in thenegative and affirm.BACKGROUND*2 This is the second appeal before this Court regarding azoning dispute in Clarksville, Maryland. See Khan v. Kendall,Nos. 1399 & 2115, Sept. Term 2023, 2024 WL 4523785, at*1-2 (Md. App. Oct. 18, 2024).5 We provide an abbreviatedrecitation of the facts most relevant to this appeal below.In February 2022, Ms. Khan filed a noise complaint with DPZagainst a neighboring commercial property (“Property”). Id.at *1. The Property's tenant operates a pet services businessknown as Pinkie's Play Place (“Business”), which offersindoor and outdoor boarding of pets and pet care during theday. Id. Ms. Khan's noise complaint “alleged that the Businesswas illegally allowing dogs to be outdoors all day and that thedogs barked nonstop, disturbing her use of her home, whichis located directly across the street from the Property.” Id.DPZ inspected the Property and concluded that the Business’use did not violate the Howard County Zoning Regulations.Id. Ms. Khan appealed this decision to the Board's HearingExaminer, who, in January 2023, issued a corrected orderdirecting DPZ to reopen the case and issue a notice ofviolation to the owner of the Property. Id. at *2. DPZ thenissued a notice of violation to the Property's owner. Id.The owners of the Property and the Business timely appealedthe Hearing Examiner's decision and order to the Board. InSeptember 2024, the Board reversed the Hearing Examiner'sdecision, determining that “DPZ's decision to not issue a[n]otice of [v]iolation was not arbitrary or capricious[,]” andthat, as the reviewing court, it should “give[ ] considerableweight” to DPZ's interpretation of the Howard County ZoningRegulations because “the agency exercises expertise in thefield.”
LUBNA KHAN v. HOWARD COUNTY BOARD OF APPEALS, ET AL., Not Reported in Atl. Rptr. (2026) WESTLAW   © 2026 Thomson Reuters. No claim to original U.S. Government Works.2Ms. Khan's Petition for Judicial Review and Circuit CourtProceedingsIn September 2024, Ms. Khan filed a second amended noticeof petition for judicial review of the decision of the Boardin the Circuit Court for Howard County. After a one-dayhearing in January 2025, the court held the matter sub curia,and in June 2025, issued a memorandum opinion and orderconcluding “that the decision by the Board was supported bysubstantial evidence and further, that there were no errors oflaw.” Ms. Khan filed a “Motion to Alter or Amend or Reviseand Motion for a New Trial[,]” which the court denied. Ms.Khan timely noted an appeal.Ms. Khan's Civil Complaint and Circuit CourtProceedingsIn February 2025, Ms. Khan filed a civil complaint againstthe following: Howard County, Maryland; the Board; theBoard's administrator; Board members (current and former);the Howard County Office of Law; and the Senior AssistantCounty Solicitor. Her complaint included seven counts: onecount of civil conspiracy, two counts of defamation per se, twocounts of false light defamation, one count of infringement ofher Fourteenth Amendment rights to due process and equalprotection, and one count of “[d]enial of [e]qual [p]rotection”under Howard County Code § 102.0B. All named defendantsfiled a motion to dismiss with prejudice.*3 Following a motions hearing at which Ms. Khanappeared pro se, the circuit court issued a correctedmemorandum and order granting the motion to dismiss. Thecourt found that “[a]ll of the acts purported by [Ms. Khan]arise from the adjudicatory function of the [Board]” and that“the [d]efendants, named or otherwise, are all members ofthe [Board, and] are entitled to absolute immunity.” The courtfurther noted that Ms. Khan “even states in the complaint ...that the [Board] is an administrative body responsiblefor adjudicating land disputes.” The court determined thatall actions of which Ms. Khan complained constituted“acts which arise from an adjudicatory function[,]” and,“[t]herefore, ... the [d]efendants are entitled to absoluteimmunity under the theory of quasi-judicial immunity.” Ms.Khan timely appealed.STANDARD OF REVIEW“In appeals from circuit court judgments on administrativeagency decisions, we ‘repeat the task of the circuit court, i.e.,to determine whether the circuit court's review was correct.’” Matter of HRVC Ltd. P'ship, 266 Md. App. 391, 421 (2025)(quotation omitted). “[W]e analyze ‘the agency's decisionusing the same standards used by the circuit court.’ ” Id.(quotation omitted). We limit our review “to determiningwhether there is substantial evidence in the record as a wholeto support the agency's findings and conclusions, and todetermine if the administrative decision is premised upon anerroneous conclusion of law.” Id. (citing Kenwood GardensCondo., Inc. v. Whalen Props., LLC, 449 Md. 313, 325(2016)).Appellate courts “review the grant or denial of a motionto dismiss to determine whether the trial court was legallycorrect.” Patriot Constr., LLC v. VK Elec. Servs., LLC, 257Md. App. 245, 271 (2023) (citing Blackstone v. Sharma,461 Md. 87, 110 (2018)) (further citation omitted). Inreviewing the trial court's decision, “we must assume thetruth of all well-pleaded facts and allegations contained inthe complaint, and view those facts, as well as all inferencesthat may reasonably be drawn from them, in the lightmost favorable to the non-moving party.” Patriot Constr.,LLC, 257 Md. App. at 271 (citation omitted). “An ordergranting dismissal is appropriate ‘only if the allegations andpermissible inferences, if true, would not afford the relief tothe plaintiff.’ ” Id. at 271-72 (quotations omitted).DISCUSSIONI. MULTIPLE PORTIONS OF MS. KHAN’S BRIEFSMUST BE STRICKEN.We have identified numerous issues with the cases cited inMs. Khan's filings with this Court. Of the 148 cases cited inMs. Khan's filings to this Court, at least 40 contained a citationirregularity.6,7We strike the portions of Ms. Khan's briefs as pertinentto her arguments that the Board arbitrarily interpretedHoward County Zoning Regulations § 119.0B(47), (65),that “Joseph Rutter[’s] testimony lacks credibility[,]” andthat “there is no substantial evidence that supports theProperty operates a kennel” because of the following citationirregularity: Superior outdoor signs v. Eller media Co., 150Md. App.479,497-98 (App. 2003), see No. 1060 Reply Br.to Board at 17; No. 1060 Reply Br. to DPZ at 10, does notcontain the language that Ms. Khan purports to quote.
LUBNA KHAN v. HOWARD COUNTY BOARD OF APPEALS, ET AL., Not Reported in Atl. Rptr. (2026) WESTLAW   © 2026 Thomson Reuters. No claim to original U.S. Government Works.3*4 We strike the portions of Ms. Khan's briefs as pertinentto her arguments that the “Board lacked [s]ubject [m]atterjurisdiction[,]” that “absolute immunity does not apply[,]”that the Board forfeited its immunity, that “[p]etitioning[p]arties [l]acked [s]tanding and [j]usticiable [c]laim[,]” thatMs. Khan's Fourteenth Amendment rights were violated, “ex-parte communication[,]” and “civil conspiracy” because ofthe following citation irregularities:• Engineering Mgmt. Servs., 375 Md. at 242, see No. 968Appellant's Br. at 18, does not stand for the propositionasserted.• Shell Oil Co. v. Supervisor, 276 Md. 46, 343 A.2d 526-527(1975), see No. 968 Appellant's Br. at 18, does not standfor the proposition asserted.• Mandel v. O'Hara, 320 Md. 103, 113 (1990), see No. 968Appellant's Br. at 18, does not stand for the propositionasserted.• Parker v. State, 337 Md. 271, 284 (1995), see No. 968Appellant's Br. at 18, No. 968 Reply Br. at 3, does notstand for the proposition asserted.• Talbot Cnty., 316 Md. at 339, see No. 968 Appellant'sBr. at 19, does not contain the language that Ms. Khanpurports to quote.• Patterson v. Ramsey, 413 F. Supp. 523, 531 (D.Md.1976),see No. 968 Appellant's Br. at 23, does not contain thelanguage that Ms. Khan purports to quote.• Logan v. Zimmerman Brush 455 U.S. 42(1982), see No.968 Appellant's Br. 23, does not contain the languagethat Ms. Khan purports to quote.• Rodriguez v. Mayor & City Council of Balt., 387 Md.1, 26 (2005), see No. 968 Appellant's Br. 23-24; No.1060 Appellant's Br. 28; No. 1060 Reply Br. to Board 13,does not exist. The case found at the principal citationis Johnson v. Mayor & City Council of Balt., 387 Md.1 (2005), a case about whether firefighters’ dependentsmay collect full workers’ compensation death benefits inaddition to service pension benefits.• Queen Anne's Conservation, Inc. v. Cnty. Comm'rs ofQueen Anne's Cnty., 382 Md. 306, 326 (2004), seeNo. 968 Appellant's Br. at 24, does not stand for theproposition asserted.• Howard Cnty. v. Mangione, 47 Md. App. 350, 353 (1980),see No. 968 Appellant's Br. at 24; No. 1060 Appellant'sBr. at 25, 27, neither contains the language that Ms. Khanpurports to quote nor stands for the propositions asserted.• Calvert Cty. Planning Comm'n v. Howlin Realty Mgmt.,Inc., 364 Md. 301, 322 (2001), see No. 968 Appellant'sBr. at 24, does not contain the language that Ms. Khanpurports to quote.• Tumey v. Ohio, 273 U.S. 510 (1927), see No. 968Appellant's Br. at 25, does not contain the language thatMs. Khan purports to quote.• Hill v. Baltimore County, 86 Md. App. 642, 660 (1991),see No. 968 Appellant's Br. at 25, does not contain thelanguage that Ms. Khan purports to quote.• Simms v. Maryland Dep't of Health, 240 Md. App. 294,326 (2019), aff'd, 467 Md. 238 (2020), see No. 968Appellant's Br. at 25, does not stand for the propositionasserted.• Boehm v. Anne Arundel County, 54 Md. App. 497, 511(1985), see No. 968 Appellant's Br. at 25-26, does notstand for the proposition asserted.• Mathews v. Eldridge, 424 U.S. 319, 332-35 (1976), seeNo. 968 Appellant's Br. at 26, does not contain thelanguage that Ms. Khan purports to quote.• Tyler v. College Park, 415 Md. 475, 499-500, 3 A.3d 421,434- 435 (2010), see No. 968 Appellant's Br. at 27, doesnot stand for the proposition asserted.• Smith v. McCullough, 141 U.S. 589 (1891), see No. 968Reply Br. at 1, does not exist. The case found at theprincipal citation is Marshall v. Holmes, 141 U.S. 589(1891), a case about the power of equity courts to grantrelief against judgments obtained by fraud.*5 • Espina v. Prince George's Cnty., 438 Md.634 (2014),see No. 968 Reply Br. at 13, does not exist. The casefound at the principal citation is MVA v. Deering, 438Md. 611 (2014), a case about suspected drunk driversnot being able to avoid automatic administrative licensesuspension for refusal to take a blood alcohol test or testresults that reveal a blood alcohol concentration abovecertain levels.
LUBNA KHAN v. HOWARD COUNTY BOARD OF APPEALS, ET AL., Not Reported in Atl. Rptr. (2026) WESTLAW   © 2026 Thomson Reuters. No claim to original U.S. Government Works.4• Mallette v. Arlington Cty. Emps. Supp. Ret. Sys., 91 F.3d630, 634 (4th Cir. 1996), see No. 968 Reply Br. at 13-14,does not stand for the proposition asserted.• Thacker v. Hale, 146 Md. 638, 651–52 (1924), see No.1060 Appellant's Br. at 20, 24, does not exist. The casefound at the principal citation is Stiegler v. Eureka LifeIns. Co. of Balt., 146 Md. 629 (1925), a case about a lifeinsurance company's payment obligation.• Mayer v. Montgomery Cnty., 143 Md. App. 216 (2002),see No. 1060 Appellant's Br. at 20, does not exist. Thecase found at the principal citation is Brown v. Contemp.OB/GYN Assocs., 143 Md. App. 199 (2002), a case abouta medical malpractice claim.• Angel Enterprises v. Talbot County, 474 Md. 237,266 (2021) (quoting K. Hovnanian, 472 Md. at 292)(emphasis in original), see No. 1060 Appellant's Br. at23, does not contain the language that Ms. Khan purportsto quote.• Clipper v. Sprenger, 924 A.2d 1160, 1171, 399 Md.539 (2007), see No. 1060 Appellant's Br. at 25, neithercontains the language that Ms. Khan purports to quotenor stands for the proposition asserted.• Maryland-National Capital Park & Planning Comm'n v.Smith, 333 Md. 3, 10-14, 633 A.2d 855, 859-61 (1993),see No. 1060 Appellant's Br. at 26, does not contain thelanguage that Ms. Khan purports to quote.• United Parcel Serv. Inc. v. People's Counsel, 336 Md. 569,576 (1994), see No. 1060 Appellant's Br. at 26, does notstand for the proposition asserted.• Pollock v. Patuxent Inst. Bd. of Review, 374 Md. 463, 503(2003), see No. 1060 Reply Br. to Board at 12, does notstand for the proposition asserted.• Bell v. Anne Arundel Cnty., 215 Md. App. 161, 169 (2013),see No. 1060 Reply Br. to Board at 14, does not standfor the proposition asserted.• Joseph H. Munson Co. v. Sec'y of State, 294 Md. 160,168–69 (1982), see No. 1060 Reply Br. to Board at 14,does not stand for the proposition asserted.• Hayden v. Md. Dep't of Nat. Res., 242 Md. App. 505,520-21 (2019), see No. 1060 Reply Br. to DPZ at 10,does not contain the language that Ms. Khan purports toquote.• Adams v. Manown, 328 Md. 463, 476 (1992), see No.1060 Reply Br. to DPZ at 12, does not stand for theproposition asserted.• Sherwood Co. v. Sherwood Distilling Co., 177 Md. 455(1939), see No. 1060 Reply Br. to DPZ at 12-13, doesnot stand for the proposition asserted.• Reyes 281 Md. at 288, see No. 1060 Reply Br. to DPZ at13, does not contain the language that Ms. Khan purportsto quote.We strike the portions of Ms. Khan's briefs as pertinent toher arguments regarding “defamation per se” and “false light”because of the following citation irregularities:• Padgett v. Sweeting, 65 Md. 404 (1886), see No. 968Appellant's Br. at 29, does not contain the language thatMs. Khan purports to quote.• Peurifoy v. Congressional Motors, 254 Md. 501, 510(1969), see No. 968 Appellant's Br. at 29-30, twice doesnot stand for the proposition asserted.*6 • McClure v. Lovelace, 214 Md. App. 716, 739–40(2013), see No. 968 Appellant's Br. at 31, does not standfor the proposition asserted.• Piscatelli v. Van Smith, 424 Md. 294, 306 (2012), see No.968 Appellant's Br. at 32, No. 968 Reply Br. at 8, twicedoes not stand for the proposition asserted.• Bagwell v. Peninsula Reg'l Med. Ctr., 106 Md. App. 470,507 (1995), see No. 968 Appellant's Br. at 32, does notstand for the proposition asserted.We strike the portions of Ms. Khan's briefs as pertinent to herargument that “[t]here is [n]o [c]laim [s]plitting” because ofthe following citation irregularities:• Burke v. Md. Bd. of Physicians, 250 Md. App. 334, 344(2021), see No. 968 Appellant's Br. at 33, does not standfor the proposition asserted.• Md. Rule 7-208, see No. 968 Appellant's Br. at 33, doesnot stand for the proposition asserted.Although we have detailed Ms. Khan's case citation defects,and they are legion, the defect in her briefs runs deeper.
LUBNA KHAN v. HOWARD COUNTY BOARD OF APPEALS, ET AL., Not Reported in Atl. Rptr. (2026) WESTLAW   © 2026 Thomson Reuters. No claim to original U.S. Government Works.5Maryland Rule 8-504(6) requires “[a]rgument in support ofthe party's position on each issue.” That requirement does notturn on citation form, or on citation to case law at all. Ms.Khan's citations stood in for her argument. Once we strike thecitations that misstate the law, misquote the cases, or cite casesthat do not exist, nothing remains from which we can discernwhat she was arguing. This is a failure of argument, not afailure of citation form, and it is fatal under Rule 8-504(a)(6). “This Court cannot be expected to seek out law or factsin favor of either party.” Oxley v. Frederick Mem. Hosp., 268Md. App. 575, 587 n.6 (2026) (citation omitted). Accordingly,we will not reach either issue.JUDGMENTS OF THE CIRCUIT COURT FORHOWARD COUNTY AFFIRMED; COSTS TO BE PAIDBY APPELLANT.All CitationsNot Reported in Atl. Rptr., 2026 WL 2085160Footnotes*This is an unreported opinion. This opinion may not be cited as precedent within the rule of stare decisis. Itmay be cited for its persuasive value only if the citation conforms to Maryland Rule 1-104(a)(2)(B).1Ms. Khan filed this lawsuit against both the Board and the Howard County Department of Planning and Zoning.2Ms. Khan named as defendants in this lawsuit: Howard County, Maryland, the Board, the Board'sadministrator, Board members (current and former), the Howard County Office of Law, and the SeniorAssistant County Solicitor.3Separate from the appeals consolidated here, we note that Ms. Khan has pursued additional litigationfactually related the underlying zoning dispute. See Matter of Khan, No. 2077, Sept. Term 2024, 2025 WL3122762 (Md. App. Nov. 7, 2025) (seeking review of the administrative response to Ms. Khan's MarylandPublic Information Act requests pertaining to the property at issue in the instant appeal); C-13-CV-24-000375(same); C-13-CV-24-000471 (same).4Ms. Khan presented the following 13 questions in her brief in Appeal No. 968:1. Whether circuit court consideration of matters outside the complaint submitted with [the] Board'sdispositive motion converted it to a motion for summary judgment and should have been denied[.]2. Whether the Board's arbitrary and unlawful conduct—including altering evidence, ex partecommunications, andin the absence of jurisdiction—supports independent LGTCA claims rather than claim-splitting, sincejudicial review provides no monetary remedy constitutional and tort claims[.]3. Whether the court committed reversible and prejudicial legal errors in dismissing [Ms.] Khan's LGTCAclaims on grounds of absolute immunity in the absence of complete jurisdiction of the Board[.]4. Whether complete absence of jurisdiction renders [the] Board's decision void ab initio—and a bar toabsolute immunity to all claims pled by [Ms.] Khan including constitutional claims [under] 42 U.S.C.§ 1983, warrants federal review[.]5. Whether the fraudulent and corrupt action of the Board altering evidence was shielded by absoluteimmunity in the absence of jurisdiction[.]
LUBNA KHAN v. HOWARD COUNTY BOARD OF APPEALS, ET AL., Not Reported in Atl. Rptr. (2026) WESTLAW   © 2026 Thomson Reuters. No claim to original U.S. Government Works.66. Whether [the] Board violated [Ms.] Khan's due process rights by refusing to grant her a hearingon dispositive motions, issuing blanket denials, effectively mischaracterizing motions content andchallenges to the Board's jurisdiction, standing of interested parties, and the justiciability of their claimsunder §[ ]102.0[.]7. Whether [the] Board's failure to terminate the proceeding and disclose its ex-parte communicationswas actionable per M[aryland] Code, State Gov't § 10-219 and voids its decision[,] or is it shielded byabsolute immunity in the absence of jurisdiction[.]8. Whether DPZ's [f]ailure to [e]nforce the [c]itation, despite §[ ]102.0 [m]andating [e]nforcement[i]ndependent of [h]earing [a]uthority, [n]on-[d]iscretionary [o]nce [m]ade [a]ware of violation, [w]as[a]rbitrary and [c]ontrary to [l]aw [r]equires [the] [c]ourt [t]o [i]ssue [m]andamus[.]9. Whether [the] court[’s] action was erroneous because it overlooked the elements of the complaint ofconspiracy[.]10. Whether the Board/Chair enjoy a qualified or absolute privilege for its defamatory per se statementsand/orplacing [Ms.] Khan in [f]alse [l]ight in the absence of jurisdiction[.]11. Whether there is competent evidence to support an award of compensatory damages[.]12. Whether an award of $1.00 in compensatory damage[s] support[s] an award of punitive damages[.]13. Whether the Board could legislate or it acted arbitrar[ily][.]Ms. Khan presented the following eight questions in her brief in Appeal No. 1060:1. Whether the Board lacked subject matter jurisdiction under Cts. & Jud. Proc. §[ ]4-401 by reopeningan administratively closed case and asserting jurisdiction over a district court citation[.]2. Did the [B]oard act arbitrar[ily], contrary to the law and illegal[ly] when it lacked subject matterjurisdiction to hear [an] invalid petition, in violation of HCC §[ ]102.0B and §[ ]16.302[,] therebyrendering its decision void ab initio?3. Whether the Board acted arbitrar[ily], contrary to the law, unreasonabl[y][,] and fraudulent[ly] to reverse[the] citation by designating [Ms.] Khan as petitioner and proceeding without jurisdiction, where shenever petitioned the Board, had already prevailed, and was no longer aggrieved[.]4. Whether Lisa Reuwer and Dogs and Cats, LLC, lack[ed] any cognizable interest in 100% Land, hadstanding or a justiciable claim to initiate or maintain the proceeding[.]5. Whether the Board's undisclosed conflicts of interest, ex parte communications, and alteration of [Ms.]Khan's exhibits rendered its proceedings arbitrary, fraudulent, and void[.]6. Whether the Board lacked authority as an administrative board to engage in [a] legislative act bychanging the governing statute (§[ ]102.0B) to allow direct appeals in violation of §[ ]16.302[.]7. Whether the circuit court committed prejudicial reversible legal error by affirming the Board's voiddecision and failing to safeguard [Ms.] Khan's constitutional right to a fair and impartial tribunal, [a]due process protection warranting federal review[.]
LUBNA KHAN v. HOWARD COUNTY BOARD OF APPEALS, ET AL., Not Reported in Atl. Rptr. (2026) WESTLAW   © 2026 Thomson Reuters. No claim to original U.S. Government Works.78. Whether the Board's interpretation of HCC §[ ] 119.0.B(47) and (65) was correct or arbitrary,unreasonable, without rational basis, and contrary to law[.]5In the first consolidated appeal before this Court, Ms. Khan had “filed an amended complaint against the ...then-acting Director of the Howard County [DPZ] ... seeking a writ of common-law mandamus.” Khan, No.1399, 2024 WL 4523785, at *1. We affirmed the circuit court's dismissal of Ms. Khan's amended complaint“for three key reasons: (1) [Ms.] Khan lacked a clear right to compel DPZ's issuance of a citation, (2) codeenforcement is not a ministerial act, and (3) [Ms.] Khan had an adequate alternative legal remedy.” Id. at *3-4.6We further note that, of the 148 cases cited in Ms. Khan's filings, six were not appropriately noted in thetables of authorities, in violation of Maryland Rule 8-504(a)(1). We also note that several page notations ofcase references within the briefs were incorrect in the tables of authorities. “[T]he procedural, evidentiary, andappellate rules apply alike to parties and their attorneys. No different standards apply when parties appearpro se.” Gantt v. State, 241 Md. App. 276, 302 (2019) (alteration and emphasis in original) (quotation omitted).7The citation irregularities identified in this opinion are copied, without alteration, from Ms. Khan's briefs.End of Document© 2026 Thomson Reuters. No claim to original U.S. Government Works.
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