Joseph F. Cunningham v. Matthew Feinberg

Summary

The Court of Appeals of Maryland held that the fact an employment agreement was entered into outside Maryland did not, by itself, bar an unpaid-wage claim under the Maryland Wage Payment and Collection Law. Lex loci contractus was inapplicable because the claim did not require determining the agreement’s validity, enforceability, interpretation, or construction, and the court therefore remanded for further proceedings on the merits. The court also stated in dicta that the MWPCL likely embodies a strong Maryland public policy that could overcome the doctrine. Adkins, J., concurring, would have resolved the case directly on the public-policy exception rather than on the majority’s principal ground.