# ARA Health Services, Inc. v. Department of Public Safety & Correctional Services

> Court of Appeals of Maryland · November 26, 1996 · 344 Md. 85

URL: https://www.frixlaw.com/law-library/cases/9885192

## Case

- **Full name:** ARA HEALTH SERVICES, INC., D/B/A Correctional Medical Systems, v. DEPARTMENT OF PUBLIC SAFETY AND CORRECTIONAL SERVICES
- **Court:** Court of Appeals of Maryland
- **Decided:** November 26, 1996
- **Citations:** 344 Md. 85; 685 A.2d 435; 1996 Md. LEXIS 123
- **Precedential status:** Published
- **Opinion:** Concurrence by Chasanow
- **Judges:** murphy,c
- **Cited by:** 49 later opinions in the Frix Law Library

## Citator (automated)

- No negative treatment found by the automated citator. That is not the same as a confirmation that the case is good law; read the citing cases.
- Full citator and citing cases: https://www.frixlaw.com/law-library/cases/9885192

## How later opinions describe it (automated extraction)

- holding that, “generally, quasi-contract claims such as quantum meruit and unjust enrichment cannot be asserted where an express contract ... exists”
- holding that the state had not waived immunity under § 12-201(a
- holding that immunity was not waived where a claim did not satisfy the formal requirements of a written contract under S.G. § 12-201(a)
- stating that “[o]rdinarily, the doctrine of estoppel does not apply against the State....”
- noting that the doctrine of sovereign immunity “precludes suit against the governmental entities absent the State’s consent”

## Opinion text

*97 CHASANOW, Judge,
concurring:
I concur in the judgment in this case for the reasons stated by Judge Hollander in her excellent opinion in Dept. of Public Safety v. ARA 107 Md.App. 445 , 668 A.2d 960 (1995).

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Source: Frix Law Library, https://www.frixlaw.com/law-library/cases/9885192. Public record. Not legal advice.