Document Type


Publication Date

Spring 2008


In this article the author pays tribute to Judge Raker’s pre-law school tour de force citizen testimony in Eger v. Stone, 253 A.2d 372 (Md. 1969), which established the standard for credibility of lay witnesses in zoning cases, acceptance of citizen testimony as establishing the basis for an application’s denial, and acceptance of hearsay in an administrative forum in Maryland.

Judge Raker was a student of the author, who taught a course in modern land law at the Washington College of Law during Judge Raker’s tenure in law school. The article discusses two of Judge Raker’s real estate transaction opinions, Myers v. Kayhoe, 892 A.2d 520 (Md. 2006) and Cochran v. Norkunas, 919 A.2d 700 (Md. 2007), in terms of the common method by which the judge decided them. In each, Judge Raker invoked the objective theory of contracts by letting the documents, not the surrounding circumstances nor the expectations of the parties as they might be shown outside the four corners of the documents, control.



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