U.S. Court of Appeals for the Fourth Circuit
Nancy Levine v. Yankee Candle Company, Inc.
August 19, 2026
Summary
The court affirmed dismissal of Levine's negligence action because she failed to timely serve Yankee Candle under Maryland law, despite a later reissuance of process and eventual service. The court held that the state court had not made a final determination entitled to full faith and credit and that the federal district court could decide the reserved service issue after removal. The court also held that Levine forfeited additional arguments by raising them for the first time on appeal.