At first glance, the phrase prima facie sounds like something pulled from a dusty law school textbook—Latin jargon with little practical meaning. But this term has real power for plaintiffs, especially in personal injury and civil rights cases. It is the legal foundation that can decide whether your case gets to a jury or gets thrown out before it even begins.
This page explains what a prima facie case is, why it matters, and how Maryland courts treat this concept in practice. We will explain how it applies to negligence claims, what makes a claim strong enough to survive summary judgment, and how Maryland courts have handled it over the years—from century-old case law to modern rulings involving everyday car crashes.
Understanding prima facie is not just for lawyers. It is about knowing the rules of the courtroom—rules that can determine whether your voice gets heard. Whether you are suing a negligent driver, a school that failed to protect your child, or a powerful institution that enabled abuse, establishing a prima facie case is often the first—and most important—legal hurdle.
Let’s walk through what it means, why it matters, and how this seemingly technical concept has real, high-stakes consequences for people trying to hold wrongdoers accountable.
What Is a Prima Facie Case?
Prima facie is Latin for “on the face of it” or “at first sight.” In legal contexts, it refers to an assumption or presumption that is accepted as true unless it is rebutted or proven otherwise. A prima facie case is one where the plaintiff has presented sufficient prima facie medical evidence or factual support to shift the burden of proof to the defendant.
In other words, if you bring a negligence claim and show that a duty existed, it was breached, and harm resulted, you’ve likely established a prima facie negligence claim. The defendant must then respond with evidence to dispute that assumption. Without a rebuttal, your case could move forward to trial or even win outright.
The Legal Significance of a Prima Facie Case
A prima facie case creates a legal presumption that, unless disproved, allows the case to survive summary judgment and reach a jury. It is not necessarily the end of the story, but it is often enough to get through the courthouse doors. The concept of prima facie liability applies across civil law, including torts, contracts, and especially personal injury cases.
Prima Facie Legal Meaning and Use in Maryland Law
The prima facie legal meaning often refers to evidence that is legally sufficient to establish a fact unless rebutted. Maryland appellate courts and legislators sometimes use the term to describe compelling legal evidence, often in the form of a rebuttable presumption. This means the court tells the jury to assume the fact is true unless sufficient evidence is presented to dispute that fact.
Example Prima Facie Negligence in Personal Injury Cases
Let’s take an example of prima facie negligence. If a car rear-ends another vehicle, Maryland courts may recognize a prima facie case of liability against the rear-ending driver. The burden then shifts to that driver to provide an explanation—maybe the front driver stopped abruptly or the brakes failed due to a manufacturing defect.
So, in this sense, a prima facia case (often misspelled) is the plaintiff’s opportunity to show the basic building blocks of their claim. If those elements are supported by credible evidence, the case proceeds unless the defense can prove me otherwise.
Misunderstanding the Term: Prima Facie vs. Prima Facia
The term is frequently misspelled as prima facia, even by lawyers. In a recent unreported appellate opinion, the court even mocked a lawyer’s mistake by inserting a “[sic]” when quoting the erroneous spelling in the brief—though that lawyer still won the appeal. Precision matters, especially when you’re trying to establish something as foundational as a prima facie case.
Historical Use in Maryland Case Law
The concept of a prima facie case has deep roots in Maryland jurisprudence. One of the earliest and most cited explanations comes from the 1924 Maryland Court of Appeals case Motor Car Co. v. First National Bank, where the court turned to Jones’ Commentaries on Evidence to explain the subtle but crucial distinction between the burden of proof and the weight of the evidence.
“During the progress of a trial it often happens that a party gives evidence tending to establish his allegation, sufficient, it may be, to establish it prima facie, and it is sometimes said that the burden of proof is then shifted.
All that is meant by this is that there is a necessity for evidence to answer the prima facie case or it will prevail; but the burden of maintaining the affirmative of the issue involved in the action is upon the party alleging the fact which constitutes the issue, and this burden remains throughout the trial.”
This principle has been reaffirmed in numerous Maryland decisions. In Imbraguglio v. Great A&P Tea Co., 358 Md. 194 (2000), the Court of Appeals stated that:
“A prima facie case is made when the plaintiff produces evidence that, if believed, would support the elements of the claim. The defendant then has the opportunity to rebut or challenge that evidence, but the burden of persuasion never shifts.”
In Edwards v. Corbin, 379 Md. 278 (2004), the court explained how prima facie evidence may compel a case to survive summary judgment or a motion for judgment:
“When a party introduces prima facie evidence, the court is not to weigh its persuasiveness. If the evidence, taken in the light most favorable to the non-moving party, supports the necessary elements, the matter is for the jury.”
Additionally, in Stanley v. State, 313 Md. 50 (1988), the Maryland high court noted that prima facie may serve as a trigger for a legally mandatory rebuttable presumption—shifting the tactical burden to the opposing party without relieving the original party from the burden of persuasion:
“The establishment of a prima facie case does not mean the plaintiff wins as a matter of law. It simply entitles the plaintiff to go forward and have the issue decided by the fact-finder, unless the defendant can present sufficient rebuttal evidence to defeat the presumption.”
These cases underscore that Maryland courts treat prima facie legal meaning as a procedural threshold rather than an evidentiary conclusion. Establishing a prima facie case—whether in negligence, contract, or tort—is often the decisive step in surviving pre-trial motions and reaching a jury.
Modern Interpretation: Stanley v. State
In Stanley v. State, a 1988 opinion, the Maryland high court reaffirmed that a prima facie case is the establishment of a legally mandatory, rebuttable presumption. This interpretation closely aligns with the German concept of anscheinsbeweis, which also refers to assumed facts unless proven otherwise.
Trial Strategy and the Importance of a Prima Facie Case
Establishing a prima facie case at trial is often the minimum needed to survive a motion for summary judgment or directed verdict. Once this threshold is met, the court allows the fact-finder (usually the jury) to weigh the evidence unless and until the defense can rebut the presumption.
For lawyers, especially in Maryland personal injury cases, recognizing and presenting prima facie medical evidence can be the difference between dismissal and success. It’s the backbone of litigation strategy and the first step toward recovery.
Related Content
- JNOV Opposition Motion
- Andrade v. Housein – A rear-end accident case involving rebuttable presumption of fault.