Under the Statute or Ordinance Rule, "[i]t is the existence of [a] cause and effect relationship that makes the violation of a statute prima facie evidence of negligence." Brooks, 378 Md. at 79 (internal citation omitted). "To prove causation in a lead paint case, a plaintiff must prove that the defendant's negligence was a substantial factor in causing the plaintiff's injury." Kirson v. Johnson, 236 Md.App. 384, 392 (2018). That is, a plaintiff must "produce evidence from which a jury could find that lead-based paint was present at the property and that [the plaintiff] was exposed to it there."
This Court has further clarified: "To prove causation in a lead paint case, a plaintiff must prove that the defendant's negligence was a substantial factor in causing the plaintiff's injury." Kirson v. Johnson, 236 Md.App. 384, 392 (2018). "Put another way," I'Maya must "produce evidence from which a jury could find that lead-based paint was present at the property and that [s]he was exposed to it there."
Appellant points to no case holding that a trial court is required to admit an Arc Report into evidence. Appellants rely on Ross v. Housing Auth. of Baltimore City, 430 Md. 648, 655 (2013); and Kirson v. Johnson, 236 Md. App. 384, 388-89, cert. denied, 459 Md. 185 (2018), as cases where Arc Reports were admitted. In Ross, 430 Md. at 652, there is no discussion of the issue other than the statement that the plaintiff relied on the report.