Four Aces Case Study

Four Aces argues that the District Court should be estopped from enforcing Four Aces’ liability on bonds which the District Court had purportedly closed. The District Court, for its part, argues that the State cannot be estopped from enforcing its valid statutes, and alternatively that Four Aces’ fails to satisfy the elements so as to invoke the doctrine of estoppel. We hold that the doctrine of equitable estoppel cannot apply to compel the State to act in violation of law. “[E]quitable estoppel [is] the effect of the voluntary conduct of a party whereby he is absolutely precluded, both at law and in equity, from asserting rights which might perhaps have otherwise existed, either of property, of contract, or of remedy, as against another …show more content…
Transp. Auth. Police Lodge No. 35 of FOP, Inc. v. Md. Transp. Auth., 195 Md. App. 124, 217-18 (2010), rev’d on other grounds, 420 Md. 141 (2011). Although we have never applied equitable estoppel against the State, in the few instances where the doctrine has been applied against lesser municipalities, have held that“[a] municipality may be estopped to deny the actions of its officers when they were taken within the scope and course of their actual authority.” Anne Arundel Cnty. v. Muir, 149 Md. App. 617, 636 (2003). The negative corollary is that “estoppel will not apply to an act of a municipal corporation’s officer that is outside his actual authority, . . . or that is taken in violation of the law.” Id. at 637 (citations omitted). Accordingly, the narrow exception to the general prohibition on applying equitable estoppel against the State requires not only that the State induce another to act to the other’s detriment and the other acts in reliance on that inducement, but the inducement the State originally must not have usurped its actual