Abrams v. Lamone
Annotate this Case
Download PDF
Stephen N. Abrams v. Linda A. Lamone, et al., No. 142, September Term 2005. Opinion by Bell, C.J. CONSTITUTIONAL LAW - INTERPRETATION - ELIGIBILITY REQUIREMENTS ATTORNEY GENERAL The constitutional requirements, as prescribed by Article V, § 4 of the Maryland Constitution , for the off ice of the A ttorney Gene ral of Ma ryland mand ate that a can didate for that office be a member of the Maryland Bar for at least ten years and be a practitioner of law in Maryland for an identical requisite period. Where a candidate was a member of the Maryland Bar for only five years, and practiced, albeit for a period of more than ten years, primarily outside of the State, he was ineligible to run for the office of the Attorney General in the primary election. IN THE COURT OF APPEALS OF MARYLAND No. 142 September Term, 2005 STEPHEN N. ABRAMS v. LINDA H. LAMONE, et al. Bell, C. J. Raker *Wilner Cathell Harrell Greene Eldridge, John C. (Retired, specially assigned), JJ. Plurality Opinion by Bell, C. J., which Wilner and Cathell, JJ., join. Concurring Opinion by Eldridge, J., which Raker, J., joins; Harrell and Greene, JJ., join in Parts I and II only. Concurring Opinion by Wilner, J. Concurring Opinion by Harrell and Greene, JJ. Filed: March 26, 2007 *Wilner, J., now retired, participated in the hearing and conference of this case while an active member of this Court; after being recalled pursuant to the Constitution, Article IV, Section 3A, he also participated in the decision and adoption of this opinion. This case is the first of two pertaining to the eligibility requireme nts of a can didate for the office of the Attorney General of Maryland.1 The genesis of this case was the attempt by Mr. Thomas E. Perez ( Perez ), an attorney and law professor, one of the appellees, to run for the office of the Att orney General of M aryland in the 2006 Gu bernatorial Primary Election. Article V, Section 4 of the Maryland Constitution prescribes the qualifications for that office. It provides: No person sh all be eligible to th e office o f Attorney-G eneral, wh o is not a citizen of this State, an d a qualified voter therein, and has not resided and practiced Law in this S tate for at least ten years. MD CON ST. art. V, § 4 (emphasis added). Today, we address whether a combination of membe rship in the Maryland Bar for five years, fewer than the ten years prescribed, and the practice of law for more than ten years, much of it being done at the federal level, suffices to meet the constitutional requirements of Article V, Section 4.2 In analyzing past and present bar admission requirements of this State, the historical role of the Atto rney Gener al, and other Constitutional provisions which were in existence at the time of Article V, Section 4's adoption, w e shall hold that a candidate for the office of the Attorney General must be a member of the Maryland Bar for at least ten years and must be a practitioner of law in Maryland for an identical requisite period. 1 The second case pertaining to the eligibility requirements of a candidate for the office of the Attorney General is Liddy v. Lamone, __ Md. __, __A .2d __ (2007). 2 There is no dis pute tha t Perez is a citize n of this State a nd a q ualified voter, who ha s resided...in this State for at lea st ten years. Th e only issue be fore us is wheth er Pere z has p racticed Law i n this Sta te for at le ast ten yea rs. I. Perez announced his candidacy for the office of the Attorney G eneral on May 23, 2006. Before doing so, recogn izing that there was a po tential question as to his eligi bility, i.e. the sufficiency of his professional credentials, to s erve as A ttorney Gene ral, in a letter dated May 8, 200 6 and in th e continue d spirit of thor oughne ss and due diligence...as to whether [he] met the eligibility requirements of [Article V,] Section 4 of the Maryland Cons titution, 3 he requested an advisory opinion fro m the off ice of the A ttorney Gene ral.4 In that letter, Perez related his career, as follows. After graduating from H arvard Law School in 1987, Perez was admitted to the New York Bar in 1988 and clerked for a federal judge in C olorado u ntil 1989. H e moved to Maryland after the clerkship and accepted a position with the United States Department of Justice ( DOJ ), through its Attorney General s Honors Program. He remained in that position , perfor ming v arious f unction s within the De partme nt, until 1 999. In his first position, as a federal prosecutor in the Criminal Section of the Civil R ights Division, which he held from 1989 to 1994, and which w as based in the District of Columb ia headquarters of the Department, Perez investigated and prosecuted criminal civil rights 3 Perez s letter to the office of the A ttorney General, and the A ttorney General s subseq uent op inion, w hich rela ted to its o wn of fice, rais e a pote ntial con flict of in terest. This issue, h oweve r, has not bee n presented and, theref ore, we w ill not address it. 4 Perez later filed an affidavit, dated July 25, 2006, with the Circuit Court for Anne Arundel County in which he reiterated his professional qualifications for the office of the Attorney G eneral. 2 cases nationwide. In that capacity, he was responsible for directing the investigation of the case, discussing the matter with the local Assistant United States Attorney, FBI agent or other investigator, making a determination of whether a case merited prosecution, and then prosecuting the case, if [it] merited prosecution. Some of the cases on his do cket were Marylan d cases . In 1994, Perez was promoted to the Deputy Chief of the Section. His responsibilities in that position in cluded su pervising a ll cases that occurred in Maryland. This requ ired him to consult with any attorney in the Section desiring to pursue an investigation or prosecution in Maryland[.] He also reviewed briefs and discussed strategies with the attorneys he supervised. In 1995, while remaining a DOJ e mployee, Pe rez was d etailed from the Civil R ights Division to the minority staff of the Senate Judiciary Committee on a fluctuating basis, i.e. he worked in both positions, staying, on an altern ating basis, a f ew mo nths in each . While with the Judiciary Committee, Perez worked on various bills that had widespread impact in areas such as juvenile crime, immigration, and civil rights. In 1998, Perez was appointed the Dep uty Assistant A ttorney Gene ral for the C ivil Rights Division, one of the four highest ranking positions in the Division. In that position, he oversaw the Criminal, Education, and Employment Sections, which entailed roughly 30% of all litigatio n activitie s within the Div ision. Several of the cases had a geographic anchor in Maryland. 3 In 1999, Perez left the Justice Department and became the Director of the Office for Civil Rights at the U.S. Department of Health and Human Services. In that capacity, Perez led a 220 per son agen cy whose m ission was to enforce civil rights laws in the health and human service context across the co untry, acting as a legal strategist, case supervisor, manager, and policy maker. His nationwide caseload included cases from Maryland involving Title VI of the Civil Rights Act of 1964 and the Americans with Disabilities Act of 1990. None of the Maryland cases involved litigation. Perez left federal service in January, 200 1. He joine d the facu lty of the Univ ersity of Maryland School of Law as an Assistant Professor of Law and Director of Clinical Law Programs in April 2001. Also in that year, Perez took the Maryland lawyer s bar examination and was admitted to practice in Maryland.5 As Director of Clinical Law Programs, Perez supervised students who handled real cases and we re permitted to appear in court pursu ant to Ma ryland s studen t practice rule (Rule 16). 6 He supervised those programs from 2001 until 2003. 5 Rule 13(d) of the Rules Governing Admission to the Bar of Maryland, which requires prior practice experience for a total of ten years, or at least five of the ten years immediately prior to the filing of the [admission] petition, governs who is eligible to take the lawyer s examination. 6 Rule 16 of the Rules Governing Admission to the Bar of Maryland (2007) provides, as relevant: Legal assis tance by law students. *** (b) Eligibility. A law student enrolled in a clinical program is eligible to engage in the practice of law as provided in this Rule if the student: (1) is enrolled in a law sch ool; 4 When, in 2003, Perez was elected to the Montgomery County Council , he resigned his position of Clinic Dire ctor, althoug h he rema ined a me mber of th e faculty. Perez recently was promoted from Assistant Professor of Law to Associate Professor of Law. Based on the information provided by Perez,7 the Attorney General, on May 19, 2006, issued an opinion, 91 Opinions of the Atto rney G eneral 99 (2006), concluding that Perez was qualified to hold the office of the Attorney General. Attorney General Curran reasoned: While the State Co nstitution explicitly requires that a candidate for Attorney General have practiced law in the State for 10 years and implicitly requires th at the candid ate be adm itted to the State bar, it neither explicitly nor implicitly requires that a candidate have accum ulated a ll of that e xperien ce wh ile a me mber o f the Sta te bar. Practice in Maryland authorized by federal and State law counts toward the durational experience requirement in the Maryland Constitution, even (2) has read and is familiar with the Maryland Lawyers' Rules of Professional Conduct and the relevant Maryland Rules of Procedure; and (3) has been certified in accordance with section (c) of this Rule. *** (d) Practice. In connection with a clinical program, a law student for whom a certificate is in ef fect may app ear in any trial cou rt or the Cou rt of Specia l Appeals or otherwise engage in the practice of law in Maryland provided that the supervising attorney (1) is satisfied that the student is competent to perform the duties assigned, (2) assumes responsibility for the quality of the student's work, (3) directs and assists the stud ent to the e xten t nec essa ry, in th e sup ervising attor ney's professional judgment, to ensure that the student's participation is effective on behalf of the client the student represents, and (4) accompanies the student when the student appears in court or before an administrative agency. The law student shall neither ask for nor receive personal compensation of any kind for service render ed und er this R ule. 7 Attorney General Curran cautioned, [b]ecause an Attorney General opinion is not a vehicle for investigating or determining facts, we base our analysis solely on the inform ation tha t you [Pe rez] hav e provi ded ab out your b ackgro und. 91 Opinions of the Attorney General at 100, n.1. 5 if that work was performed while the attorney was not a member of the M aryland b ar. Id. at 116. Relying on this opin ion, Perez, as we have seen, announced his candidacy for the office of the Attorney General and, on June 19, 2006, for mally registered his candida cy with the State Board of Elections ( the State Board ). By filing, pursuant to § 5-301(a)(1)8 of the Election Law Article, a certificate of candidacy, he certified, under oath,9 that, among other things, he was a registered voter and a citizen of Maryland and [met] all other [constitutional] requirements fo r the...office [of the Attorney Ge neral]. The State Boa rd accepted Perez s certificate and, pursuant to § 5-601(1)10 of the Election Law Article, placed 8 Maryland C ode (200 3, 2006 C um. Sup p.) § 5-301 (a) of the E lection Law Article provides: In general (a) In general. An individ ual may beco me a can didate for a public or pa rty office only if: (1) the individu al files a certifica te of cand idacy in accordan ce with this s ubtitle; and (2) the individual does not file a certificate of withdrawal under Subtitle 5 of this title. (Emph asis added). 9 See Maryland Code (2003, 2006 Cum. Supp.) § 5-302(a) of the Election Law Article, which provides: On form (a) A certificate of candidacy shall be filed under oath on the prescribed form. 10 Maryland C ode (200 3, 2006 C um. Sup p.) § 5-601 (a) of the E lection Law Article provides: The name of a candidate shall remain on the ballot and be submitted to the voters at a primary election if: (1) the can didate has f iled a certificate of candid acy in 6 his nam e on the ballot fo r the 20 06 Prim ary Electio n. On July 13, 2006, Mr. Stephen N. Abrams ( Abrams ), the appellan t, a registered voter in Maryland and a Republican candidate for the office of Comptroller of Maryland,11 filed, in the Circuit Court for Anne Arundel County, an action pursuant to §§9-209 (b)12 and accordance with the requirements of § 5-301 of this title and has satisfied any other requ irements of this article relating to the office which the individual is a candidate, provided the candidate: (i) has not w ithdrawn the candid acy in accordan ce with Su btitle 5 of this title; (ii) has not died or become disqualified, and that fact is known to the applicable board by the deadline prescribed in § 5-504(b) of this title; (iii) does not seek nomination by petition pursuant to the provisio ns of § 5-7 03 of this title; or (iv) is not a write-in candidate. 11 While the re was a c ontention th at Abram s did not ha ve standing to bring this action since he was a Repub lican candid ate for Co mptroller an d, thus, not elig ible to vote in the Democratic Primary Election, that issue was not raised during trial. We, therefore, decline to addr ess it. 12 Maryland C ode (200 3, 2006 C um. Sup p.) § 9-209 of the Elec tion Law Article provides: § 9-209. Judicial review Timing (a) Within 3 days after the con tent and arrangeme nt of the ballots are placed on public display und er § 9-207 of this subtitle, a registered voter may seek judicial review of the content and arrangement, or to correct any othe r erro r, by filing a sw orn p etitio n with the circ uit co urt for the cou nty. Relief that may be granted (b) The circuit court may require the local board to: (1) correct an error; (2) show cause why an error should not be corrected; or (3) take any other action requ ired to prov ide approp riate 7 12-202 (b)13 of the Election Law Article, seeking declaratory and injunctive relief against Perez, Ms. Linda H. Lamone ( Lamone ), in her official capacity as the State Administrator of Electio ns, and the State Board , collectiv ely, the ap pellees. 14 Abrams sought an order relief. Errors discovered after printing (c) If an error is discovered after the ballots have been printed, and the local board fails to correct the error, a registered voter may seek judicial review not later than the second Mon day prec eding th e electio n. (Emphasis add ed). 13 Maryland C ode (200 3, 2006 C um. Sup p.) § 12-20 2 of the E lection Law Article provides: § 12-202. Judicial challenges (a) In general. If no other tim ely and adeq uate reme dy is provided by this article, a registered voter may seek judicial relief from any act or omission relating to an election, whether or not the election has been held, on the grounds that the act or omission: (1) is incon sistent with this article or other la w applica ble to the elections process; and (2) may change or has changed the outcome of the election. Place and time of filing (b) A registered voter may seek judicial relief under this section in the appropriate circuit court within the earlier of: (1) 10 days after the act or omission or the date the act or omission became known to the petitioner; or (2) 7 days after the election results are certified, unless the election was a gub ernatorial primary or special primary election, in which case 3 d ays after the election results are certified. (Emphasis add ed). 14 In addition to his Complaint, Abrams filed, on the same date, a Motion for Tempo rary Restraining Order in a n attempt, on ce again, to p rohibit Lam one and th e State Board from placing Perez s name on the ballot. The Circuit Court for Anne Arundel County denied Abrams Motion for a Temporary Restraining Order, but believing that the Comp laint raised sub stantial and im portant issue s on the m erits, necessitating a full adversary he aring, entered an Orde r to Shorten Time to R espond, in which the defenda nts 8 declaring that Perez did not have the qualifications required for the office of the Attorney General, an injunction requiring Perez to withdraw his certificate of candidacy, and an injunction prohibiting Lamone and the State Board from placing Perez s name on the ballot for Attorney General. He argued that, under §5-301(b)15 of the Election Law Article, it was the State Board s duty to determine whether Perez met all of the qualifications prescribed by the election laws, including constitutional requireme nts as to his eligibility to run for, and, thus, to hold th e office o f the Attorn ey General. 16 were g iven fiv e 5 days to respon d to Ab rams C ompla int. 15 Maryland C ode (200 3, 2006 C um. Sup p.) § 5-301 (b) of the E lection Law Article provides: Determination by state board or local board (b) The appropriate board shall determine whether an individual filing a certificate of candidacy meets the requirements of this article, including: (1) the vote r registration an d party affiliation requireme nts under Subtitle 2 of this title; and (2) the cam paign fina nce reportin g requirem ents unde r Title 13 of this article. 16 Abrams, in his brief in this Court, asked: Does the State Board of Elections have any duty to inquire into the representations made by a candidate for any office in Maryland when the candidate certifies under oath to the State Board of Elections that he or she meets the Maryland Constitutional requirements? He did n ot further ad dress this po int at all in the brief, however. Instead, he focused primarily on the eligibility requirements of Article V, § 4 of the Maryland Constitution, arguing that Perez did not meet them. The appellant simply did not address in his brief the issue of the Board s duty to inquire into a candidate s qualifications for the office for which that can didate f iles. Ac cordin gly, we d ecline to addres s the issu e. See Oak Crest Village, Inc. v. Murphy, 379 M d. 229, 241 , 841 A.2d 816, 824 (2004) ( A n appellan t is required to a rticulate and a dequately arg ue all issues th e appellant d esires the app ellate court to consider in the app ellant s initial brief ); DiPino v . Davis, 354 Md. 18, 56, 729 A.2d 354, 374 (1999) ( [I]f a point germane to the appeal is not adequately raised in a 9 The appellees, d efendan ts below, responded by filing dispositive motions. Perez filed a Motion to Dismiss and/or Motion for Summary Judgment, principally on the ground that he met the qu alifications pre scribed by A rticle V, § 4 of the Maryland Constitution. Lamone and the State Board filed a Motion to Dismiss and to Expedite Scheduling. They contended that Abrams action was barred by the applicable statute of limitations and by laches and that party's brief, the [appellate] court may, and ordinarily should, decline to ad dress it ); Ritchie v. D onnelly, 324 M d. 344, 375 , 597 A.2d 432, 447 (1991) (ho lding an ap pellate court, in its discretion , need not consider[] the arguments that are not made in an appellant s b rief); Health Serv. Cost Rev. v. Lutheran Hosp., 298 Md. 651, 664, 472 A.2d 55, 61 (19 84) ( [A ] question n ot presented or argued in an appe llant's brief is not p roperly preserv ed for r eview ). See also Maryland R ule 8-504 (a) (5), whic h manda tes that: [a] brief shall comply with the requirements of Rule 8-112 and include the following items in the order listed: *** (5) A rgume nt in sup port of the party's p osition. In the Circuit Court, Abrams argued that whether Perez is qualified to run for the office of the Attorney General is a matter of statutory interpretation, rather than one for determination by administrative decision of the Attorney General. Relying on the Code of Maryland Regulations 33.01.02.01, Abrams further argued that Perez, as a person considerin g candida cy, should hav e petitioned th e State Bo ard, not the A ttorney Gene ral, to resolve any questions Perez may have had pertaining to his qualification for the office of the Attorney General. The Code of Maryland Regulations 33.01.02.01 provides: Petition Authorized An interested person may petition the State Board for a declaratory ruling on the manner in which the Board would apply any of the following to a person or property on the facts set forth in the petition: A. A Board regulation; B. A Board order; or C. A st atute tha t the Bo ard enf orces. The Circuit Court declined to address the issue of the propriety of the Attorney General s opinion stating that it is somewhat of a side issue...whether it should have happened or could have happened differently or whatever, this is not necessarily imputed by the Board. 10 their sole interest in the action was in ensuring an orderly administration of the election process, the deadlines of which would be jeopardized if the action were not adjudicated expeditiously. The Circuit Court held a hearing on the motions, at the conclusion of which it issued its oral op inion. The Circuit Court first addressed the issue of the timeliness of the appellant s action under § 12-202(b) of the Election Law Article.17 The court rejected the appellees argument that the relevant act or omission in the case sub judice was Pere z s filing of h is certificate of candid acy, whic h occu rred on June 1 9, 2006 , and their contention that the appellant should have known about that filing earlier. Instead, the Circuit Court concluded that the operative and critical date and, therefore, the relevant, statutory determinant was July 3, 2006, the filing deadline.18 It explained , to the extent that there may have been errors...[the 17 As mentioned earlier, the appellant s Complaint was also filed pursuant to § 9-209 (b) of the Election Law Article. The Circuit Court found that this ground did not apply, a finding that the appellant is not challenging. 18 The appellees, including Perez, who preferred to have the issue resolved on the merits, pressed their contention that A brams waited too lo ng to file this action under § 12-202, prompting a lengthy discussion in the Circuit Court on the point. They argued that Abrams should have known that Perez had filed to run for Attorney General. Citing, e.g., Could Technicality Boot Montgomery Official from Attorney General Race? Washin gton Post, M ay 7, 2006. at C 4; Perez OK d in Race for Attorney General, Baltimore Sun, M ay 20, 2006, a t 5B; AG Opinion Finds Perez Candidacy Constitutional, The Ga zette, May 19 , 2006; Perez is Eligible to Run for Attorney General, Washington Post, May 20, 2006, at B10, they noted that the occasion was highly publicized. The appellees further argued that Abrams had a duty to remain informed about the election, and he failed so to do. Moreover, they asserted, he should be precluded from claiming that he had no knowledge of what was transpiring merely because he was on vacation, particularly with te chnologic al advanc es, such as th e Internet, at his d isposal. Abrams cou ntered by testifying that he did not have perso nal knowledg e of Perez s 11 filing deadlin e] is sort o f the clo sing be ll, if you w ill.... There was, in the court s opinion, no other more reliable mea sure of the appellant s knowledge than the filing deadline itself, when the appellant would be charged with knowledge of Perez s candidacy. Because, the court ruled, th e appe llant s m otion w as filed on July 13 , 2006, within ten days of the filing deadline, it was within the period prescribed for filing for judicial review, and, therefore, time ly. The Circuit Court also was not persuaded by the laches argument advanced by Lamone and the State Board. Noting that laches would a pply if the claim ant neglecte d to formal filing until after he re turned fro m a three-w eek vaca tion and ch ecked the State Board s website on July, 5, 2006. He submitted that it was then that he knew that Perez had filed. Moreover, he claimed that no major newspaper in the area where he was vacationing reported that Perez had formally filed his certificate of candidacy and that the State Board s website was the best place for him to ascertain who was running. He contended, however, that he did not check the website until after the actual filing deadline because he w as not interested in finding ou t who may hav e been in the race as there was the possibility that candidates could withdraw at anytime before the close of the filing deadline. Abrams contended that he was only interested in the final list of candidates. We agree, on this point, with the appellees. Section 12-202 of the Election Law Article mu st be interprete d in a reason able, but pra ctical mann er. A reaso nable interpretation would place an obligation on a registered voter seeking to challenge the qualifications of a candidate to keep informed as to the relevant acts and omissions of that candidate. A voter may no t simply bury his or h er head in th e sand an d, thereby, avoid the triggering of the 10-d ay statutory time perio d, prescribed by §12-202 , in which to seek judicial review from any act or omission relating to an election. T he State Board s website, along with media coverage, would have been the principal places from which Abrams would have been able to find information pertaining to Perez s candidacy. It was incumbent upon Abrams to avail himself of these sources. Being on vacation is not an adequate, or even good, excuse for not being informed, as being on vacation did not bar him fro m utilizin g these source s to kee p infor med. 12 prosecute the matter in such a way that it cause[d] as a result of [the] passage of time...the adversary to be prejudiced, it was satisfied that the appellant was not, in any way, dilatory in his actions19 and, thus, that the State Boa rd was no t prejudiced . Accordin gly, the Circuit Court denied the motion to dismiss for laches. The Circuit Court, finally, addressed the constitutiona l issue of Pe rez s eligibility to hold the of fice of the A ttorney Gene ral, pursuant to Article V, § 4. Believing the question to be whether Perez has practiced Law in this State for at least ten years, more spec ifica lly: [d]o you h ave to be a Maryland B ar memb er for at least 1 0 years becau se only a Maryland B ar memb er can prac tice law in the State of M aryland?, the Circuit Court 19 On this point, the court opined: Now I certainly understand that...everything involving the electoral process is on a very very tight time line. And I recognize that every day that passes c reates the po tential for grea ter problem s and grea ter expense to the State Board. However, in large part those timing issues are not triggered by anything that Mr. Abrams did or didn t do in this case. I mean the fact of the matter is that there is just a whole lot of stuff that needs to get done and a relatively short tim e to do it...I think w ithin the con text of this case and given the complicated nature of the issues and so forth, what he did wa s certain ly within re ason. Neither Lamone nor the State Board filed a cross-appeal challenging these adverse rulings. T hus, the y are not b efore u s on this appea l. See Jose ph H . Mu nson Com pany, Inc. v. Secre tary of State, 294 Md. 160, 168, 448 A.2d 935, 940 (1982) ( [A party], not having filed an orde r of appeal, may not on ap peal attack the trial court s declaratory judgm ent ). See also Id., 448 A .2d at 93 9, citing Robeso n v. State, 285 Md. 498, 502, 403 A .2d 122 1, 1223 (1979 ), cert. denied, 444 U.S. 1021, 100 S. Ct. 680, 62 L. Ed. 2d 654 (1980) (holding an appellate court will address an issue sua sponte, even if not raised by the appellee, under the principle that a judgment will ordinarily be affirmed on any ground adequately shown by the record, whether or not relied on by the trial court or raised b y a party ). 13 answered, no. It reasoned, relying on Kenne dy v. Bar A ss n of M ontgom ery County, 316 Md. 646, 561 A .2d 200 (1989 ), Attorney Grievance Comm n v. Bridges, 360 Md. 489, 759 A.2d 233 (2000) and In the Matte r of R.G .S 312 Md. 626, 637, 541 A.2d 977, 982 (1988), that one can practice law in the State of Maryland without being a member of the Maryland Bar and that Perez s federal practice does, indeed, satisfy the practiced Law requirement under Article V , § 4. Kennedy, it stated, stood for the proposition that one can have essentially a federal p ractice in the S tate of M aryland even if [one] is no t a member of the Maryland Bar, while Bridges , citing, w ith appr oval, Sperry v. Florida, 373 U.S. 379, 83 S. Ct. 1322, 10 L. Ed. 2d 428 (1963), recognized an attorney s right to maintain a legal practice restricted to the federal c ourts prior to admission to that state s bar. Th e Circuit Court concluded, as to R.G.S.: I also find it significant that the Court of Appea ls in that case c ited with approval an Attorney General s opinion, 68 opinion.[20] And cited among other things the provision of that opinion that recognized that the phrase such as practice of law m ay mean dif ferent things in different contexts and specifically as used in A rticle 5, Section 4 of the Constitution relating to the qualifications for the O ffice o f the A G, the phrase... mean s somethin g quite different and less restricted than the meaning of the phrase practice of law for the pur pose o f Rule 14 or an y unauth orized p ractice. The Circuit Court also observe d tha t the plain lang uage [of Article V , § 4] says absolutely nothing about being a member of the bar because fra nkly that had a whole different import back in t hat d ay than it may have now. Recalling the history of bar 20 See 68 Opinions of the Attorney General 48 (1983). 14 admissions in Maryland, the Circuit Court noted that there was no formal, state-wide bar admission process until 1898,21 that, at the time, there was no federal law as we know it toda y, and despite the fact that the framers of the Maryland Constitution could not have contemplated a situation in which th e phrase p racticed La w in this Sta te could have meant something other than what they intended it to mean - the practice of state law in Maryland, the Circuit Court concluded: [T]he plain language...leads...to the inescapab le conclusion that it [the phrase practiced Law in this State for at least ten years ] simply requires that someone have practiced for at least ten years in the State of Maryland, but that [it is] not tantamount to being a member of the Maryland Bar...[and] that as a factual matter he [Perez] has practiced law. That as a legal matter that practice occurred in Maryland. And accordingly that under Section 4 of Article 5 of the Maryland Constitution he is eligible to stand for elec tion as A ttorney G eneral. 21 The curre nt procedu res for adm itting attorneys in this State have their origin in Chapter 1 39, 1898 Laws o f Maryland , the enactm ent of wh ich placed b ar admissio ns in this Court s exclusive jurisdiction. Chapter 139 provided: All applications for admission to the bar in this State shall be made by petition to the C ourt of A ppeals. A State Board o f Law Ex aminers is hereby created to consist of three members of the bar of at least ten years standing, who shall be appointed by the Court of Appeals, and shall hold office for the term of three years....All applications for admission to the bar shall be referred by the Court of Appeals to the State Boa rd of Law Examin ers, who sh all examine the applican t, touching his qualifications fo r admission to the bar. The said board shall report their proceedings in the examination of applicants to the Court of Ap peals with any recomm endations said board m ay desire to mak e. If the Court of Appeals shall then find the applicant to be qualified to discharge the duties of an attorney, and to be of good moral character and worthy to be admitted, they shall pass an order admitting h im to practice in all the courts of the State . Chapter 139, A cts of 1898 (ratified Ap ril 14, 1898) (emphasis ad ded). 15 The court thus granted Perez s Motion for Summary Judgment and denied the appellant s cross-motion. In response to that ruling, the appellant noted an appeal bo th to this Court, pursuant to § 12-203(a)22 of the Election Law Article, and to the Court of Special Appeals. In addition, h e filed, in this Co urt, a Petition for W rit of Certiora ri, which this Court granted . Abrams v. Lamone, 393 Md. 478, 903 A.2d 417 (2006). Oral argument was heard on Aug ust 25, 200 6, and, on th at same day, the Court issued its Order reversing the judgment of the C ircuit Court. We now set forth the reasons for that O rder. II. When the framers of the Maryland Constitution assembled in 1774 to formulate a response to the Bos ton Port A ct,23 they did not contemplate that just two short years later they 22 Maryland C ode (200 3, 2006 C um. Sup p.) § 12-20 3(a) of the E lection Law Article provides: (a) In general. A procee ding und er this subtitle sh all be cond ucted in accordan ce with the Maryland R ules, excep t that: (1) the proceeding sh all be heard and decid ed without a jury and as expeditiously as the circumstances require; (2) on the request of a party or sua sponte, the chief administrative judge of the circuit court may assign the case to a three-judge panel of circuit court judges; and (3) an appea l shall be taken directly to the Co urt of Ap peals within 5 d ays of the date of the dec ision of the c ircuit court. (Emphasis add ed). 23 The Boston Port Act, one of the measures variously called the Intolerable Acts, enacted b y the British Parlia ment on M arch 31, 17 74, was [a]n act to d iscontinue, in such manner, and for such time as are therein mentioned, the landing and discharging, lading or shipping, of go ods, wares, and m erchandise, at the town, an d within the harbou r, of Bosto n, in the prov ince of M assachuse t s, in North A merica. Its en actment w as in response to Boston protesters throwing 342 chests of tea over board into the Boston 16 would meet again, this time to produce a Constitution, a document that would govern the citizens of the S tate of M aryland. The office of the Attorney General24 was established by constitutional provision at the 1776 M aryland C onven tion. Section 48 of the 1776 Maryland Constitution provided , as relevant: That the governor, for the time being, w ith the advice and consent of the council, may appoint the chancellor, and all ju dges an d justice s, the attorney general, naval officers, officers in the regular land and sea service, officers of the militia, registers of the land office, surveyors, and all other civil officers of government...and may also suspend or remove any civil officer who has not a commission du ring good behav iour.... (Emphasis added). The office of the Attorney General was later abolished by Constitutional amendment25 Harbor during the Boston Tea Party. The protestors were billed for the tea that was destroyed, and the Harbo r was ultimately closed. 14 Ge o. III. c. 19 (1774). 24 Although the office was established here in Maryland in 1776, the office of the Attorney General, or the Attornatus Regis or King s Attorney, has its origins in English Law and dates back as far as the 13 th century, or perh aps even earlier as it is unc lear as to exactly w hen the office was o riginally sta rted. See generally, e.g., Hugh Bellot, The Origin of the Attorney-General, 25 L.Q . Rev. 4 00 (19 09); W .S. Hol dswo rth, The Ea rly History of the Attorney and Solicitor General, 13 Ill. L. R ev. 602 (1919 ). See also State v. Burning Tree Club, Inc., 301 M d. 9, 26-32, 4 81 A.2d 785, 794 -97 (1984 ); Murphy v. Yates, 276 M d. 475, 480 -88, 348 A .2d 837, 84 0-44 (197 5); Hawk ins v. State, 81 Md. 306, 32 A.2d 2 78 (18 95). 25 The mode of Constitutional amendment has changed over time. The original mode of amending the Constitution was that amendments were to be made by an Act of Assem bly passe d at one session and a c onfirm atory Ac t at the ne xt. See MD CONST. 1776 sec . 59. With the adoption o f the 1851 Constitution , all Constitution al amend ments were to be made by Conventions, which were elected for that purpose. The sense of the people w as taken ev ery ten years, follow ing the return s of every cen sus, in regard to calling a Conv ention f or alterin g the C onstitutio n. See MD CONST. 1850 art. XI. The process changed once again with the adoption of the 1864 Constitution, whereby amendments could be proposed by the General Assembly as long as three-fifths of all the membe rs elected to b oth house s agreed. T he sense o f the peop le was still take n, albeit 17 proposed in 1816, C hapter 247 , Acts of 1 816, and ra tified, February 5, 1817.26 It was reestablished in 1818, pursuant to Chapter 146, Acts of 1817.27 In 1821, the constitutional every tw enty years, in regard to calling a Con vention . See MD CON ST. 18 64 art. X I. The p rocess h as subs tantially rem ained th e same since its a doptio n in 186 4. See MD CON ST.18 67 art. X IV; M D CO NST . art. XIV . See also 1941 Laws of Maryland, ch. 337, rejected Nov. 3, 1942; 1943 Laws of Maryland, ch. 476, ratified Nov. 7, 1944; 1972 Laws of Maryland, ch. 367, ratified Nov. 7, 1972; 1977 Laws of Maryland, 679, ratified Nov. 7, 1978; 1978 Laws of Maryland, ch. 975, ratified Nov. 7, 1978. 26 Chapter 2 47 provid ed, as releva nt: An act to alter and ch ange all and every part of the C onstitution and Form of Go vernm ent as re lates to th e Attor ney Gen eral. Sec. 1. Be it enacted by the General Assembly of Maryland, That all and ever y part of the constitution and form of government of this state, w hich rela tes to the attorney g eneral, be and the sam e is hereby abro gated, ann ulled, and m ade void . 2. And be it enacted, That the duties and services, now provided by law to he done and performed by the attorney gen eral, shall be done and performed by such persons, and in such manner, as the general assembly of Maryland shall hereafter direct. Chapter 247, A cts of 1816 (ratified Feb . 5, 1817) (emphasis ad ded). 27 Chapter 1 46 provid ed, as releva nt: An act providing for the appointment of an Attorney General, and of District Attorneys, in the several Judicial Districts of this State, and for Baltimore City Court. Sec. 1. Be it enacted by the General Assembly of Maryland, That there shall be appointed and commissioned a person of sound legal knowledge, who shall be styled Attorney General of Maryland, and who, previous to and during his acting as such, shall res ide in the state, a nd who se duty it shall be to prosecute and defend, on the part of the state, all cases now depending, or which may hereafter be brought in, or removed to, the court of appeals for the Western or eastern shore, by or against the state, or wherein the state shall or may be interested, in the same manner that the attorney general 18 provision pertaini ng to th e Attor ney Gen eral wa s repea led and reenac ted. See Chapter 126, Acts of 182 1 (ratifie d Jan.7 , 1822). Although very similar to the previous provision pertaining to the office of the Attorney General, the amendment, as proposed and ratified, outlined the duties of the Attorney General in greater detail and provided for the appointment of deputies, providing: [T]he governor shall nominate, and by and with the advice and consent of the council, appoint and commission a person of sound legal knowled ge, who shall be styled attorney general of Maryland, and who previous to, and during his acting as such, shall reside in this state; and it shall be the duty of the said attorney general, to prosecute and defend on the part of the state, all cases now depending, or which may hereafter be brought in, or removed to any of the counties of this state by or against the state, or wherein the state shall or may be interested, in the same manner, as the attorney general heretofore was accustomed to do or could do; and he shall have, exercise and use all and every the powers a nd author ities in and relating to the same, as the attorney general heretofore had used and exercised, or can have, use and exercise in similar cases; and he shall give his opinion and advice whenever he shall be required by the genera l assembly, or eith er branch th ereof, by the g overnor a nd coun cil, or by the treasurer o f the Easte rn and Western Shore, or any deputy he may appoint, on any matter or subject depending before the m. (Em phasis added). heretofore was accu stomed to d o, or could d o; and he s hall have, exercise and use, all and every the powers and authorities in and rotating to the same, as the attorney general heretofore had, used and exercised, or can have, use and exercise, in similar cases, and he shall give his opinion and advice w henever he sh all be requ ired by the general a ssem bly, or either branch thereof, by the governor and council, or by the treasurer of either shore, on any matter or subject depending before them, or where the interest of the state may require . Chapter 146, A cts of 1817 (ratified Feb . 7, 1818) (emphasis ad ded). 19 That provision remained unchanged for the next 30 years, u ntil 1851, w hen, as a resu lt of the Constitutional Convention of 1850,28 the office of the Attorney General once again was abolished.29 According to Article V, § 3 of th e 1850 Con stitution, the Attorney General s duties were to b e discharged by the state s atto rney in eac h county a nd in Balt imore City. 30 It provided , as pertinent, that [t]he S tate s Attorne y shall perform the duties and receive such fees and com missions as are now prescribed by law for the Attorney Gen eral and his Deputies. The office of the Attorne y General was not reestab lished as part of the Maryland 28 Pursuant to Chapter 346, Acts of 1849, which was ratified February 21, 1850, the General Assembly proposed to Maryland voters the calling of a convention to frame a new constitution. The Act was entitled, An act to provide for the taking upon the expediency of calling a Convention to frame a new Constitution and Form of Government for this State, and to provide for the election of Delegates to such Convention. Maryland voters app roved the c onvention , and, in No vember 1 850, the elec ted delegate s met to frame a new Maryland Constitution. 29 Article III, § 32 of the 185 0 Maryland Constitution provided that [n]o law shall be passed creating the office of the Attorney General. MD. CONST . 1850 art. III, § 32. 30 There w as much deliberation a t the Cons titutional Con vention of 1850 as to whether the office of the Attorney General should be abolished. There were a number of reasons fo r the sugge stion; how ever, the m ain reason s eemed to have bee n due to financ ial circum stances . See Debates and P roceedings of the M aryland Reform Convention to Revise the State Constitution ( Debates I ), Vol. II, 9 (Annapolis, 1851) (Delegate Thomas Dorsey of Anne Arundel County suggested that it would be a great saving to the S tate, for e ach atto rney to tran sact the b usiness with w hich he was fa miliar. After he had prepared himself to argue a case in the county court, he would be prepared to argue it before the court of appeals. No compensation would therefore be required for these ex amina tion of th e same case by a nother attorney ). See also Debates I at Vol. I, 519-550 (providing a detailed discussion of the abolition of the office of the Attorney General). 20 Constitution until 1864 when, for the first time in Maryland history, it was made an elective office.31 Moreover, Article V of the 1864 Constitution, captioned, Attorney General and State s Attorney, provided a detailed statement of the duties of the office of the Attorney General, Article V, § 3, and, although prior provisions had required residency and, by implication, suggested that a candidate for Attorney General be skilled in the legal practice, as the duties included prosecuting and defending cases involving the State or in whic h the State had an interest, for the first time, the qualifications for the position were articulated.32 Article V, § 4 of the 1864 Constitution provided: No pers on sh all be eligi ble to the o ffic e of a ttorn ey general who has not resided and practiced law in this State for at least seven years next preceding his election. (Em phasis a dded). 31 Article V, § 1 of the 1864 Maryland Constitution provided: There sh all be an A ttorney Gene ral elected by the q ualified vo ters of the S tate, on general ticket, on the Tuesday next after the first Monday in the month of Novem ber, in the year eig hteen hun dred and sixty four, and o n the same day in every fourth year thereafter, who shall hold his office for four years from the first Monday of January next ensuing his election, and until his successor shall be elected and qualified, an d shall be re-e ligible thereto, an d shall be su bject to removal for incompetency, willful neglect of duty, or misdemeanor in office, on convic tion in a C ourt of Law. MD. CO NST. 1864 art. V, § 1 (emphasis ad ded). 32 Although the eligibility requirements for the Attorney General were first articulated in the 1864 Constitution, those pertaining to the State s Attorney and judicial candidates were already in place and could be found in its predecessor, the Constitution of 1850. The eligi bility r equirem ents for these othe r pos ition s we re, th us, clearl y, considered by the framers in their adoption of Article V, § 4. 21 The Maryland Constitution was revised once again, just three years later.33 Although the essence of Article V, § 4 remained the same, th e new p rovision ch anged the length of b oth the residency and p ractice of law requireme nts from se ven to ten year s, the length it has remained to this day. Article V, § 4 of the 1867 Constitution provided: No person shall be eligible to th e office o f Attorney-G eneral, wh o is not a citizen of this State , and a qualified voter therein, and has not resided and practiced Law in this State for at least ten years. MD . CON ST. 18 67 art. V , § 4 (em phasis a dded). III. The appellant asserts that the Circuit Court erred in applying a broad interpretation of Article V, § 4, to find Perez eligible to hold the office of the Attorney General. He first argues, as he did below, that, under the canons of constitutional interpretation there can be only 33 The 1867 Constitution is still Maryland s Constitution. Although it has been amended in some particulars, on the subject of the office of the Attorney General, it has remained unamended. That is not to say that it has, during this period, always been viewed as adequate. Believing the 1867 Constitution to be very restrictive to the successful operation of an efficient state government and entirely too clumsy and ineffective as a document of basic law, see Report of the Constitutional Convention Commission (Annap olis: Constitutio nal Conv ention Co mmission , 1967) at vii; See Rasin v. Leaverton, 181 Md. 91, 96, 28 A.2d 612, 614 (1942) ( [T]he constitution of 1867 does not always possess the con sistency that the argument suppo ses ), Governor J. M illard Tawes app ointed a comm ission to study the document in an effort to determine w hether a new co nstitution w as needed . The com mission pro posed tha t a conven tion be held in order to revise th e docu ment a s a wh ole, see Chap ter 500 , Acts o f 1996 . See also Chapter 4, Acts of 1967 (providing for the appointment and election of delegates), and in 1967, the fifth constitutional convention convened. The constitution resulting from the deliberations of that convention failed ratification in a referendum held on May 14, 1968, howe ver. 22 one reading of the phrase practiced Law in this State for at least ten years. That is so, the appellant submits, be cause the p hrase is clear a nd unam biguous; in order to be eligible to practice Law in this State, one necessarily must be admitted to the bar of the State. In sum, the appellant argues that Perez could not have been practicing law in Maryland when he was not admitted to its b ar, because to have done so, he would have had to, in effect, engage in the unauthorized practice of law. The appellant, moreover, contends that the phrase should not only be given its plain, ordinary meaning but should not be liberally construed to mean anything else. The appellant next argues, alternatively, that, if Article V, § 4 is ambiguo us, resort to its legislative histo ry supports his c ontention th at the frame rs intended the office to be held by a person admitted to the bar of the State. The historical role of the A ttorney Gene ral, coupled with essen tial principles of bar admission in this State, confirm his position, he proffers. He asserts, further, that the 1867 Constitution, with its enumeration of the prerequisites for holding the office of the Attorne y General, w as clearly unde rstood to pe rtain to a person admitted to practice in Maryland and, when considered in connection with the duties of the office it prescribes, to one who, due to experience, was competent to hold the office. Thus, he concludes, Article V, § 3,34 which o utlined the d uties of the A ttorney Gene ral, 34 As originally adopted, Article V, Section 3 of the Maryland Constitution governed the duties of the Attorney General and provided: It shall be the duty of the Attorney General to prosecute and defend, on the part of the State, all cases which at the time of his election and qualification, and which thereafter may be depending in the Court of Appea ls, or in the Supreme Court of the United States, by or against the 23 was explicit in its requirement that the Attorney General had to discharge all of the duties prescribed therein personally. It is logical, then, the appellant argues, that the General Assemb ly contemplated that the Attorney General be a member of the Maryland Bar, as such State, or wherein the State may be interested; and he shall give his opinion in writing whenever required by the General Assembly, or either branch thereof; the G overnor ; the C omp trolle r; the Trea sure r; or a ny Sta te's Attorney on any matter or subject depending before them; or either of them, and wh en required by the Gov ernor or the General A ssembly, he sh all aid any State's Attorney in prosecuting any suit, or action brought by the State, in any Court of this State; and he shall commence and prosecute or defend any suit, or action, in any of said Courts, on the part of the State, which the General Assembly or the Governor acting according to law, shall direct to be commenced, prosecuted, or defended, and he shall receive for his services an annual salary of twenty-five hundred dollars; but he shall not be entitled to receive any fees, perquisites, or rewards, whatever, in addition on to the sa lary afore said, fo r the per forma nce of any offic ial duty, nor have pow er to appoint any ag ent, r epre sentative , or deputy, und er an y circumstances whatever. MD. CO NST. 1864 art. V, § 3 (emphasis ad ded). As the office of the Attorney General evolved and expanded, it became evident that the Attorney General could not attend to all of the State s legal affairs personally, as originally contemplated and required by the position. Consequently, the Constitution was amen ded to a ddress the issue . See Chapter 663, Laws of Maryland 1912. The provision, as proposed to the voters, and ratified, in pertinent part, provided: It shall be the duty of the Attorney-General to prosecute and defend on the part of the State all cases, which at the time of his appointment and qualification and which thereafter may be depending in the Court of Appeals, or in the Supreme Court of the United States, by or against the State, or wherein the State may be interested; and he shall give his opinion in writing whenever required by the General Assembly or either branch thereof, the G overnor , the C omp trolle r of the T reas ury, or any S tate's Attorney, on any legal matter or subject depending before them or either of them; and when re quired by the G overnor o r Genera l Assemb ly he shall aid any State's Attorn ey in prosecutin g any suit or actio n brough t by the State in any Court of the State, and he shall commence and prosecute or defend any suit or action in any of said Courts, on the part of the State, which the General A ssembly or the Govern or, acting acc ording to law , shall direct to be commenced, prosecuted or defended, and he shall have and perform such other duties and shall appoint such number of deputies or assistants as the General Assem bly may from time to time by law presc ribe[.] Chapter 663, A cts of 1912 (ratified No vember 8, 1913 ) (emphasis added ). 24 membership would have permitted him to appear in the courts of the State. Moreover, the appellant argues that the framers of the Cons titution were precise in their choice of lang uage. Looking at other provisions of the C onstitutio n, i.e. Article V, § 10 and Article IV, § 2, pertaining respectively to the eligibility requirements for State s Attorney and judicial candidates, he emphasizes the difference in the language of the p rovision s. In both latter instances, the provision specifies expressly bar membership as a prerequisite to running for, and holding, the office. In the case of the office of the Attorney General, however, instead of an express reference to bar membership, the provision specifies the practice of law in th is State for a specif ied period o f time. This, th e appellant says, supports his position. The framers, he asserts, did not omit a bar admission requirement at all; rather, they understood that such a requirement necessarily is subsumed in the phrase, practiced Law. Fina lly, the appellant denies that P erez s fe dera l bar mem bers hip, a nd, u ltima tely, his practice of law as an official in the Justice Department and a member of the Maryland federal bar, even if do ne physically in Maryland, meet the eligibility requirements of Article V, § 4 and, therefore, makes him eligible to be Maryland s Attorney General. Federal and state bar memberships are two very distin ct privile ges, he p osits. Thus, the appellant urges that Perez can not be said to have prac ticed law in Maryland, within the contemplation of the constitutional provision, at least not until he becam e a member o f the Maryland Ba r in 2001. In sum, it is the ap pellant s pos ition that being a Justice D epartmen t official auth orized to protect the interests of the United States throughout the country and, in that capacity and for 25 that purpose, to appear in the state courts of Maryland, or being a member of the bar of the United States District Court for the District of Maryland does not authorize an individual not admitted to the bar of the Court o f Appe als of M aryland to prac tice law in Maryland in the sense in tended by Article V, § 4, th e Supr emacy C lause n otwith standin g. IV. A. Although Article V, § 4 has been considered in other contexts,35 the disputed question presented for our resolution, the meaning of practiced Law in this State for at least ten years has no t been d ecided previously by this C ourt. The general tenets of constitutional interpretation are well settled and frequently stated. Genera lly speaking, the same ru les that are applicable to the construction of statutory language are employed in interpreting constitutional verbiage[.] Brown v. Brown, 287 Md. 273, 277, 41 2 A.2d 396, 39 8 (198 0). See also Davis v. Slater, 383 Md. 599, 604, 861 A.2d 78, 81 (2004) ( When interpreting constitutional provisions, we generally employ the same rules of construction that are applicable to the constru ction of statu tory language ); Fish Market Nom inee C orp v. G .A.A., Inc., 337 Md . 1, 8, 650 A.2d 705, 70 8 (19 94) ( Ge nera lly, we apply the same principles in construing constitutional provisions as we apply in construing 35 See, e.g., Crosse v. Board of Supervisors of Elections, 243 Md. 555, 561, 221 A.2d 431, 435 (1966) (briefly observing that the Attorney General must be a qualified voter ); 68 Opinions of the Attorney General 342 (1983) (discussing the at least ten years timing aspect of the eligibility requirement); 68 Opinions of the Attorney General 48 (discussing the practice o f law aspect of the eligibility requirement). 26 statutory provisions ); New Central Coal Co. v. George s Creek Coal & Iron Co., 37 Md. 537, 557 (1873) ( There can be no good reason suggested why this same general principle [for the construction of statutes], so wise and just, should not also apply as a rule of interpretation of the Constitution ). We stated the general rule in Brown: [I]t is axiomatic that the words used in the enactment should be given the construction that effectuate s the intent of its framers...suc h intent is first sought from the terminology used in the provision, with each word being given its ordinary and popularly understood meaning...and, if th e word s are no t ambig uous, th e inquir y is termina ted.... 287 Md. at 277-78, 412 A.2d at 398-99 (citations omitted and emphasis added). See also Davis, 383 Md. 599 at 604, 861 A.2d 78 at 81 ( [T ]o ascertain the meaning of a constitutional provision...we first look to the normal, pla in meanin g of the lan guage ); Fish Market Nominee Corp., 337 Md. 1 at 8, 650 A.2d 705 at 708 ( [W]e generally constru e the provis ion to effectuate the clear meaning expressed by its words ) ; Rand v. Rand, 280 Md. 508, 511, 374 A.2d 900, 902 (1977) ( To ascertain the mandate of a constitutional [provision], we look first to the natural and ord inary sign ification of its lan guage ), quoting Balto. Gas & Elect. Co. v. Board o f Coun ty Comm rs of Calve rt County, 278 Md. 26, 31, 358 A.2d, 24 1, 244 (1976). We have further stated that [w]here the words of an [enactment], construed according to their common and eve ryday meaning , are clear and unambig uous and express a p lain mean ing, [the Cou rt] will give effect to the [enactment] as it is written. Moore v. Miley, 372 Md. 6 63, 677 , 814 A .2d 557 , 566 (2 003), quoting Jones v. Sta te, 336 Md. 255, 261, 647 A.2d 1204, 1 206-0 7. See also Bienkowski v. Brooks, 386 Md. 516, 536, 873 A.2d 1122, 1135 27 (2005) ( If th[e] language is clear and unamb iguous, we need not look beyond the pro vision s terms.... ), quoting Davis, 383 Md. at 604-05, 861 A.2d at 81; Arunde l Corp. v. M arie, 383 Md. 489, 502, 860 A .2d 886, 894 (200 4) ( If there is no ambiguity...the inquiry as to legislative intent ends; we do not then need to resort to the various, and sometimes inconsistent, external rules of construction ). Thus, [a] court may neither add nor delete language so as to reflect an intent not evidenced in the plain and unambiguous language of the statute; nor may it construe the statute with forced or subtle interpretations that limit or ex tend its a pplicatio n. Price v. State, 378 M d. 378, 3 87, 835 A.2d 1 221, 12 26 (20 03). See also Condon v. State of Maryland- University of Maryland, 332 Md. 481, 491, 632 A.2d 753, 758 (1993) ( [w]here the language is cle ar an d unamb iguo us, a court ma y not add or delete w ords to ma ke a statute reflect an intent not evidenced in that language,...[a] clearly worded statute must be construed without forced or subtle interpretations that limit or extend its application ), quoting Tucker v. Fireman s Fund Ins. Co., 308 Md. 69, 73 , 517 A.2d 730 , 732 (1986) (citations om itted). We, thus, begin o ur analysis by look ing at the plain language of Article V , § 4 to determine what it means to have practiced law in this State for at least ten years. Although this Court has generally refused to adopt a precise definition of the term practice law, see In re Application of Mark W., 303 Md. 1, 6-9, 491 A.2d 576, 578-81 (1985) ( recognizing that in determining whether a state bar applicant's activities constitute the practice of law ... the more practical app roach is to co nsider each state of facts and d etermine w hether it falls w ithin the fair intendment of the term ), quoting Grievance Committee v. Payne, 22 A.2d 623, 625 28 (Conn. 1941), we read practiced law in this State for at least ten years, a s used in A rticle V, § 4, to mean that one who seeks to hold the offic e of the Attorney General must have practice d law f or ten yea rs, in M aryland, a s a mem ber of th e Mar yland Ba r. The practice requ irement, we hold, relates not solely to the practice of law in Maryland, but to its practice in Maryland as a member of the Maryland Bar. This is consistent with the context within w hich [the lan guage of this constitutional provision] was adopted, Motor Vehicle Adm inistratio n v. M oher, 318 Md. 2 19, 225 , 567 A .2d 929 , 932 (1 990), quoting Rucker v. Comptroller of T reasury, 315 Md. 559, 565, 555 A.2d 1060, 1063 (1989), and comes from reading it as a w hole. Kushell v . Dep t of N atural Resources, 385 Md. 563, 577, 870 A.2d, 186, 193 (2005) ( The plain language of a [constitutional] provision is not interpreted in isolation. Ra ther, [the Co urt] analyze[s] th e provision as a who le ); Blondell v. Baltimore City Police Dep t, 341 Md. 680 , 691, 672 A.2d 6 39, 645 (1996) (no ting that the Court construes a constitution al provision as a who le, interpreting each part o f the provis ion in context); Outmezguine v. State, 335 Md. 20, 41, 641 A.2d 870, 880-81 (1994) (asserting that a constitutiona l provision can not be viewed in isolation, but rather must be analyzed as a whole); Wheele r v. State, 281 Md. 593, 596, 380 A.2d 1052, 1055 (1977) ( All parts of a [cons titutiona l provisi on] are to be rea d togeth er to fin d the inte ntion as to any on e part ) . Moreover, we decline to give the provision, and specifically the phr ase at iss ue, a different meaning on such theo ries that a diffe rent mean ing wou ld make [it] more workable, or more consistent with a litigant s view of good public policy, or more in tune with mode rn 29 times, or [on the theory] that the framers of the provision did not actually mean what they wrote. Bienkowski, 386 Md. at 537, 873 A.2d at 1134. See, e.g., Montrose Christian School v. Walsh, 363 Md. 565, 595, 770 A.2d 111, 129 (2001) (The phrase...clearly does not mean what is suggested....We decline to construe purely as if it were primarily or some ); Davis v. State, 294 Md. 370, 378, 451 A.2d 107, 111 (1982) (refusin g to constru e the phrase his religious beliefs in f avor of the petitioner s vie w, as such an action w ould be tan tamount to re-drafting the statute under the guise of construction ); Mauzy v. Hornbeck, 285 Md. 84, 93, 400 A.2d 1091, 1096 (1979) (declining to construe the phrase all professional employees as only certain types of professional em ployees). On this poin t, we ag ree with the app ellant. There can be no meaning attached to this phrase, as used in th e context of Article V, § 4, other than that practicing law in Maryland requires admission to the bar of this State. The practice of law in Maryland and Maryland bar admission are cote rminou s; one f ollows from a nd, inde ed, is de pende nt on th e other. This has long been the c ase in this State. The first formal bar admission in Maryland took place in 1666 when William Calvert, Daniel Jenifer, and John Morecroft were accepted to practice by the Provincial Court. That court, formed in 1637 an d consisting of the Go vernor an d his coun cil, was the highest c ourt of com mon law in the colon y, having both original and appellate jurisdiction. See, e.g., J. Hall Pleasants, Ed. Early Maryland County Courts Proceedings of the County Court of Charles County, 1658-1666 (Baltimore, 1936) at xliii ( In the Provincial Court, beginning in the sixties, are to be found a few sworn attorneys of the court, men 30 trained in their profession, who were formally admitted to practice, and enrolled as such in the court record s). See generally Act of April, 1 715, ch . 48, §§ 1 2, 13 (M axcy ed., vol. 1, p. 132 (1811) w hich prov ided, as relev ant: A ND BE IT FURTHER ENACTED, by the authority advice and consent aforesaid , That from and after the end of this presen t session of asse mbly, no attor ney, or other perso n whatso ever, shall pra ctise the law in any of the c ourts of this provinc e, without b eing admitted thereto by the justices of the several courts, who are hereby empowered to admit and suspend them (salvo jure coronae) until his majesty s pleasure shall be known therein...P ROVIDED ALWAYS, That noth ing in this act sh all extend, or b e construed to extend, to give right to any courts of this province to admit any attorney, or other person practising the law, to practise in any court that has been already refused so to do by his excellency, and his majesty s honoura ble council.... (Emphasis add ed). This State has had formal state-wide bar admission requirements dating back to the early 19 th century. O n Ma rch 10, 1 833, the Gen eral Assembly enacted Laws of Maryland, Chapter 268 entitled An act regulating the admission of Attorneys to practice law in the several Co urts of this state . Chapter 268 prov ided, as relev ant: WHEREAS, under the e xisting laws of this state, it is in the power of the several courts of law and equity, to regulate the admission of attorneys according to their discretion, by which different rules prevail in dif ferent cou rts; and it is proper and right, that the mode and terms of admission should b e uniform throug hout th is state: T herefo re, Section 1. Be it enac ted by the Ge neral Asse mbly of M aryland, That a ll applications for admission as attorney, to practice the law in this state, shall be made to some one of the county courts, courts of e quity or courts o f appeals thereof in open cou rt. Sec. 2. And b e it enacted, T hat upon e very such ap plication for admission to practice law as af ores aid...it shall be the d uty of the court to whom such application shall be made, to examine said applicant upon some day during the regular session thereof, touc hing his q ualif ication for ad miss ion a s an a ttorn ey, and they shall also require and receive evidence of his probity and general character, and if upon such actual examination, and being satisfied that he has 31 been a student of law, at least two years as aforesaid, and having heard evidence as to his probity and general character, the said court shall be of opinion tha t said applicant is qualified to discharge the duties of an attorney and worthy to be admitte d, they sha ll admit h im. Sec. 3. And be it enacted, That upon the admission of any applicant to practice law in any of the courts of record in this state as aforesaid, it shall be the duty of the court so ad mitting him , to certify the same with their own proper signatures, which certificate shall be recorded, and a copy thereof authenticated with the county seal of the c ounty in wh ich the party sha ll be admitted , shall be available and sufficient to entitle said applicant so admitted, to practice in any of the courts of th is state. Chapter 268, A cts of 1831 (ratified M arch 10, 1833) (em phasis added). 36 36 Chapter 2 68 of the 1 831 Law s of Ma ryland was late r amende d to prohib it explicitly the practice of law by persons not admitted to the bar and codified in the Maryland C ode of P ublic Law s, article XI, § 1 (1860), w hich prov ided, in pertine nt part: SEC. 1. No attorney or other person shall practice the law in any of the courts of this State without being admitted thereto a s herein directed . 2. All applications for admission as attorney to practice the law in this State shall be made to some one of the Circuit Courts for the counties, the Superior Court of Baltimo re city, the Circuit Court for Baltimore city, or to the Court of A ppeals, in open court. (Emphasis adde d). In 1888, this provision was moved from Article XI, § 1 to Article X, § 1 of the Code , where it remain ed until 1 989. See generally, 1892 L aws of Ma ryland, ch . 37.; 1898 Laws of Maryland, ch. 139; 1902 Laws of Maryland, ch. 399; 1904 Laws of Maryland, art. 10, sec. 3; 1916 Laws of Maryland, ch. 509, sec. 3; 1918 Laws of Maryland, ch. 426, sec. 3. In 1989, Article X, § 1 was repealed and reenacted, in substantive part, as §§10206 an d 10-6 01 of th e Busin ess Oc cupatio ns and Profe ssions A rticle. See 1989 Laws of Marylan d, ch. 3, § 1; ch. 23 6, § 1; ch . 631, § 2 ; ch. 632 , § 3. Maryland Code (1989, Repl. Vol. 2004, 2006 Cum. Supp.) § 10-206 of the Business Occup ations and P rofessions Article prov ides, as releva nt: § 10-2 06. Admission required; exceptions. (a) In general. Excep t as othe rwise p rovide d by law , before an individual may practice la w in the S tate, the individ ual shall: (1) be admitted to the Bar; and (2) meet any requirement that the Court of Appeals may set by rule. (Emphasis added ). 32 Bar membership, thus, has been, and remains, a threshold requirement for the authorized practice of law in Maryland. Although, the process by which one is admitted to the Bar has changed over time,37 the requirement of bar membership never has. Accordingly, beginning with its adoption in 1864, and continuing to today, the phrase practiced Law in this State has required that a person seeking to practice law in Maryland lawfully be admitted to the Maryland Bar. We , thus, reject the C ircuit Court s ratio nale that it was not until 1898 that any uniform standards for bar admissions existed, and, accordingly, when the 1867 Constitution was adopted, the framers could not have intended that an individual who was not admitted to the bar co uld hold the office of the Attorne y General. We also reject Perez s argum ent that this C ourt should construe th e eligibility requireme nts for a candidate seeking to hold the office of the Atto rney Gener al liberally merely because Article V, § 4 of the Maryland Constitution does not expressly requ ire that a cand idate for that office be admitted to or be a member of the Maryland Bar. In sup port of his argument, Perez relies on authority from other jurisdictions. See Kelly v. Cuyah oga Co unty See also § 10-601of the Business Occupations and Professions Article and Maryland Lawye rs Rule s of Pro fession al Con duct 5.5 , infra n. 39, at 39. 37 See Chap ter 268 , Acts o f 1831 , supra at 31-32 (ap plications fo r admission ...shall be made to some o ne of the c ounty courts, co urts of equ ity or courts of ap peals thereo f in open court); n. 36, at 32 (applications for admission...shall be made to some one of the Circuit Courts for the counties, the Superior Court of Baltimore city, the Circuit Court for Baltimore city, or to the Court of A ppeals, in open court). Presently, in order for an individual to be admitted to the bar of the State of Maryland, h e or she m ust take an e xaminatio n and mu st be certified b y this Court. See generally, Rules Governing Admission to the Bar of Maryland, Rules 2 through 7; Section 10-207 of the Business Occupations and Professions Article. 33 Board of Elections, 639 N.E.2d 78, 79 (Ohio 1994) ( Words limiting the right of a person to hold office are to be given a liberal constru ction in fav or of those seeking to h old office , in order that the public may have the benefit of choice from all those who are in fact and in law qualified ), quoting Schenck v. Shattuck, 439 N.E .2d 891, 89 3 (Ohio. 1 982); Sears v. Bayoud, 786 S.W.2d 248, 251 (Tex. 1990) ( We have repeatedly recognized the principle that constitutional provisions which restrict the right to ho ld public office should b e strictly construed against ineligibility ). See also 91 Opinions of the Attorney General at 103 (stating that lang uage sh ould be resolve d in fav or of eli gibility). This Court i s not pe rsuade d that a lib eral con struction of Art icle V, § 4 is appropriate. Indeed, we have construed eligibility requirements strictly, where the language of the constitu tional pr ovision is clear. In Oglesby v. Williams, 372 Md. 360, 812 A.2d 1061 (2002), for example, we held that a candidate for State s Attorney did not meet the residency requirement prescribed by Article V, § 10 of the Maryland Constitution. That provision required that a candidate for State s Attorney have resided for at least two years, in the county, or city, in w hich he may be e lected. MD CON ST. art. V , § 10. In concluding that the candidate had resided in W orcester County for less than the constitutionally prescribed residency period , approx imately on e year and eleven month s, this Court rejected Mr. Og lesby s argument that his intent sho uld be the d etermining factor. W e instead ap plied the plain meaning of the constitutional language itself. We were clear in our holding, moreover, that [t]he words reside or resident mean domicile unless a contrary intent is shown, 372 Md. at 34 373, 812 A .2d at 10 68, quoting Roberts v . Lakin, 340 Md. 147, 153, 665 A.2d 1024, 1027 (1995), giving a strict interpretation to the terms, reside and dom iciled, as it pertain ed to the residency requirement. Similarly, in the case sub judice, we shall interpret the phrase, practiced Law, consistent with its plain meaning; we refuse to interpret it otherwise as there is no semblance of any contrary intent. Perez nevertheless contends that this Court s historically broad interpretation of what it means to practice law supp orts his argum ent and his p osition. Furth ermore, he says, that, because the meaning of practice of law has evolved over time, this Court should apply the current usage of the term, which, in his view, is that bar membership is not required under Article V , § 4. W e do no t agree. To be sure, this C ourt has he ld that a variety of activities may ve ry well constitute the practice of law, but we have never suggested, much less held, that those activities were so constituted in this context. On the contrary, we have addressed this issue only in the context of attorney d iscipline , see, e.g., Attorney Grievance Comm n of Maryland v. Hallmon, 343 Md. 390, 397-98, 681 A.2d 510, 514 (1996) ( [T]he preparation of legal documents, th eir interpretation, the giving of legal advice, or the application of legal principles to problems of any complexity are considered the practice o f law ), quoting Lukas v. Bar Ass n of Montgom ery County, 35 Md. App. 442, 448, 371 A.2d 669, 673 (1977) cert. denied, 280 Md. 733 (1977 ), quoting F.T. vo m Bau r, Administrative Agencies and Unauthorized Practice of Law, 48 A.B.A. J. 715 , 716 (1962); Attorney Grievance C omm n of Maryland v. James, 340 35 Md 318, 324, 666 A.2d 1246, 12 48 (1995 ) (recognizin g that mee ting with pro spective clien ts may, depending on the circumstances, constitute the practice of la w); Attorney Grievance Comm n of Maryland v. Kennedy, 316 Md. 646, 666, 561 A.2d 200, 210 (1989) (holding that interviewing, analyzing, and explaining legal rights constitute practicing law ). See also 68 Opinions of the Attorney General at 65 (concluding that Dean of law school had practiced Law ), and determ ining the eligibility of an out-of-state attorney to take the Maryland attorneys exam ination. See R.G.S., supra, 312 Md. at 637-41, 541 A.2d at 982-84. But we have held expressly that, in order for one to practice law in this State, one must be authorized to do so. See, e.g., Attorney Grievance Comm n of Maryland v. Alsafty, 379 Md. 1, 838 A.2d 1213 (2003) (atto rney was en gaged in the unauthorized practice of law when he practiced in both state and federal courts in Maryland before being admitte d to the bar of either court); Attorney Grievance Co mm n of Maryland v. B arne ys, 370 Md. 566, 805 A.2d 1040 (2002) (attorney admitted to th e practice of law in the District of Columbia was engaged in the unauthorized practice of law wh en he repre sented mu ltiple clients in Maryland state courts); Attorney Grievance Comm n v. Briscoe, 357 M d. 554, 745 A.2d 10 37 (2000 ) (appearing in court representing a client in a criminal matter after having been decertified constituted the unauthorized practice of law ). See Ginn v. Farley, 43 Md. App. 229, 403 A.2d 858 (1979) (lay person, who was not an aggrieved party but who prepared notice of appeal, memorandum of law, argued case before Circuit Court, and noted appeal to the Court of Special Appeals, preparing the necessary brief and record extract, was engaged in the unauthorized practice of 36 law). Perez, as had the C ircuit Court, relies on R.G.S. for the proposition that Perez indeed could have been practicing law in Maryland without being engaged in the unauthorized practice of law. We do not agree. In R.G.S., this Court w as asked to determine whether an attorney admitted to practice in North Carolina was eligible, pursuant to former Rule 14,38 to take the abbreviated Maryland 38 The Rule 14 to which this Court referred in R.G.S. is currently Rule 13 of the Rules Gove rning Admission to the Bar of M aryland (2007). Rule 13 is de rived in part from for mer Rule 14 and is in part new . Rule 13 p rovides, as re levant: Out-of- State Attorneys (a) Eligibility for Ad mission by A ttorney Exam ination--G enerally. A person is eligible for admission to the Bar of this State under this Rule if the person (1) is a member of the Bar of a state; (2) has passed a written bar examination in a state; (3) has the professional experience required by this Rule; (4) successfully completes the attorney examination prescribed by this Rule; and (5) possesses the goo d moral character and fitness necessary for the practice of law. (b) Required Professional Experience. The professional experience required for admission under this Rule shall be o n a full time basis as (1) a practitioner of law as provided in section (c) of this Rule; (2) a teacher of law at a law school approved by the American Bar Association; (3) a judge of a court of record in a state; or (4) a combination thereof. (c) Practitioner of Law. (1) Subject to paragraph s (2), (3), and (4 ) of this section, a practitioner of law is a person who has regularly engaged in the authorized practice of law (A) in a state; (B) as the principal means of earning a livelihood; and (C) whose professional experience and responsibilities have been sufficient to satisfy 37 the Board that the petitioner should be admitted under this Rule. (2) As evidence of the requisite professional experience, for purposes of subsection (c)(1)(C) of this Rule, the Board may consider, among other things: (A) the ex tent of the p etitioner's expe rience in general practice; (B) the petitioner's professional duties and responsibilities, the extent of contacts with and responsibility to clients or other beneficiaries of the petitioner's professional skills, the extent of professional contacts w ith practicing lawyers and judges, and the petitioner's professional reputation among those lawyers and judges; and (C) if the p etitioner is or ha s been a sp ecialist, the extent of the petitioner's experience and reputation for competence in such specialty, and any professional articles or treatises that the petitioner has written. (3) The Board may consider as the equivalent of practice of law in a state practice outside the U nited States if the Board concludes that the nature of the practice makes it the functional equivalent of practice within a state. (d) Duration of Professional Experience. (1) A person shall have the professional experience required by section (b) of this Rule for (A) a total of ten years, or (B) at least five of the ten years immediately preceding the filing of a petition pursuant to this Rule. (e) Exceptional Cases. In exceptio nal cases, the Board m ay treat a petitioner's actua l experienc e, although not meetin g the literal requ irements of subsections (c)(1) or (d) of this Rule, as the equivalent of the professional experience otherwise required by this Rule. *** l) Attorney Examination. The petitioner must pass an attorney examination prescribed by the Board. The Board shall define, by rule, the subject matter of the examination, prepare the examination, and establish the passing grade. The Board shall administer the attorney examination on a date and at a time durin g the adm inistration of th e regular ex amination pursuant to Rule 7 and shall publish at least 30 days in advance notice of the date and time of 38 bar examination for lawyers. We drew a distinction between practice of law, as used in that Rule and as it pertains to the unauthorized practice of law, proscribed by Maryland Code (1989, Repl. Vol. 2004, 2006 Cum. Supp.) § 10-60139 of the Business Occupations and Professions Article. We explained: We are persuaded that practice of law as used in the unauthorized practice statutes need not be read as synonymous with practice of law as used in R ule 14. The question is the goal or objective of each enactment and the context within which the words are used. The goal of the prohibition against unauthorized practice is to protect the public from being preyed upon by those not compete nt to practice la w-from incompe tent, unethica l, or irresponsib le representation. The purpose of the practice requirement in Rule 14, as we have the examination. The Board shall grade the examination and shall send notice of examination results to each examinee by regular mail, postage prepaid. Successful examinees shall be notified only that they have passed. Unsuccessfu l examinees shall be give n their grades in the detail the Bo ard considers a ppropriate. R eview by un successfu l examine es shall be in accordance w ith the provisions of Ru le 8(b). 39 Maryland Code (1989, Repl. Vol. 2004, 2006 Cum. Supp.) § 10-601 of the Business Occup ations and P rofessions Article prov ides, as releva nt: § 10-6 01. Practicing without admission to Bar. (a) In general. Excep t as othe rwise p rovide d by law , a person may not practice, attempt to practice, or offer to practice law in the State unless admitted to the Bar. (Em phasis a dded). See also Maryland Lawyers Rules of Professional Conduct 5.5 (2007), which provides, in pertinent p art: (a) A lawyer shall not practice law in a jurisdiction in violation of the regulation o f the legal pro fession in th at jurisdiction, or assist anothe r in doing s o. (b) A law yer who is no t admitted to p ractice in this juris diction shall n ot: (1) except as authorized by these Rules or other law, establish an office or other systematic and continuous presence in this jurisdiction for the practice of law; or (2) hold out to the public or otherwise represent that the lawyer is admitted to practice law in this jurisdiction. 39 seen, is to assure a m inimum degree of legal co mpetenc e: to suppo rt a presumption ... that ... [the] applica nt is compe tent in the law on the bas is of his experience in practice as well as his success in another State's full bar exam ination. 312 Md. at 638, 541 A.2d at 983 (citation s and intern al quotation s omitted) (em phasis added). That minimum degree of legal competen ce did not suffice, w e were clear, to adm it the out-of-state la wyer to the bar of th is State, just to allow him or her to avoid having to take the full bar examination in this State. In R.G.S., the question before this Court was not whether the attorney was practicing law in this State; it was simply whether his legal experience was su ch, of a caliber, that he was eligible to take the abbreviated lawyers bar exam ination. Perez also relies on Norris v. Mayor and City Council of Baltimore, 172 Md. 667, 192 A. 531 (1937) in support of his argument. In Norris, this Court examined whether voting machines lawfully could be used in State elections, when Article 1, § 1 of the Maryland Constitution require d that all e lections shall be by ballot. The opponents of voting machines contended that it was impossible for the term ballot to include voting machines, as such machines did not exist when Article 1, § 1 was adopted. We do not disagree with the theory upon which Perez bases this argument. We do not agree, howev er, with the result he reaches. Our an alysis cau ses us to reach a differe nt conc lusion. In Norris, we opine d: [W]hile the principles of the constitution are unchangeable, in interpreting the language by which they are expressed, it will be given a meaning which w ill permit the application of those principles to changes in the economic, social, and 40 political life of the people, which the framers did not and could not foresee....In determining the true meaning of the language used, the courts may consider the mischief at which the provision was aimed, the remedy, the temper and spirit of the people at t he time it was framed, the common usage well known to the people, and the histo ry of the grow th or evoluti on ...[and the] long continued contemporaneous construction by officials charged with the administration of the gov ernme nt, and e speciall y by the Leg islature. Id. at 675-76, 192 A. at 535 (citation s omitted); Benson v. State, 389 Md. 615, 633, 887 A.2d 525, 535 (2005 ); Boyer v. Thurston, 247 Md. 279, 292, 231 A.2d 50, 57 (1967); Johns Hopkins University v. Williams, 199 Md. 382 , 386, 86 A.2d 89 2, 894 (1952). This Court further asserted: [W]here the meaning of the words employed is susceptible of expansion so as to include a significance in complete harmony with the sp irit and purpose of the instrument which w ill gratify a legislative intent or serve a present need, they may be s o interp reted.... 172 M d. at 676 , 192 A . at 535. 40 Nor is this case at all a nalogous to Norris. Although correct in his assertion that the meaning of practice of law has evolved, the case sub judice does not involve a chang e in 40 See also Clauss v. B oard of E ducation o f Anne Arunde l County, 181 Md. 518, 30 A.2d 779 (1943) . In examining the evolution of education, this Court remarked: It is not supposed that the framers of the Constitution of 1867 did not expect that the system of education then in force to be changed or improved. They could not, of course, foresee what changes were to come, so they w isely did no t attemp t to defin e wha t they mea nt by edu cation. They left that to be interpreted in the light of conditions at any given time when such a question should arise. Id. at 523, 30 A.2d at 78 3 (emphasis adde d). Similarly, the framers did not attempt to define or list the kinds of activities that would constitu te the p ractice o f law . We, however, do not suppose that they at anytime intended the phrase to denote the unlawful practice of law. 41 the practice of law. W hat it means to practice la w in this Sta te has rem ained con sistent. As noted earlier, albeit the process by which one becomes authorized to practice law and the authorizing authority may have been different when the Maryland Constitution was adopted, nonetheless, there were some formal admission requireme nts for an in dividual to practice law in the State.41 Someo ne, anyone c ould not sim ply walk into a court o f law and try a case. His or her qualification to do so had to be evaluated by a judge. It would be illogical, therefore, for this Court to hold, as Perez and the Circuit Court contend the case to be, that the evolution of the law thus far lend s credence to the propo sition that one who see ks to hold the office of the Attorn ey Gene ral need not be a memb er of the Marylan d bar at a ll. This logic would, in effect, undermine, and ultimately change, the basic principle of construction as we knew it in 18 67 and as we know it today. This Court is no t averse to looking at th e evolution in circumsta nces as they rela te to the practice of law. H aving don e so, how ever, we c annot, and will not, simply by reference to those circumstances, and in complete disregard of the constitutional language, expand, or restrict, the requirements for the practice of law. To this extent, we agree with the appellant that the Circuit Court s interpretation of Article V, § 4 is too broad. It is true that the Norris court cautioned that we are not to be too restrictive in our interpretation of statutes or constitutional provisions; h oweve r, neither it nor logic demands that we so broadly interpret a constitutiona l provision a s to make that provision absurd or unworkable. See Montgom ery 41 See dis cussion of bar a dmissio ns requ iremen ts, supra at 30-33. 42 County Comm rs v. Supervisors of Elections o f Mon tgomery Co unty, 192 Md. 196, 208, 63 A.2d 735, 74 0 (194 8). See also Bienkowski, 386 Md. at 548, 873 A.2d at 1141 ( [I]t is a well settled principle of statutory or constitutional construction that a provision should not be construed so as to rend er it nugatory ); Comptroller of Treasury v. John C. Louis Co., Inc., 285 Md. 527, 539, 404 A.2d 1045, 1053 (1979) ( Results that are unreasonable, illogical or inconsistent with common sense should be avoided and an interpretation should be given which will not lead to absurd or anomalous results ). We reject Perez s argument tha t this Court should take a liberal view of what it means to practice law as this would go against the intent of the framers and the purpose of the provision as a whole. Thus, the Circuit C ourt correctly ob served that P erez was not engag ed in the unauthorized practice of law when he was performing his duties as a Justice Department lawyer. It does not follow, however, that, as that court concluded, merely because the practice was authorized by another licensing a uthority and then for a limited purpose and the practice occurs physically within the confines of the State, that that practice suffices as the practice of law in this State, as the term is used in Article V, § 4. As we have concluded , such practice, by its plain meaning, implies actual bar m embership in the M aryland Bar. B. The appellant s next argument relies on the legislative history of Article V, § 4. This Court has held that, when attempting to discern the intention of the Legislature in proposing a particular constitutional provision, it is permissible to inquire into the prior state of the law, 43 the previous and con temporary history of the people, the circumstances attending the adoption of the organic law, as well as broad considerations of expediency. Brown 287 Md. at 278, 412 A.2d at 399.42 See, e.g., Luppino v. Gray, 336 Md. 194, 204 n. 8, 647 A.2d 429, 434 n. 8 (1994) ( One of the sources to which the court may look to d iscern the fra mers' purpo se in enacting the [constitutional] provision is the proce edings of the constitutional co nvention ), citing Reed v. M cKeldin , 207 Md. 553, 561,115 A.2d 281, 285 (19 55); Cohen v. Governor of Maryland, 255 Md. 5, 16, 255 A.2d 320, 325 ( The intention [of a constitutional provision] is primarily discovered by considering the words used by the draftsme n ); McMullen v. Shepherd, 133 Md. 157, 160, 104 A. 424, 425 (1918) ( In construing the Constitution we are to consider th e circumsta nces attend ing its adoption and what appears to have been the understanding of the people when they adopted it, and one of the useful and most helpful sources is the debates of the Conv ention ). Accordingly, we look, now, to the history and purpose of Article V, § 4 in an attempt to determine the scope and applicability the framers and 42 This Court s examination of the legislative history of Article V, § 4 should not be misconstrued as an attempt, on our part, to resolve an ambiguity in the provision. As we have stated, it is this Court s holding that the phrase, practiced Law in this State for at least ten years, is cle ar and un ambiguo us. We inq uire into the leg islative history as bo th confirma tion of our in terpretation an d in respon se to the argu ments off ered by both parties. See, e.g., Mayor and City Council of Baltimore v. Chase, 360 Md. 121, 131, 756 A.2d 98 7, 993 (20 00) ( [T]h e resort to legisla tive history is a con firmatory proc ess; it is not under taken to co ntradict the pla in meanin g of the statu te); Morris v. Prince G eorge s County, 319 Md. 597, 604, 573 A.2d 1346, 1349 (1990) ( Even when the words of a statute carry a definite meaning, we are not precluded from consulting legislative history as part o f the pro cess of determ ining th e legisla tive pur pose o r goal o f the law ), quoting Wilde v. Swanson, 314 Md. 80, 92 , 548 A.2d 837 , 843 (1988). 44 the people intended it to have to this case. The appellant argues that the Attorney General could not discharge the duties of the position, as outlined in Article V, § 3, unless he were a member of the Maryland Bar, as appearance in the courts o f the state and the ability to practice law witho ut restriction are necessary to being ab le to do so. Consequently, he contends that the framers must have intended for the Attorney General to be admitted to practice in the State. Perez, on the other hand, argues that the language of Article V, § 3, in fact, granted the Attorney General the power to appear in state courts, thus, allowing him to do so under constitutional mandate, rather th an thro ugh the tradition al bar ad mission proces s. There is no conflict between Article V, § 3 and A rticle V, § 4. T he appellan t correctly asserts that, when the constitutional provisions pertaining to the office of the Attorney General were adopted, the Attorney General was required to app ear personally in the courts o f this State and that he cou ld not have done so u nless he w ere a mem ber of the Maryland Bar. Perez s contention, on the other hand, that Article V, § 3 was intended to circumvent the bar admission procedures simply is unpersuasiv e. Article V, § 3, enumerating the duties of the Attorney General, does not a ddress and , indeed, is irrelevant to the q ualifications o f a candid ate to contest for the office of the Attorney General; it has no application until a candidate has been declared the winne r and, as a res ult, assumes the office. That is to say, Section 3 does not come into play until one actually becomes the Attorney General. Thus, con trary to Perez s argumen t, the qualification requirements of the Attorney General, as prescribed by Article V, 45 § 4, are not superseded by the duties that are outlined in Article V, § 3. Read ing Ar ticle V, § 4 in context with the historical role of the Attorney General leads to the consistent conclusion that the framers did, indeed, intend for the office to be held by one who is admitted to practice law in th e State. C. In interpreting Article V, § 4, in addition to its current language, which is the reason for the dispute in the case sub judice, the parties examine the changes that language has undergone, over time, since its initial adoption.43 To be sure, Article V, § 4 has undergone various changes. There was a very distinct difference between what was pro posed with regard to Attorney G eneral eligibility, in their s everal iterations, and w hat ultim ately was adopte d. As proposed, Article V, § 4 would have read: No person shall be eligible to the office of attorney g eneral, who has not been admitted to practice the law in the S tate, and who has not practiced the law for ____ years, and who has not resided for at least ____ years in t he State . (Emphasis add ed). As adopted, the bar adm ission and le ngth-of-p ractice prov isions were merged in to a single requireme nt, that the c andida te have practice d law f or the sp ecified period . It is that merger which is the point of contention in the instant case. Both sides of fer justif ication f or the C onven tion s m erger o f qualif ications . Viewing it as an apparent om ission of the phrase w ho has not been a dmitted to practice law in the 43 See constitu tional pr ovision s, supra at 21, 22. 46 State from the final version of the enactment, the appellant argues that the framers did not mean to remove the bar admission requirement at all, but, instead, recognized that it was not nece ssary, that to provide explicitly that the Attorney General be admitted to the bar to practice law in Ma ryland w ould ha ve bee n dupli citous. On the other hand, Perez, proceeding on the same premise, contends that the phrase was om itted because the framers did not intend that such a requirement apply to candidates for the office of the Attorney General. He asserts, relying on this Court s holding in Kadan v. Bo ard of Supervisors o f Elections of Baltimo re County, 273 Md. 406, 329 A.2d 702 (1974), that, if the framers had intended to impose a bar membe rship requirement on Attorney General candidates, they, like the framers in numerous other states, would, and could, have retained that express language.44 In Kadan, candidates for the office of judge of the Orphans Court, who w ere members of the Maryland Bar, brought an action against the State Board to prohibit it from placing on the ballot the names of candidates for that of fice who w ere not membe rs of the Maryland B ar. 44 Perez cites to provisions governing eligibility for the office of the Attorney General contained in other states constitutions. To be sure, othe r states have used mo re explicit la nguag e to reac h the co nclusio n adva nced b y the app ellant, see, e.g.,Connecticut Gen. Stat. Ann. § 3-124 (requiring that Connecticut Attorney General be an attorney at law of at least ten years active practice at the bar of this state. ); Colorado Constitution, Art. IV, § 4 (requiring n ominees f or Suprem e Court jus tice to have b een license d to practice law in Colorado for at least five years, and requiring Attorney General nominees to be a licensed attorney in good standing); Code of Virginia § 24.2-501 (requiring nominee s for Attorn ey General to have bee n admitted to the bar of the Com monw ealth for at least five years directly preceding the election); however, we are not persuaded that bar admission was not necessarily encompassed in the practiced Law in this State language of Article V, § 4, and, thus, a requirement. Therefore, Perez s comparison of this provision to other mo re explicit pro visions doe s not com pel a differe nt result. 47 The plaintiff s mainta ined tha t Article IV, § 40 45 required judges of the Orphans Court to be members of the Maryland B ar. This Court did not agree. We held, instead, that candidates for judge o f the O rphans Cour t were n ot requ ired to b e lawyer s. Perez argues that, as in Kadan, the lack of express language requiring bar mem bership as a prerequisite qualification is an indication that a candidate for the office of the Attorney General need n ot be a m embe r of the M aryland B ar. We do not quarrel with, indeed, agree with, Perez s an alysis of Kadan. Kadan does not support his arg ument in this case, how ever. It is, in fact, distinguishable from the case sub judice. Article IV, § 40 does not make any reference whatever to the practice of law or , for that matte r, to any indicia that would suggest, much less indicate, that bar membership is a prerequisite for being an Orphans Court judge. Thus, in Kadan, there simply was nothing that could be inferred about the issue, from the constitu tional pr ovision , the wo rds use d or om itted, as th ere is in th e instan t case. In Kadan, in other words, this Court was not f aced with the interpretatio n of spec ific language pointin g to a qu alificatio n, the pe rimeters of wh ich are in dispute , as in this ca se. Rather, this Court had to discern the significance of the absence of a ny language tending to 45 Article IV, § 40 governs the eligibility requirements for Orphans Court judges and prov ides, in pertine nt part: The qualified voters of the City of Baltimore, and of the several Counties, except Montgomery County and Hartford County, shall elect three Judges of the Orphans Courts of City and Counties, respectively, who shall be citizens of the State and residents, for the twelve months preceding, in the City or C ounty fo r which they may b e electe d. MD CON ST. art. IV, § 40. 48 support the claimed qualification. Although the election was for a judge, the only qualifications enumerated were citizenship and residency. The provision d id not refer a t all to bar membership or law practice. Here, to the contrary, Section 4 explicitly provides that the candidate have practiced Law in this State. Consequently, given the law and rules pertaining to the practice of law, that pro vision reaso nably may be co nstrued ex pressly and clea rly to contemplate, albeit perhaps by implication, bar admission. The lack of any express language at all with respect to bar admission or law practice, as in Kadan, simply can not be equated with the situation sub judice, where there is a clear requirement of the practice of law in the State, for some length, but no explicit requirement that the candidate be admitted to the ba r. Article V, § 4, in other words, is not devoid of all language that would require a candidate for the Attorney General to be a lawyer, th us, argu ably ope ning th e positio n to non -lawyers . On the contrary, it reflects, we believe clearly, the purposeful merger of two requirements, which, taken together, m ake clear tha t being an a ttorney is a nece ssary requirem ent to being able to run fo r, and ho ld, the of fice of the Atto rney Ge neral. This Court interprets the framers actions as an attempt to avoid being repetitive. The rewording of the prov ision was n ot, as Perez c laims, a result o f an attempt to change the meaning of the lang uage or to change th e eligibility requirements for the office of the Attorney General. Confirm ation of our interpretation is provided by the proceedings of the debates. 49 During the debates of the 185 0 Constitu tional Convention, Delegate Ben jamin C. How ard 46 of Baltimore County, albeit discussing the eligibility requirements of prosecuting attorneys, stated: In framin g a Co nstitution ...it [is] altogether unnecessary to introduce all the matters of detail, when we ought to content ourselves with laying down c ertain general rules or principles for the guidance of the legislature. If we are to go on in this way, it will end in making a book w hich the people w ill no more understand than they do the old Constitution itself, and after all, it will be found impossible for us to provide for all contingencies. To specify that a man who is elected to the office of prosecuting attorney must b e a practitione r of laws is entirely superfluous. It is preposterous to fill the Constitution with details of this sort...it was generally understood that the applicant for the office must know something of the business, that he must be a practitioner of law. If we are apprehensive that the people may elect some one who is entirely incompetent to perform the duties of the office, it will be better that we should not give them the righ t to elect. Debates I at Vol. I I, 14 (em phasis a dded). See also The Debates of the Constitutional Convention of the State of Maryland ( Debates II ), 369 (Annapolis, 1864) (Mr. DUVALL. If it is correct to say frequent, maintain, or contribute, then the o r between frequent a nd mainta in is superflu ous. ); Debates II at 1601 (Mr. SCHLEY said: I have no objection to the proposition as it stands; but deeming it superfluous, I vote no ). Perez also relies on Article IV, § 2 and Article V, § 10 of the Maryland Constitution, 46 Delegate Howa rd was a c ongressm an. His stud y of law w as interrupted by his service in the U.S. Army during the War of 1812, where he reached the rank of brigadier general be fore returnin g to Ma ryland to com plete his legal s tudies. He w as admitted to the Maryland bar in 1816 and ran for Governor in 1861. 50 which, respectively, require judicial candidates to have b een adm itted to practice law in this State and candidates for the office of State s Attorney to have been admitted to practice law in this State. His argument, the framers use of express language requiring bar mem bership in these provisions is indicative that their intent, as expresse d in Article V , § 4, was n ot to require it there. Perez and the Circuit Cou rt read Article IV, § 2 an d Article V § 10 to m ean that on ly candidates for state s attorney and judge are required to be ad mitted to the b ar and that is because the constitutional provisions governing each say so. On the other hand, he continues, the absence of the same or similar language in Article V , § 4 indicates that it is possible for the Attorney General candidate to practice law without ever having been admitted to the Maryland Bar. We decline to so interpret the framers intent. That would mean that state s attorney and judicial candidates are required to be admitted to the bar, while the State s lawyer, the top lawyer for the State - and at times the only lawyer for the State in civ il, Federal, and appe llate procee dings - n eed no t be. Moreover, the assum ption und erlying this argum ent may not b e correct. It is no t at all clear that requiring candidates for judge and state s attorney to be members of the bar was imposed as a more stringent requirement than that fo r Attorney G eneral. To th is Court, it is far more lik ely that it w as inten ded to b e, rather , a more relaxed one. The framers intent was to require of candidates for State s Attorney and judge so lely that they be admitted to the bar. That is to say, they very deliberately did not impose on those seeking to be a state s attorney 51 or a judge the requireme nt of havin g actually prac ticed law, whether in Maryland or elsewhere, just that they be members of the bar. The opposite is true for the office of the Attorney General. Because the Attorney General was, and is, intended to be the foremost lawyer for the State, it is not surprising that a candid ate for that of fice wou ld be require d to have more qualification than simply a bar membership, that it would be required that a person aspiring to that position would be required to be both le arned in the law, as e videnced by his or her bar membership, and experienced in its practice, as reflected in his or her length of practice . As stated earlier, constitutional provisions need to be read in context and as a whole. See Moher, supra, 318 Md. a t 225, 56 7 A.2d at 932, quoting Rucker, supra, 315 Md. at 565, 555 A.2d at 10 63; Wheeler, supra, 281 Md. at 596, 380 A.2d at 1055. The appellant concedes that a candidate for the office of the Attorney General need only be a member of the bar in order to be eligible and urges this Court to so hold. On the other hand, Perez urges this Cou rt to hold that practice for the requisite time period is all that is required. Thus, the appellant reads out of Article V, § 4, the practiced Law language,47 and Perez reads that same language narrowly an d in a cons trained ma nner, refus ing to give it its common and ordinary 47 The appellant argue s that if Perez had been a member of the Maryland Bar, rather than the New York Bar for the past 17 years and possessed the same professional qualifications, he would be eligible to hold the office of the Attorney General. We do not agree. As noted earlier, one who seeks to hold the office of the Attorney General must be both a me mber of th e Maryland Bar for at le ast ten years and must hav e practiced la w in Maryland for at least ten years; thus, Perez s eligibility to be Attorney General under the appellant s hypothetical is at least an open question. 52 signification. Neither, in other words, reads Article V, § 4 as a whole. Turning again to the debates of the Constitutional Convention of 1864, Delegate Archiba ld Stirling Jr. of Baltimore City, while discussing the salary of the A ttorney Gene ral, stated that [the citizens of Maryland] must hav e for the attor ney general a man w ho is accustomed to trying cases, or he will not be fit for the office. Debates II at 1461. During the same debate, Delegate Peter Negley of Washington County and Delegate John E. Smith of Carroll County also spoke to the kind of individual who should occupy the office of the Attorney General. Delegate Negley observed that if [the framers] put in an insu ffic ient s alary, [they could] not get the services of a man whose services [would] be worth anything. And rather than have a second or third rate man in the office, [they should] strike out the provision entirely, Debates II at 1460, while Delegate Smith stated: I think a ma n who is c alled upon to fill this responsible position, ought to have practiced law fo r ten years at least. It is one of the most im portant and responsible positions in the State. And from the circumstances that now surround us, from the changes proposed to be made by this constitution, it is evident that we require in this position the services of one who has occupied a leading po sition, in the pro fession fo r ten years at least. Debates II at 1465 . (Emphasis added) Delegate Sm ith stated furth er: I know there are instances of rather extraordinary men. But a gentleman may be learned in the law, and yet not knowing about the d uties of attorn ey general. I think ten years is short enough time to require of one who will be called upon 53 to apply himself to the practice of law in all its branches. Id.48 It is apparen t that the fram ers, viewing the position o f Attorney G eneral as a highly important one, requiring the practice of law in all the government's branches, desired to have an experienced attorney fill that role, measured by a term of ten years. A mere member of the bar for a few years would be insufficient - while they recognized that there may be instances of brilliant attorneys who could perform the duties of the Attorney General withou t ten years of bar membership, the framers felt secure in promoting a seasoned practicing attorney for the position, one who was admitted to the Maryland Bar and had, in fact, practiced for the prescribed period.49 The framers did not ever contemplate that the office would be held by an individual who did not, at the least, posses s a professional record o f the length prescribed, 48 Delegate Smith s proposal that a candidate for the office of the Attorney General needs to have practiced law in this State for ten years was rejected by a vote of 24 yeas and 26 nays. The Convention, ultimately rejecting Delegate Smith s as well as Delegate Frederick Schley s proposal that the minimum length of practice should be 5 years, settled on seven years as the requirement, adopting the proposal by Delegate Ezekiel Forman Chambers of Kent County. The minimum practice required of a candidate for the Attorney General subsequently was changed to ten years with the adoption of the 1867 Maryland Constitution. It was proposed at the 1967 Constitutional Convention that the practice period be redu ced to f ive years. See Constitutional Convention of Maryland 1967-1968 Comparison of Present Constitution and Constitution Proposed by Convention, 77-78, 157 (Baltimore, 1968). That proposal was rejected, however. The lang uage of A rticle V, § 4, thu s, has rem aine d unchan ged for o ver a cent ury. 49 It can be deduced from these debates that the framers, in fashioning the "practiced Law" requirement in Article V, § 4, felt that ten years was an adequate amount of time afte r which a n attorney, hav ing practiced the entire time , would b e sufficien tly tested and, thus, capable of handling the duties of the Attorney General. The change of length requirement from 1864 to 1867, requiring an additional three years, only confirms this Court s holding that a candidate for the office of the Attorney General must be an experie nced a ttorney ad mitted to practice law in M aryland. 54 upon which the voters could bas e their decision. Thus, we hold, a candidate for the office of the Attorney General mu st be both a mem ber of the Maryland Bar for ten years and a practitioner of law in Maryland for ten years.50 50 An examination of the past Attorneys General of the State of Maryland, from 1864 to the present, the period from which the eligibility requirements were first articulated to now, reveals that all those who have occupied the office of the Attorney General have been members of the Maryland Bar and have had the requisite practice experie nce. All of this State s past Attorneys General practiced law in Maryland, as members of the Maryland Bar, for a period of at least ten years. This Court, thus, declines to depart fro m wha t has been, a nd continu es to be, the c lear, unam biguous e ligibility requirements for this office. To allow an individual who does not meet the qualifications, as prescribed by Article V, § 4, to become the Attorney General of this State would serve to undermine not only the intent of the framers but also the long history of those competent individuals who have performed the duties of this important office. The follo wing is a list o f Maryland s Attorneys G eneral from 1864 to th e present, detailing their re quisite profe ssional exp erience: Alexand er Randa ll (1865-1867), admitted to th e Bar in 18 24, engag ed in private practice fro m 1824 -41; Andrew K. Syester (1871-1875), admitted to the Bar in 1853, partner at A.C. Bond of Westminster from 18 53-71, Sta te s Attorne y for Wash ington Co unty in 1854 ; Charles J.M. Gwinn (1875-1883), admitted to the Bar in 1843, lead counsel for the B&O Railroad, General Counsel for Western Maryland Union Telephone Co. and C & P Telephone Co. 1843-49, State s Atto rney for Balto . City 1857-61 ; Charles B oyle Roberts (1883-18 87), admitted to the Bar in 1 864, private practice 18 64-75, 18 79-83; William P inkney Wh yte (1887-1891), admitted to th e Bar in 18 46, private p ractice 184 9-51, 185 7-68, 187 4-75, 188 3-87; John Prentiss Poe (1891-1895), adm itted to the Bar in 1857, private pra ctice/founder law firm of John P. Poe & Sons 1857-71, Professor of Law, University of Maryland School of Law 1869-71 , Dean, U niversity of M aryland Scho ol of Law 1871-19 09, Baltimo re City Counse lor 1882-8 4; Harry M. Clabaugh (1895-18 99), admitted to the Bar in 1878, priv ate practice 18 78-91; George Rigg s Gaither, Jr. (1899), ad mitted to the B ar 1886, pr ivate practice 18 86-99; Isidor Rayner (1899-19 03), admitted to the Bar in 1871, priv ate practice 18 71-78, 18 94-99; William Shepard Bryan, Jr. (1903-1907), admitted to the Bar in 1882, pr ivate practice 1882-90 , City Solicitor 189 2-96; Isaac Lobe Straus (1907-1911), admitted to th e Bar in 18 92, private p ractice 189 2-1902; Edgar Allan Poe (1911-1915), admitted to th e Bar in 18 85, private p ractice John P. Poe & Sons 18 95-1900 , Deputy State s Attorney and State s Attorney for Baltimore City 1900-07, Deputy City Solicitor and City Solic itor 1908-1 1; Albert C. R itchie (1915-1919), admitted to the Bar in 1898, 55 D. The appellant s final argument addresses Perez s federal bar membership. Perez argues that, because he has practiced federal law in Maryland for over 20 years, he meets the private practice Steele, Seemes, Carey & Bond 1900-03, Janney and Ritchie 1903-19, Assistant City Solicitor for Baltimore 1903-10, Professor of Law, University of Maryland School o f Law 1 907-20; Ogle Marb ury (1918-19 19), admitted to the Bar in 1904, priv ate practice Marbury & Perlman and later partner with Lee I. Hecht 1904 1910, Attorney for the County Commissioners of Prince George s County 1914-18, 1937-41, Attorney for Bd. of Education Prince George s County 1916-37, Assistant Attorney General 1916-20; Alexander Armstrong (1919-1923), admitted to the Bar 1904, City Attorney for Hagerstown 1904-06, State s Attorney for Washington County 1908-12, private practice Armstron g & Sco tt 1912-19 ; Thomas H. Robinson (1923-1930), admitted to the Bar 1883, priv ate practice 1 883-192 3; William Preston La ne, Jr. (1930-1934), admitted to the Bar 1916, private practice Keedy & Lane (later Lane, Bushong & Byron) 1919-30; Herbert R. O Conor (1934-1938), admitted to the Bar 1919, General Counsel for American M erchant Marine In stitute 1920-21, Assistant State s A ttorney for Baltimore City 1921-2 2, State s A ttorney for Ba ltimore City 192 3-34; William C. Walsh (19381945), admitted to the Bar 1912, private practice 1913-16, City Solicitor Apr. 1920 Sept. 1921, Associate Judge Fourth Judicial Circuit 1921-24, Chief Judge Fourth Judicial Circuit and membe r of the Co urt of Ap peals 192 4-26; William Curran (1945-1946), admitted to th e Bar 191 0, private pra ctice 1910 -45; Hall Hammond (1946-1952), admitted to the Bar 1925, Private practice Willis & Hudgins 1925-29, private practice 1929-38 , Deputy A ttorney Gene ral of Ma ryland 1938 -46; Edward D.E. Rollins (19521954), adm itted to the Ba r 1922, Sta te s Attorne y for Cecil C ounty 1930 -1943; C. Ferdinand Sybert (1954-1961), admitted to the Bar 1925, private practice 1925-31, Counsel for Howard County Bd. of County Commissioners 1931-34, State s Attorney for Howa rd Coun ty 1934-46; Thomas B. Finan (1961-1966), admitted to the Bar 1939, private practice 1939-41, 1945-48, City Solicitor for Cumberland 1948-50, 1952-59; Robert C. Murphy (1966), admitted to the Bar 1952, Counsel to the University of Maryland 1 952-54, S pecial Ass istant to the A ttorney Gene ral, Assistant A ttorney Gene ral, and De puty Attorney G eneral of M aryland 1956 -66; Francis B. Burch (1966-1978), admitted to th e Bar in 19 43, private p ractice Allen , Burch an d Baker 1 945-61, C ity Solicitor of B altimore 19 61-63; Stephen H. Sachs (1979-1987), admitted to the Bar 1960, Assistant U.S. Attorney for Maryland 1961-64, private practice Tydings, Rosenberg & Gallaghe r 1964-67 , private practic e 1970-7 9; J. Joseph Curran (1987-20 07), admitted to the Bar 1959, Attorney 1959-87. 56 practiced Law in this State requireme nt. That is so, P erez conte nds, becau se his federal bar membe rship and his position with the Justice Department authorized him to practice law in this State and that his oversight of cases involving Maryland and any appearances in the federal courts in Maryland was evidence that he has practice d law in this Sta te, within the meaning of Art icle V, § 4. Aga in, we d o not ag ree. Perez bases his argument on 28 U.S.C. § 517 (2007) and Rule 701(1)(b) of the Local Rules of the United States District Court for the District of Maryland (2007). 28 U.S.C. § 517 provides: The Solicitor General, or any officer of the Department of Justice, may be sent by the Attorney General to any State or district in the United States to atten d to the interests of the United States in a suit pending in a court of the United States, or in a court o f a State, or to attend to any other interest of the United States. To be sure, Pe rez is correct th at he was authorized , beginning in 1989 an d continuin g until he left federal government service, to appear in any State or in any federal court in which a suit affecting the interests of the United States was pending, even those to whose bar he had not been admitted to practice, to attend to the interests of the United States. That authorization, however, does not e quate to the practice of law in this State, as cont empla ted by A rticle V, § 4. A member of the bar of any state may be admitted to the federal bar of any state, whether or not admitted to the bar of the state in which the federal court is loca ted p hysically. 51 51 See Federal R ules of A ppellate Pro cedure R ule 46, wh ich provide s, as relevant: Rule 46. Atto rneys . (a) Admission to the Bar. 57 Con sequ ently, the entry of appearance in a federal court located in this State by someone not admitted by this Court to practice here is not tantamount to practicing law in this State.52 Nor is the appearance in Maryland state courts to attend to the interests of the United States authorization to practice law in this State for purpo ses of A rticle V, § 4. As with Pro Hac Vice admissions, see Rule 14,53 its duration is fixed and its purpose define d - it ordinarily is (1) Eligibility. An attorney is eligible for admission to the bar of a court of appeals if that attorney is of good moral and professional character and is admitted to practice before the Supre me Co urt of th e Unite d States , the highest c ourt of a state , another United States court of appeals, or a United States district court (including the district courts for Guam, the Northern M ariana Islands, and the V irgin Islands). 52 We know this to be true, as we have previously held that an attorney who was authorized to practice in a Maryland federal court violated the Rules of Professional Conduct when she attempted to practice at the Maryland state level without Maryland bar membership. See Attorney Grievance Comm n v. Johnson, 363 Md. 598, 628, 770 A.2d 130, 148 (2001); See also Alsafty, 379 M d. at 18-20, 8 38 A.2d at 1223-2 4; Bridges, infra at 61-62, 36 0 Md. at 5 09-12, 75 9 A.2d a t 244-45; Attorney Grievance Comm n v. HarrisSmith, 356 M d. 72, 83-84 , 737 A.2d 567, 573 (1999); Kennedy, infra at 61-62, 316 Md. at 667-68, 561 A.2d at 211. The holdings in these cases could not be correct unless practice in Maryland federal courts were viewed differently than practice in Maryland state courts. 53 Rule 14 of the Rules Governing Admission to the Bar of Maryland (2007) provides, as relevant: Special a dmission of out-of-s tate a ttorn eys. (a) Motion for special admission. A member of the Bar of this State wh o is an attorne y of record in a n action pe nding in any court of this State, or before an administrative agency of this State or any of its political subdivisions, or representing a client in an arbitration taking place in this State involving the application of Maryland law, may move, in writing, that an attorney who is a member in good standing of the Bar of another state be admitted to practice in this State for the 58 limited purpose of appearing and participating in the action as co-counsel with the movant. If the action is pending in a court, the m otion shall be filed in that co urt. If the action is pending b efore an a dministrative agency or arb itration panel, the motion shall be filed in the circuit co urt for the co unty in which the principal office of the agency is located or in which the arbitration h earing is loca ted or in any oth er circuit to which the action may be appealed and shall include the movant's signed certification that copies of the motion have been furn ished to the a gency or the a rbitration pan el, and to all parties of record. *** (d) Limitations on out-of-state attorney's practice. An attorney specially admitte d may act on ly as co-couns el for a party represented by an attorney of record in the action wh o is admitted to practice in this State. The specially admitted attorney may participate in the court or administrative proc eedi ngs o nly when acco mpa nied by the Maryland atto rney, unless the latter's presence is waived by the judge or administrative hearing officer presiding over the action. Any out-of-state attorney so admitted is subject to the Maryland Lawyers' R ules of Pro fessional C onduct. See also Rule 15 of the Rules Governing Admission to the Bar of Maryland (2007), which provides, as relevant: Special au thorization f or out-of-sta te attorneys to pra ctice in this state. (a) Eligibility. Subjec t to the pr ovision s of this R ule, a member of the Bar of another state who is employed by or associated w ith an organ ized legal ser vices prog ram that is sponsored or approved by Legal Aid Bureau, Inc. may practice in this State pursuant to that organized legal services program, if (1) the individual is a graduate of a law school meeting the requirements of Rule 4(a)(2), (2) the legal services program provides legal assistance to indigents in this State, and (3) the individual will practice under the supervision of a member of the Bar of this State. (b) Proof of eligibility. To obtain authorization to practice under this Rule the out-of-state attorney shall file with the Clerk of the Court of Appeals a written request accompanied 59 limited to the pending case. Until he became a member of the Maryland Bar in 2001, Perez simply did not have carte blanche authorization to practice law in the state of Maryland; he could practice only in federal court or in state court in the interest of the United States. 28 U.S.C. § 517 does not obviate the Maryland requirement that one desiring to practice law in Maryland must be a dmitted to the Maryland B ar. Perez fares no better under Rule 701(1)(b) of the Local Rules of the United States District Court for the District of Maryland. Rule 701(1)(b) provides: An attorney who is a member of the Federal Public Defender s Office, the Office of the United States Attorney for this District, or other federal government lawyer, is qualified for admission to the bar of this District if the attorney is a mem ber in g ood sta nding o f the hig hest co urt of an y state. by (1) evidenc e of gradu ation from a law sch ool as defin ed in Rule 4(a)(2), (2) a certificate of the highest court of another state certifying that the attorney is a member in good standing of the Bar of that state, and (3) a statement signed by the Executive Director of Legal Aid Bureau, Inc., that the attorney is currently employed by or associated with an approved organized legal services program. *** (e) Revocation or suspension. At any time, the Court, in its discretion, may revoke or suspend authorization to practice under this Rule either by written notice to the attorney or by amendment or deletion of this Rule. (f) Special authorization not admission. Out-of-state atto rneys authorized to practice under this Rule are not, and shall not represent themselves to be, members of the Bar of this State, except in co nnection w ith practice tha t is authorized under this Rule. They shall be required to make payments to the Client Protection Fund of the Bar of M aryland and the Disciplinary Fund . 60 Rule 701(1)(b) outlines the qualifications an attorney who wishes to become a member of the bar of this District, must meet. It does not address the bar admission rules or require ments o f Ma ryland, the State in w hich it is lo cated. Unlike 28 U.S.C. § 517, however, Rule 701(1)(b) draws expre ssly a distinction between federal bar admittance and state bar admittance. This is significant and consistent w ith our approach to the fed eral/state practice issue. This Court has held tha t a lawyer adm itted to the federal bar in this State is not authorized to practice law in the State courts, unless also admitted to the Ma ryland Bar. As the Circ uit Cou rt noted , Kennedy, supra, 316 Md. 646, 561 A.2d 200 and Bridges, supra, 360 Md. 489, 759 A.2d 233, permit a non-Maryland lawyer, admitted to the bar of another state and to the federal bar, to maintain a federal practice in this State. They do not stand for the proposition that the maintenance of such a practice satisfies the practice of law requirement of Art icle V, § 4, how ever. Kennedy and Bridges, in fact, illustrate the difference between maintaining a federal practice in this State and practicing law in this State. In Kennedy, an attorney, who was a member of the federal bar and of the Court of Appeals of the District of Columbia, but not a member of the Maryland bar, was determined to have engaged in the unauthorized practice of la w in Maryland, when he advised clients and prepared documents in connection with matters involving state law and state legal issues, in his principal office, located in Maryland. 316 Md. at 663, 561 A.2d at 208. In holding that the attorney s argument turn[ed] on the substantive law applicable o r potentially applic able 61 to the client s matter, Id. at 662, 561 A.2d at 208, we differentiated between the federal practice he was permitted to have and the state law practice, which was not permitted: Kennedy may not utilize his admission to the bar of the federa l court in Maryland, or his adm ission in Washin gton, D.C ., as a shield against injunctive relief by asserting that he will operate a triage. He is not pe rmitted to sort through clients who may present themselves at his Maryland office and represent only those whose legal matters would require suit or defense in a Washington, D.C. court or in the federal court in Maryland because the very acts of interview, analysis and explanation of legal rights constitute practicing law in Maryland. For an unadmitted person to do so on a regular basis from a Maryland principal office is the un author ized pra ctice of law in M aryland. Id. at 666, 561 A. 2d at 210. Bridges was to like effect. In holding that an attorney admitted to practice in a number of jurisdictions, other than Maryland, including the Maryland federal bar, did not engage in the unauthorized practice of law in Maryland before his admission to the Maryland Bar, this C ourt examined the substance of Bridges activities. 360 Md. at 511, 759 A.2d at 245. We concluded that, rather than engaging in the unauthorized practice of law, he limited his practice in this S tate v ery sp ecif ically to federal cou rt and fe deral law . Id. See also Harris-Sm ith, supra, 356 M d. at 83- 84, 737 A. 2d at 573 (holding that an attorney admitted to the federal district court in the State, but not to the State bar, engaged in the unauthorized practice of law when she screened her firm s clients for her bankruptcy practice and held herself out to the public as a general pra ctitioner); Johnson, supra, 363 Md. at 628, 770 A. 2d at 148 (holding that an attorney admitted to the federal bar engaged in the unauthorized practice of law when he met with, an d advised , clients in a Marylan d office, m ade telepho ne calls to clien ts from his 62 Maryland home, ex ecuted retain er agreem ents in M aryland and d id not includ e his jurisdictional limitations on the firm s letterhead, wh ich bore only a Maryland ad dress). Perez, finally, relies on Sperry, supra, 373 U.S. 379, 83 S. Ct. 1322, 10 L. Ed. 2d 428, to support his argument that his federal bar membership allowed h im to practice law in this State and that pra ctice counts toward h is eligibility to be the A ttorney Gene ral. In Sperry, the Supreme Court of Florida held that the petitioner, a non-lawyer registered to practice before the United States Patent O ffice, had engaged in the unauthorized practic e of law by maintaining an office in the State, prepa ring legal do cuments, a nd by holdin g himself o ut to the public as a Patent Attorney. The Supreme Court of the United States reversed, holding: A State may not enforce licensing requirements which, though valid in the absence of federal regulation, give the State's licensing board a virtual power of review o ver the fed eral determ ination that a p erson or ag ency is qualified and entitled to perf orm certain functions, or which impose upon the performance of activity sanctioned by federal license additional conditions not contemplated by Congress. No State law can hinder or obstruct the free use of a license granted under an act of Congress. 373 U.S. at 385, 8 3 S. Ct. a t 1326,1 0 L. Ed . 2d at 43 2-33, quoting Pennsylvania v. Wheeling & Belmont Bridge Co., 54 U.S. 518, 566, 13 How. 518, 566, 14 L. Ed. 249, 269 (1815). Perez s reliance on Sperry, and, in effect, on the Supremacy Clause, is misplaced. While we agree with the prin ciples enun ciated in Sperry, in context, the case simply is inapposite. It is true that a non-lawyer was authorized to practice law in Florida pu rsuant to federal law and regulations; however, that practice was limited to a specialized federal practice 63 and federal law. What the Florida Supreme Court did, which the Supremacy Clause did not permit, was to prohibit what federal law allo wed; it denied Sperry the right to do in Florida what federal law permitted him to do there. On the other hand, the federal law that permitted Sperry to practice patent law, even though he was a non -lawyer, did not, and did not purp ort to, authorize Sperry to engage in a State law practice in Florida or to enable him to avoid the State bar admission requirements. The statute relevant to this case, 28 U.S.C. 517, and Local Rule 701(1)(b), as in Sperry, authorized Perez to p ractice in M aryland, but on ly to protect the inte rests of the United States or, in the case of the rule, in federal court; neither authorized, or purported to, the unrestricted practice of law or, more to the point, a Maryland State law practice . Unlike in Sperry, therefore, not construing Perez s federal practice, even that which occurred in Maryland and that may have involved Maryland issues, as the practic e of law in this State for p urposes o f his qualifying to be the Attorney General of this State in no way denied Perez the rights the federal statute and the local rule gave him . Just as the ruling in Sperry did not give the petitioner more rights than those that were already conferred upon him, our ruling simply does not confer on Perez rights to which he is not entitled by virtue of the federal statute and rule. To be clear, it is not this Court s holding that Perez has not practiced law for the requisite ten year period. Indeed, we agree that he has continuously been practicing law since his admission to the New York Bar in 1988. Rather, we decline to construe Article V, § 4 so as to credit all of that practice as complying with the provision s practiced Law in this 64 State re quirem ent. On this point, Perez contends that the framers were not concerned with the person occupying the office of the Attorney General having sufficient leg al experien ce in connection with Maryland, but, instead, that he or she w ere merely steeped in the law, of sufficient legal maturity to undertake the duties of the office. See 68 Opinions of the Attorney General at 54. He argues, moreover, that because his federal practice took place in Maryland , he has, in fac t, been practicing law in this State. We reject this argument. Article V, § 4, read in conjunction with the duties delineated in Article V , § 3, clearly reflects the intent of the framers that the Attorney General be a Maryland lawyer, w ith a specified amount of experience. The Attorney General s first and foremost duty is to prosecute and defend on the part o f the State all cases in the appellate courts of the State , in the Supreme C ourt of the United States or the inferior Federal Courts, by or against the State, or in which the State may be interested.... MD CON ST. art. V , § 3(a)(1) (emphasis added). In addition, the Attorney General is required to: (2) Investigate, commence, and prosecute or defend any civil or criminal su it or action or category of such suits or actions in any of the Federal Courts or in any Court of this State, or before administrative agencies and quasi legislative bodies, on the part of the State or in which the State may be interested, which the General Assembly by law or joint resolution, or the Governor, shall have directed or shall direct to be investigated, commenced and prosecuted or defen ded. (3) When required by the General Assembly by law or joint resolution, or by the Gove rnor, aid any State's Attorney or other authorized prosecuting officer in investigating, commen cing, and prosecuting a ny criminal suit or action or category of such suits or actions brought by the State in any C ourt of this State. (4) Give his opinion in writing whenever required by the G eneral As sembly 65 or either branch thereof, the Governor, the Comptroller, the Treasurer or any State's Attorney on any legal matter or subject. MD CONS T. art. V, § 3(a)(2)-(4) (empha sis added). In order for the Attorney G eneral to discharge the various duties prescribed by Arti cle V, § 3, he or she would have to be not merely steeped in the law, generally, but steeped in Maryland law, both as a member of its bar and as an active practitioner, who, as a result, has acquired a familiarity with the relevant procedures enveloped therein. Given the Attorney General s responsibility for litigation and transactions on behalf of the State in state courts, c oupled w ith his or her administrative duties, it was quite logical for the framers to require that candidates for the office of the Attorney General to have practiced law in the S tate for ten years, thereby ensuring that they are conversant and familiar with Maryland law and its practice. The critical holding in this case is that the relevant co ndition of e ligibility set forth in Article V, § 4, that the person have practiced law in this State for at least ten years, is not satisfied unless the person (1) has been admitted by this Court to practice law in Maryland for that period, and (2) pursuant to that admission, has, in fact, practiced here for that period. We do not mean , in this Opinion, to determine, in any categorical sense, what activity does or does not constitute practicing law in this State for purposes of Article V, § 4. T wo things are importa nt to no te, how ever. The first is to make clear that we are not creating a Federal-State dicho tomy. We are not holding that a person who has been admitted by this Court to practice in Maryland does not, in fact, practice here simp ly because he or she prac tices mostly, or even only, in the 66 Federal courts or de votes his or her practice to matters involving Federal law. The practice of law in Ma ryland does include practice in Federal court and before Federal agencies. Many cases in Federal court, and especially in the Bankruptcy courts, involve Maryland law. Lawyers admitted by this Court to practice in Maryland who are employed by Federal agencies in the State, such as the Un ited States Attorney s Office or the Federal Public De fender s Office, do indeed practice law in Maryland for purposes of Article, V, § 4. A lawyer who works for a Fed eral agenc y outside of M aryland, how ever, will not be regarded as practicing law in this State simply because he or she is authorized by Federal law to represent the Government in litigation in an y State, including Maryland, a nd may, on a few isola ted occasions over an extended period, have some involvement in a case here. The second point is that a person may be regarded as practicing law even if the person never appears in any court. Lawyers do not have to be litigators, and many are not. It is not the kind of la w or the n ature of t he practi ce th at co unts , but o nly that the person, for at least ten years, have been adm itted by this Cou rt to practice law in Maryland and that he or she, for that period of time, has, on a regular basis, done so. The problem for Mr. Perez, first, is that he was not admitted by this Court to practice in Ma ryland fo r ten years . Second, and equally significant, his work, in Washington, for the Department of Justice fr om 198 9 to 1999 and, on a p art-time basis , for the Senate Judiciary Committee, though it included an occasional involvement over that 10-year period with an unquantified but apparently small number of cases in Maryland, does not qualify as practicing 67 law in th is State f or that p eriod, w ithin the contem plation o f Articl e V, § 4 . For the forego ing reason s, we reve rse the Circu it Court s rulin g that Perez has, in fact, practiced Law in this State for ten years, thereby making him eligible to run for the office of the Attorney General of Maryland. Perez s admission to the Maryland Bar in 2001, coupled with his lengthy, but primarily, federal practice of law is not s ufficient to meet the requireme nts of the off ice of the A ttorney Gene ral as prescribed in Article V, § 4 of the Maryland Constitution . We, thus, h old Perez in eligible as a ca ndidate for Attorney General of Maryland in the 2006 Gubernatorial Primary Election.54 54 The con curring op inions mer it some resp onse. To b e sure, this Co urt, see supra at 50-5 2, and th e conc urrenc e by Judg e Eldrid ge, see Abrams v. Lamone, __Md. __, __ A.2d __ [Slip. Op. at 11-12] (Eldridge, J., concurring) (2007), have contrasted the constitutional requirements of judges and the State s Attorney, and used them as illustrative. Do ing so wa s never inten ded to indic ate, and it certain ly does not sug gest, that t he re quireme nts are interre lated or that the y- those fo r judge an d Sta te s A ttorn ey define tho se for the A ttorney Gene ral; they were se t for entirely diffe rent reason s and to serve entirely dif ferent purp oses. Our u se of the dif ferences in the langua ge used in those provisions was, as indicated, for comparison and illustrative purposes. The expression admitted to practice law , as oppos ed to prac ticed Law , is strikingly different, with the latter, contrary to the concurring opinion of Judge Eldridge that the language of the Maryland Constitution furnishes a stronger basis for this Court to review the profes sional activity of c andidates f or judicial of fice than it do es for the C ourt to review the professional activity of candidates for Attorney General, id. at 12, imposing an additional, if not a more stringent requirement, for those who would run for the office of the Attorney General. If the framers had intended for the Attorney General to be simply a member of the bar, they could, and most likely would, have said so. By using the word, practiced, they indicated that much more was required. The term , practice of law, as w e have alre ady acknow ledged, ha s, in the past, been d efined by this Co urt in a v ariety of w ays. See supra at 35-36. It is not inconceivable that judicial service m ight well be included w ithin those definitions. It would be incongruous for one who calls the balls and strikes on those who practice law and, thus, occupies an oversight, if not a superior, position not to be credited, for 68 qualific ation pu rposes , with pr acticing him or h erself. Ju dges, lik e law p rofesso rs, see 68 Opinions of the Attorney General at 65 (concluding that Dean of law school had practiced Law ), are continually involved, if not engaged, in the practice of law, and they use th eir legal k nowle dge an d skill on a daily bas is. See R.G.S., supra at 14, 36, 312 Md. a t 637-3 8, 541 A .2d at 98 3, citing Gazan v. H eery, 187 S.E. 371, 378 (Ga. 1936) (holding that judicial service may enhance [a candidate s] qualifications more than an active practitioner at the bar during the same period ). While defining the practice of law to include judging is not at all inconsistent with this Court s opinion in this case, it is an issue with which we need not concern ourselves at this time; neither of the candidates for the office of the Attorney General in this year s election were former judges, whose tenure as such is critical to the eligibility determination. The concurring opinions state that we have unnecessarily decided a constitutional issue. __Md. __, __ A.2d __ [Slip. Op. at 5] (Eldridge, J., concurring); __Md. __, __ A.2d __ [Slip. Op. at 1] (Harrell, J., concurring) (2007). Judge Eldridge s concurrence proffers that [t]he Court s unanimous decision that Mr. Perez is ineligible to be a candidate for Attorney General, on the ground that he has not been a member of the Maryland B ar for ten years, is d ispositive of th is case. The re is no reaso n for the C ourt to go beyond that holding and rule on a perceived additional constitutional requirement under the final clause of Article V, § 4. __Md. __, __ A.2d __ [Slip. Op. at 5] (Eldridge, J., concurring), while Judge Harrell states, Mr. Perez failed to satisfy the threshold requirement of Art. V, Sec. 4 of the Maryland Constitution in that he had not been admitted to the B ar of Maryland for at least ten years. Th at is as far as the Court need (and ought) go in order to decide the present case. The criterion that is dispositive of this matter is thus straightforward and easy for all to understand. __Md. __, __ A.2d __ [Slip. Op. at 1] (Harrell, J., concurring). The concurrences are incorrect. We have interpreted A rticle V, § 4, no thing more . Indeed, the o nly issue this case presents to th is Court i s a cons titutiona l issue - d etermin ing the m eaning of the p hrase w e have constru ed. The meaning of that phrase, although having two prongs, cannot be, and should not be, determined by parsing or otherwise separating those prongs. This Court s holding is that in order for one to be eligible to hold the office of the Attorney General, one must be a member of the Maryland Bar for at least ten years and must be a practitioner of law in Maryland for an identical requisite period. Supra at 1; see supra at 29, 55, 66. Perez s bar membership may well be independently dispositive in this case, but it is, in fact, but one prong of the interpretation of a single phrase, practiced Law in this State. Bar memb ership is not, as th e conc urrenc es wo uld hav e it, the on ly criterion for elig ibility. Judge E ldridge s co ncurrence spends a g reat deal of tim e focusing on who would not be e ligible to hold th e offic e of the Attorn ey Gene ral und er this C ourt s ru ling, see __Md. __, __ A.2d __ [Slip. Op. at 11, 19] (Eldridge, J., concurring), however, in doing 69 so, it constantly read s out of the in terpretation o f the pertinen t statutory provisio n the in this State lan guage. H e claims that the opinion s empha sis on being steeped in Maryland la w is not co nsistent with the nature o f many mo dern law practices, w hich in several respects is nation-wide or world-wide. Id. at 11. We, however, disagree. At no time ha s this Co urt stated , or infer red, that s omeo ne law fully prac ticing law , i.e. admitted to practice by this Court, in this State, whether solely Maryland, or a mixture of Maryland law, prov ided that it is for the requisite period, wou ld be ineligible to run for, and thu s, hold th e offic e of the Attorn ey Gene ral. See supra at 66-67. Judge E ldridge s co ncurrence goes on to state that the ph rase practic ed law is analogous to learned in the law. See __Md. __, __ A.2d __ [Slip. Op. at 12-14] (Eldridge, J., concurring) This Court addressed the issue of learnedness in the law, see supra at 52-5 3, and la rgely doe s not dis agree w ith wha t Judge Eldridg e is saying . Learnedness, however, simply goes to the bar membership requirement; it does not equal, and cannot be equated to, the practice of law. This is, once again, in line with the frame rs inten t. See supra at 53-5 4. The references in his concurring opinion to the Cons titutiona l debate s, see __M d. __, __ A.2d _ _ [Slip . Op. at 1 6-17] (E ldridge , J., concurring), in support of his position - as proof that practiced law is the equivalent of learnedness in the law - actually only solidifies this Court s position. Judge Eldridge s reference to the debates of the Constitutional Convention of 1864 reinforces the fact that the framers wanted an individual holding the office of the Attorney General to have practiced la w, as they us ed that phra se nume rous times. In fact, it would be impos sible for on e to giv e up so methin g, whic h he or s he has n ever do ne. Judge Eldridge s concurring opinion sp eaks to the quality of the individua l whom the fram ers were seekin g, see id. at 17-18, but that quality was based, by the framers own words, on the individ ual s pra ctice ex perienc e. See supra at 53-54. Moreover, the cases Judge Eldridge cites do not support the proposition that the two ph rases ar e analo gous. In fact, tho se case s, see, e.g., Opinion of the Justices, 181 So.2d 10 5, 108-10 9 (Ala. 196 5); Heathscott v. Raff, 973 S.W .2d 799, 80 3 (Ark. 19 98); In re Scarre lla, 221 N.W .2d 562 (M inn. 1974) ; In re Daly, 200 N.W.2d 913, 917, 920 (Minn . 1972) , cert. denied, 409 U.S . 1041, 93 S . Ct. 528, 34 L. Ed.2d 4 91 (1972 ); State ex rel. Jack v. Schmahl, 147 N.W . 425 (M inn. 1914) ; Pearce v. Meier, 221 N.W.2d 94, 98 (N.D. 19 74); Freiler v. Sch uylkill County, 46 Pa. Su per. 58 (19 10); Jamieson v. Wiggin , 80 N.W. 137 (S.D. 1899), are not contrary to what we have said on the issue. They simply define learned in the law in terms of b ar memb ership; they do n ot suggest, n ot to mention demonstrate, in any manner, that the phrase should, and can be, used interchangeably with practiced law. In addition, those cases cited by him which required that a candidate have practiced law similarly offer little assistance. In Whitmer v. Thurman, 247 S.E.2d 104 70 (Ga. 1978), the court applied a constitutional provision, also codified by statute, prohibiting a person from being a district attorney unless at the time of his election he shall have . . . practiced law for three years ne xt preceding his election. Th e trial court having ruled that he had not met the three-year practice requirement, the appellant proffered his admissio n to the Ca lifornia Ba r, arguing tha t it should be c onsidered in determining the practice time requirement. The Supreme Court of Georgia rejected that argument, reiterating its prior holding on the issue, that the language shall have practiced contemplated lawful practice and defined lawful practice as the practice of law as an active member of the State Bar of Georgia in good standing, quoting Wallace v. Wallace, 166 S.E.2d 718, 720 (Ga. 1969), and, particularly relevant to this case, stating: Appe llant's argume nt that the prac tice requirem ent include legal practice in other states directly conflicts with the judicial policy of Georgia that lawyers licensed to practice in other states will not be admitted to practice law in Georgia on the basis of comity. Rule 2-101 of the Rules and Regulations for Organization and Government of the State Bar of Georgia, Title 9 Appendix of the Georgia Code Annotated. It is clear that the intent of the legislature when it imposed this practice requirement was to insure that the individuals who were elected to the office of district attorney would be experienced in the prac tice of law before the courts in which they would be required to perform their functions as district attorneys. It w ould be co ntrary to this intent to a llow individ uals who have not been licensed to practice before our superior courts to include their practice time in other states as partial satisfaction of Code §§ 2-4201 and 24 -2901 , the three -year prac tice requ iremen t. Whitmer, 247 S.E.2d at 106. In Littlejohn v. Cleland, 308 S.E.2 d 186 (G a. 1983), the Suprem e Court of Georgia examined the qualifications of a candidate who was not [then] nor ha[d] he ever been a member of the State Bar of Georgia, 308 S.E.2d at 187, to run for office as a Justice of the Supre me Cou rt of Geo rgia. The S tate Constitu tion provide d that [n]o person sh all be a Justice of the Supreme Court ... unless, at the time of his election, he shall ... have practiced law for seven years. Id. (brackets in o riginal). The c ourt held the candidate constitutionally ineligible to run, explaining [s]ince a person may not practice law unless he or she is a member of the State Bar, a person cannot qualify for an office requiring law practice unless he or she is a member of the State Bar. Id. In context, the court did no t, as Judge Eldridge s concurring opinion would have it, define practiced law as requiring bar membership only. It was the candidate s complete lack of bar membership that led the court to c onclude th at the candid ate [did] n ot meet the c onstitutional re quiremen t to seek or hold the position of Associate Justice of the Supreme of Georgia, id., and that is 71 a far cry from defining what it means to practice law when someone is actually a member of the b ar of a p articular state. See also Daly, 200 N.W.2d at 914 (recognizing that none of the persons seekin g to become jud ge was adm itted to the Minnesota B ar). Furthermore, so far as a ppears in the record of th e cases cited in Judge E ldridge s concurring opinion, the only provision bearing on the meaning of the phrase being construed was the constitutional provision itself. Unlike in the case sub judice, there does not appear to have been other constitutional provisions containing different, but related, language wh ich bore on and inf ormed the mea ning of the subject prov ision. In the case sub judice, the interpretation of Article V, § 4, as stated earlier, is informed by Article V , § 10 an d Artic le IV, § 2 , supra at 50-52, n. 54 at 68, both of which define the qualification for office in terms of b ar admissio n, rather than practice of law. No t to consider th ese provisio ns wou ld run afou l of a basic p rinciple of co nstitutional interpretation. 72 IN THE COURT OF APPEALS OF MARYLAND No. 142 September Term, 2005 _________________________________________ STEPHEN N. ABRAMS, Appellant v. LINDA H. LAMONE, et al., Appellees _________________________________________ Bell, C.J. Raker *Wilner Cathell Harrell Greene Eldridge, John C. (Retired, Specially Assigned), JJ. _______________________________ Concurring Opinion by Eldridge, J., which Raker, J., joins; Harrell and Greene, JJ., join in Parts I and II only. _______________________________________ Filed: March 26, 2007 _________________________________________ *Wilner, J., now retired, participated in the hearing and conference of this case while an active member of this Court; after being recalled pursuant to the Constitution, Article IV, Section 3A, he also participated in the decision and adoption of this opinion. Eldridge, J., concurring: I agree with the result in this case on the ground that Mr. Perez has not been a member of the Maryland Bar for ten years. I disagree, however, with Chief Judge Bell s opinion which is joined by two other members of the Court. Article V, § 4, of the Constitution of Maryland sets forth the qualifications for a person to be eligible for the office of Attorney General of Maryland. Section 4 provides (emphas is added): Section 4. Qualifications of Attorney Gener al. No person shall be eligible to the office of Attorney General, who is not a citizen of this State, and a qualified voter therein, and has not resided and practiced Law in this State for at least ten years. The dispute in this case is over the meaning of the final clause in § 4, containing the single professional requirement that, to be eligible for the office of Attorney General, a person must have practiced Law in this State for at least ten years. Chief Judge Bell s plurality opinion takes the position that the final clause in § 4 actually contains two professional requirements, namely that a person, to be eligible for the office of Attorney General, (1) must have for ten years been a member of the Maryland Bar and (2) must have for ten years engaged in professional activity in Maryland which is sufficient, in this Court s view, to be deemed the practice of law in Maryland. The opinion states (slip opinion at 5354) (emphas is added): -2- Thus, we hold, a candidate for the office of the Attorney General must be both a member of the Maryland Bar for ten years and a practitioner of law in Maryland for ten years. See also slip opinion at 1. At other places, the plurality opinion says that a candidate for Attorney General must have more qualification than simply a bar membership and must be experienced in its [the law s] practice (slip opinion at 51). The three judges constituting the plurality do not agree that, if Perez had been a member of the Maryland Bar, rather than the New York bar for the past 17 years and possessed the same professional qualifications, he would be eligible to hold the office of Attorney General (id. at 51, n.47). The plurality opinion states that a candidate for the office of the Attorney General must be an experienced attor ney (id. at 53, n.49, emphas is added), and that a person, to be eligible for the office of Attorney General, must be not merely steeped in the law, gen erall y, but steeped in Maryland law, both as a member of its bar and as an active practitioner (id. at 64). Chief Judge Bell concludes that, even if Mr. Perez had been a member of the Maryland Bar from 1989 to 1999, his work for the Department of Justice and the Senate Judiciary Committee does not qualify as practicing law in this State for that period, within the contemplation of Article V, § 4" (id. at 66). I. As previously indicated, I agree with the plurality that the final clause of Article V, § 4, of the Maryland Constitution means that, to be eligible for the office of Attorney General, a Maryland resident is required to have been a member of the -3Maryland Bar for ten years. It is true that § 4 does not expressly require Maryland Bar membership; con sequ ently, in my view, § 4 is to some extent ambiguous. Nevertheless, when § 4 is read in conjunction with the constitutional duties of the Attorney General prescribed in Article V, § 3, of the Maryland Constitution, admission to the Maryland Bar would seem to be required. The constitutional duties of the Attorney General, which have remained essentially unchanged since 1867, could only be performed by a member of the Maryland Bar. Furthermore, except for an out-of-state attorney being given permission by the court to try or argue one specific case, the concept of an attorney legally practicing law in a state, without being a member of that state s bar, was likely unknown in 1864 and 1867 when the language of Article V, § 4, was formulated and adopted. The statute authorizing a United States Department of Justice attorney to represent the United States in, inter alia, the courts of any State, was not enacted until 1870. See Act of June 22, 1870, Ch. 150, 16 U.S. Statutes At Large 162, 163 (1870). Cases dealing with the concept of legally practicing law in certain fields, in a state where the attorney was not a member of the bar, came much later. See, e.g., Sperry v. Florida, 373 U.S. 379, 83 S. Ct. 1322, 10 L. Ed.2d 428 (1963); Attorney Grievance Commission v. Bridges, 360 Md. 489, 508-511, 759 A.2d 233, 243-245 (2000); Kennedy v. Bar Ass n, 316 Md. 646, 661-668, 561 A.2d 200, 208-211 (1989), and cases there cited. Con sequ ently, the final clause of Article V, § 4, should be read as if it said and [admitted to] practice [] Law in this State for at least ten years. Since -4Mr. Perez has not been a member of the Maryland Bar for ten years, he does not at this time meet the professional eligibility requirement set forth in the final clause of Article V, § 4, of the Maryland Constitution. 1 In my view, this is the only proper basis for this Court s prior order that Mr. Perez does not meet the eligibility requireme nts specified in Article V, § 4, of the Maryland Constitution. II. Prel imin arily, it is puzzling why the three-judge plurality ventures beyond the holding that Mr. Perez fails to meet the eligibility requireme nts of Article V, § 4, on the ground that he has not been a member of the Maryland Bar for ten years. This Court s established policy is to decide constitutional issues only when necessary. Insurance Commissioner v. Equitable , 339 Md. 596, 614, 664 A.2d 862, 871 (1995), quoting Mercy Hospital v. Jackson, 306 Md. 556, 565, 510 A.2d 562, 566 (1986). See also Christopher v. Department of Health , 381 Md. 188, 217, 849 A.2d 46, 63 (2004); Murrell v. Baltimore, 376 Md. 170, 191 n.8, 829 A.2d 548, 560 n.8 (2003); Baltimore Sun v. Baltimore, 359 Md. 653, 659, 755 A.2d 1130, 1 During the oral argument before this Court in the present case, counsel for the appellee Perez was asked by the Court whether Mr. Perez had challenged in the trial court, or was challenging in this Court, the validity under the United States Constitution of the final clause in Article V, § 4, of the Maryland Constitution, providing that the Attorney General must have resided and practiced Law in this State for at least ten years. Counsel s attention was specifically directed to the federal constitutional equal protection principles applied in Board v. Goodsell, 284 Md. 279, 286-293, 396 A.2d 1033, 1036-1040 (1979), and the Supreme Court opinions and other opinions discussed in Goodsell. See also Green Party v. Board of Elections, 377 Md. 127, 162-163, 832 A.2d 214, 234-235 (2003). Counsel for Mr. Perez responded by stating that Mr. Perez had not challenged in the trial court, and was not challenging in this Court, the validity of Article V, § 4, under the Constitution of the United States. Consequently, no issue regarding the federal constitutional validity of Article V, § 4, is directly presented in this case. -51134 (2000), and cases there cited. The Court s unanimous decision that Mr. Perez is ineligible to be a candidate for Attorney General, on the ground that he has not been a member of the Maryland Bar for ten years, is dispositive of this case. There is no reason for the Court to go beyond that holding and rule on a perceived additional constitutional requirement under the final clause of Article V, § 4. The plurality opinion, however, goes beyond the dispositive issue of Maryland Bar membe rship and states that Mr. Perez, even if he had been a ten-year member of the Maryland Bar, would still be ineligible under Article V, § 4, because his professional activity did not constitute practicing law in this State for ten years. (Slip opinion at 66). The plurality s justification for unneces sarily deciding this latter constitutional issue is that [w]e have interpreted Article V, § 4, nothing more and that the bar membe rship issue is but one prong of the interpretation of a single phrase, practiced Law in this State. (Slip opinion at 68, n.54). Under the circumstances here, this is not a valid justification for deciding the second constitutional issue. Many state and federal constitutional requireme nts are set forth as single phrases. For example, the constitutional phrases due process of law or equal protection of the laws or twice put in jeop ardy are each single phrases. Nevertheless, if a court interprets and applies one of these phrases to decide that particular action violates the constitutional provision in one respect, and if that decision is dispositive of the case before the court, it is not necessary for the court -6to further interpret the single phrase and decide whether the action violates the same phrase in some other respect. Exploring all aspects of a constitutional phrase may be appropriate for a treatise or law review article. It does not, however, reflect the type of judicial restraint which should characterize appellate opinions. Not only does Chief Judge Bell s opinion reach a constitutional issue unn eces saril y, but it rules upon an issue that was not presented to the Court. The appellant-petitioner, Steven N. Abrams, presented the following two questions to the Court: QUESTIONS PRESENTED I. Does the Constitution of Maryland require that a candidate for Attorney General be admitted to practice law before all of the courts of the State courts of Maryland for at least ten years prior to his or her commencing their term as Attorney General? II. Does the State Board of Elections have any duty to inquire into the representations made by a candidate for any office in Maryland when the candidate certifies under oath to the State Board of Elections that he or she meets the Maryland Constitutional requirements? Mr. Abrams s sole constitutional argument was that Mr. Perez was ineligible to be Attorney General because he had not been a member of the Maryland Bar for ten years. Mr. Abrams stated in his brief (emphas is added): In short, because the phrase practiced Law in this State has a well-understood, common, and ordinary meaning that necessarily implies admission to practice law in Maryland, that meaning should be adopted, and there should be no need for further analysis. -7- During oral argument before this Court, the following colloquy occurred: Judge Cathell : If a person passes the Maryland Bar and is admitted to the Maryland Bar by this Court, has a job right out of law school with a federal judge in the District of Columbia, goes directly to the District of Columb ia and works for that federal judge. Then, gets a job directly from there with some federal agency in the District of Columb ia and has never, twenty years later, actually practiced law in the geographical confines of Maryland, but he has been a member of the Maryland Bar. Mr. Abrams: And maintained his membe rship over that ten year period. Judge Cathell : Granted. Mr. Abrams: Right. Judge Cathell : Is he practicing law in Maryland? Mr. Abrams: I would argue, your Honor, that he is both practicing law, and he meets the requirement of initiating the practice of law in Maryland and continuou sly practicing law under that requirement for that ten year period. . . . There was no contention before this Court that Article V, § 4, embodied two distinct professional requirements. The only constitutional issue raised and argued in this Court was whether Article V, § 4, required membe rship in the Maryland Bar for ten years. Under the circumstances of this case, the judges of this Court should not reach any other constitutional issue. See Maryland Rules 8-131 and 8-504; Simmons v. State, 392 Md. 279, 292-293 n.1, 896 A.2d 1023, 1031, n.1 (2006); Sweeney v. Savings First Mortgage, 388 Md. 319, 325 n.8, 879 A.2d 1037, 1040 n.8 (2005); Oak Crest v. Murphy, 379 Md. 229, 241, 841 A.2d 816, 823 (2004); -8Moosavi v. State, 355 Md. 651, 660, 736 A.2d 285, 290 (1999); Langworthy v. State, 284 Md. 588, 595-596, 399 A.2d 578, 582-583 (1979), cert. denied, 450 U.S. 960, 101 S.Ct. 1419, 67 L.Ed.2d 384 (1981). III. Although I do not agree with three judges reaching a constitutional issue unn eces saril y, and particularly one which was not raised on appeal, I shall comment on that issue only because the [plu rality] of the Court has decided to do so. Montgomery County v. McNeece, 311 Md. 194, 213, 533 A.2d 671, 680 (1987) (concurring opinion). I strongly disagree with Chief Judge Bell s second constitutional ruling that, in addition to membe rship in the Maryland Bar for ten years, a ten-year resident of Maryland, to be eligible for the office of Attorney General, must also have engaged in such professional activity that, in the judgment of the judi ciary, renders the person a practitioner of law in Maryland for ten years or an active practitioner who is steeped in Maryland law. (Slip opinion at 54, 64). This position, adopted by three members of the Court, is neither supported by the language of Article V, § 4, nor supported by the constitutional history of that provision. The position also violates the principle that provisions should not be interpreted in a manner leading to unreason able results. Numerous long-time Maryland lawyers could be disqualified from being Attorney General if the views of the three judges were to prevail in the future. Another result of the plurality opinion would be that this Court, every four years, might have to evaluate the nature or -9quality of the legal work performed in Maryland over a ten-year period, by each candidate for Attorney General, to determine whether such work meets the standard of actively practicing Maryland law in this State. Moreover, as Judges Harrell and Greene intimate in their concurring opinion, the plurality s requireme nts concerning the nature or quality of the law practice by a ten-year member of the Maryland Bar, in order for that member to be a candidate for Attorney General, would be difficult, if not impossible, for the State Board of Elections to administer. Fina lly, the plurality s interpretation of the state constitutional provision might raise questions as to its validity under the federal constitution. (a) Article V, § 4, setting forth the single professional requirement that the Attorney General must have practiced law in this State for at least ten years, contains no language furnishing any basis for a court to review and evaluate the tenyear professional experience of a Maryland Bar member seeking to become Attorney General, or reject a candidate for the office of Attorney General on the grounds that he was not sufficiently active as a practitioner or not sufficiently steeped in Maryland law. A member of the Maryland Bar representing the United States Government is practicing law. 2 The plurality opinion, at one place, correctly acknowledges that the phrase 2 It should be noted that Article 2 of the Maryland Declaration of Rights mandates that federal law shall be the Supreme Law of the State . . . . Consequently, federal law is Maryland law. See Ponte v. Investors Alert, 382 Md. 689, 698-701, 857 A.2d 1, 6-8 (2004), and cases there cited. -10 practice of law encompasses a variety of activities (slip opinion at 35). The opinion goes on to discuss several of this Court s opinions holding that the meaning of the phrase varies depending upon the context. (Id. at 35-41). Then, somewhat inco nsis tentl y, the plurality opinion states that the meaning of the phrase practice law in this State has remained consistent and that the phrase is clear and unam biguou s. (Id. at 41, 43 n.42). Later, the opinion adopts a narrow definition of the phrase, taking the position that Mr. Perez would not have been practicing law in this State even if he had been a member of the Maryland Bar for ten years (slip opinion at 66), and that only a lawyer who is steeped in Maryland law as an active practitioner (id. at 64) is eligible to be Attorney General. This Court s prior opinions have consistently taken the position that there are many different definitions of the phrase practice of law, depending upon the context and the circumstances. See In re Application of Mark W., 303 Md. 1, 7-18, 491 A.2d 576, 579-584 (1985) ( Numerous definitions of what constitutes practice of law are to be found . * * * These definitions have arisen in a variety of circum stances . * * * [A]ttem pts to define the practice of law have not been particularly successful ), and cases there cited. The predominant professional activities of many lawyers, such as legal research, teaching law, etc., are regarded as the practice of law, although such activities would not constitute the unauthorized practice of law if done by non-lawyers. As indicated prev ious ly, the plurality s limited definition of the phrase might render a large number of Maryland lawyers ineligible to be Attorney General. Moreover, despite the plurality s -11disclaimer, the opinion s emphas is on being steeped in Maryland law is not consistent with the nature of many modern law practices, which in several respects is nation-wide or world-wide. As earlier discussed, the final clause of Article V, § 4, when considered in light of Article V, § 3, reasonab ly means that a candidate for the office of Attorney General must be admitted to practice[] Law in this State for a least ten years. Except for the ten-year period, this interpretation makes the professional qualification for Attorney General the same as the professional qualifications for judges 3 and State s Attorneys.4 Nothing in the language of Article V, § 4, requires a 3 Article IV, § 2, of the Maryland Constitution provides as follows: Section 2. Qualifications of judges. The Judges of all of the said Courts shall be citizens of the State of Maryland, and qualified voters under this Constitution, and shall have resided therein not less than five years, and not less than six months next preceding their election, or appointment, as the case may be, in the city, county, district, judicial circuit, intermediate appellate judicial circuit or appellate judicial circuit for which they may be, respectively, elected or appointed. They shall be not less than thirty years of age at the time of their election or appointment, and shall be selected from those who have been admitted to practice law in this State, and who are most distinguished for integrity, wisdom and sound legal knowledge. (Emphasis added). 4 Article V, § 10, of the Maryland Constitution states: Section 10. Qualifications of State s Attorneys. No person shall be eligible to the office of State's Attorney, who has not been admitted to (continued...) -12professional qualification over and above membe rship in the Maryland Bar for ten years.5 In fact, the language of the Maryland Constitution furnishes a stronger basis for this Court to review the professional activity of candidates for judicial office than it does for the Court to review the professional activity of candidates for Attorney General. Article IV, § 2, of the Maryland Constitution, unlike Article V, § 4, contains more than one professional qualification for judges. Article IV, § 2, requires that district, circuit, and appellate judges be selected from those [1] who have been admitted to practice law in this State, and [2] who are most distinguished for integ rity, wisdom and sound legal know ledge. No one has ever suggested that this Court is authorized to review the careers of judicial candidates to determine if they meet the qualitative standards contained in the last clause of Article IV, § 2. Instead, it is for the Governor and/or the voters to decide upon such qualifications. Sim ilarly, if a ten-year Maryland resident, seeking the office of Attorney General, has for ten years been a member in good standing of the Maryland Bar, it should be for the voters to decide whether the candidate s professional activity is sufficient for him or her to be elected to the office of Attorney General. 4 (...continued) practice Law in this State, and who has not resided, for at least two years, in the county, or city, in which he may be elected. 5 Article V, § 4, contains two ten-year requirements, namely residence in Maryland for ten years and membership in the Maryland Bar for ten years. The plurality would impose a third tenyear requirement, i.e., activity for ten years which meets the three judges concept of practicing law. -13The words practiced law, or the more frequently used phrase learned in the law, found in state constitutions, have regularly been construed to mean simply admission to the bar of the particular state involved. To the extent that such constitutional phrases have been viewed as providing for a higher level or quality of legal experience, courts have held that the matter is for the voters and/or appointing authorities and not a subject for judicial review. See, e.g., Opinion of the Justices, 279 Ala. 38, 40-42, 181 So.2d 105, 108-109 (1965) ( The phrase learned in the law as used by the framers of the Constitution did not contemplate[] that . . . qualifications of a candidate . . . should be determined by a referee or jury in a contested election case, but means lawyers admitted to practice in Alabama ); Heathsc ott v. Raff, 334 Ark. 249, 257, 973 S.W.2d 799, 803 (1998) ( Based on the American and English use of the phrase, . . . we hold that the constitutional qualification phrase learned in the law means an attorney licensed to practice law in the state ); 6 Littlejohn v. Cleland, 251 Ga. 597, 598, 308 S.E.2d 186, 187 (1983) (Constitutional phrase shall . . . have practiced law for seven years means that a person cannot qualify . . . unless he or she is a member of the State Bar ); Whitmer v. Thurman, 241 Ga. 569, 570-571, 247 S.E.2d 104, 106 (1978) (Constitutional eligibility requirement that district attorney shall have practiced law for three years means a person must have been licensed to practice before our superior courts ); Wallace v. Wallace, 225 Ga. 102, 166 S.E.2d 718 (1969) (same); In re 6 As the Supreme Court of Arkansas discussed in the Heathscott case, 334 Ark. at 253, 973 S.W.2d at 802, similar language appeared in the Magna Carta of 1215, and the specific phrase learned in the law was used in a 1344 English statute. -14Candidacy of Daly , 294 Minn. 351, 357, 362, 200 N.W.2d 913, 917, 920, cert. denied, 409 U.S. 1041, 93 S. Ct. 528, 34 L. Ed.2d 491 (1972) ( To be learned in the law means that the person must have been admitted to the bar and must not be suspended or disbarred); In re Scarrellam in, 300 Minn. 500, 221 N.W.2d 562 (1974) (same); State ex rel. Jack v. Schmahl, 125 Minn. 533, 147 N.W . 425 (1914) (same); Pearce v. Meier, 221 N.W.2d 94, 98 (N.D. 1974) ( Our view is that the phrase learned in the law is synonymous with and means admitted to the bar or admitted to practice by the Supreme Court of our State ); Freiler v. Schuylkill County , 46 Pa. Super. 58 (1910) (same); Jamieson v. Wiggin , 12 S.D. 16, 80 N. W. 137 (1899) (same). The type of qualitative judicial review, under Chief Judge Bell s opinion, of a candidate s professional experience to determine his or her eligibility for constitutional office, is unprecedented as a matter of Maryland law. It is contrary to the cases in other jurisdictions. As long as a candidate for Attorney General has been a member of the Maryland Bar, in good standing, for ten years, the judiciary should not further review the candidate s professional activ ity. Such review is a matter for the voters. (b) The constitutional history relied on in the plurality opinion does not support its conclusion that the final clause of Article V, § 4, contains two distinct professional qualifications, both of which are judicially reviewable. Although I agree that the constitutional history supports the holding that a candidate for -15Attorney General must have been a member of the Maryland Bar for ten years, the history actually refutes the plurality s position that there is an additional professional qualification, pursuant to which this Court may evaluate the professional activity of an Attorney General candidate, who is a ten-year member of the Maryland Bar, to determine whether the candidate is sufficiently experienced and is an active practitioner who is steeped in Maryland law. Chief Judge Bell points out that an earlier proposed version of Article V, § 4, contained two expressed professional requirements, namely that the Attorney General have been admitted to practice law in the State and that the Attorney General had practiced law for a certain number or years. (Slip opinion at 46). The plurality opinion then observes that the two professional eligibility requireme nts were merged into a single requireme nt (ibid.). The opinion goes on to say that it interprets the framers actions as an attempt to avoid being repetitive (id. at 48). I fully agree with the plurality that the bar admission requirement and the practice of law requirement were viewed as meaning the same thing and were merged into a single requirement to avoid repetition. Later in the opinion, however, Chief Judge Bell takes the position that there are two separate professional eligibility requireme nts and that the final clause of Article V, § 4, means that the Attorney General must be both a member of the Maryland Bar for ten years and practitioner of law in Maryland for ten years. (Id. at 53-54). This later position taken by the plurality is flatly inconsistent with its earlier position based on the -16legislative histo ry. In my view, the sparse legislative history of the provision indicates that there is a single professional eligibility requirement in Article V, § 4, which is membe rship in the Maryland Bar for ten years. The plurality also relies upon the debates at the 1864 Constitutional Convention regarding the salary of the Attorney General and the ten-year bar membership. Thus Delegates Negley and Bond stated (The Debates of the Constitutional Convention of 1864 at 1460): M R . N EGLEY. I am as much in favor of keeping down salaries as anyb ody. But you better strike out this provision altogether than to put in an inadequa te sala ry. Because if you put in an insufficient sala ry, you cannot get the services of a man whose services will be worth anything. And rather than have a second or third rate man in the office, you better strike out the provision entir ely. Three thousand dollars a year is little enough for such an officer. They are the younger members of the bar who are elected State s attorneys, and they will be continually calling upon the attorney general for his opinion, and perhaps require his personal assistance at the trial. He is to be besides the legal adviser of the governor, comptroller, treasurer, and even of the legislature; he will have his hands full. Three thousand dollars a year is not too large. Let us have salary enough to secure a good officer, or let us have none at all. M R . B OND . In my judgmen t, a salary of three thousand dollars a year is little enough for a good lawyer. The attorney general, by this report, is forbidden to receive any other fee or compensation whatever, except his sala ry. As has been well remarked by the gentleman from Washington county (Mr. Negle y,) you better strike out this provision entir ely, than not get a good man in this office; and you cannot get a good one, unless you give him a good comp ensatio n. Delegate Stirling commented (id. at 1460-1461): -17 M R . S TIRLING. I think the views of my friend from Washington (Mr. Mayhugh) are correct so far as the general principle is concerned. I have myself on several occasions voted here not to put these salaries too high. I have no objection to putting the salary of the attorney general at $2,500, though I think that is full low. But I suggested that sum, because I know there is an indisposition to pay large salaries. *** Now you must have for attorney general a man who is accustomed to trying cases, or he will not be fit for the office. And any man who has a good practice trying cases makes a considerab le sum of money every year by trying cases against the State. But if such a man accepts this office, he must give up entirely that portion of his practice. Taking all these things into consideration, I believe a competent attorney general at three thousand dollars a year will be a saving to the State at least a thousand dollars a year. Later, with regard to the ten-year requireme nt, Delegate Smith emphasized the importance of the position and the type of lawyer who should be Attorney General. It is important to keep in mind what these debates related to and what they did not. The debates concerned the salary needed to attract good and experienced lawyers and concerned the ten-year bar admission requireme nt. The delegates were not suggesting that a ten-year member of the Maryland Bar must have a certain type or quality of experience in order to be eligible to seek the office of Attorney General. On the con trary, they were afraid that, if the salary were too low, the highest quality Maryland lawyers would not be candidates for the office and that lesser quality attor neys would be candidates and would be elected Attorney General. The need to attract higher quality candidates by setting a high salary is -18inconsistent with the notion that a court could declare ineligible ten-year members of the Maryland Bar based upon the court s evaluation of their professional experience. Instead of prescribing qualitative experience requireme nts which might be judicially reviewable, the framers of Article V, § 4, sought to attract high quality applicants for the office of Attorney General by setting what was then considered a high salary and by a ten-year Maryland bar membe rship requireme nt. Con sequ ently, the constitutional history discussed in the plurality opinion undermines the opinion s conclusion that a court can review the quality or nature of the professional activity of a ten-year Maryland Bar member. (c) This Court, time after time, has emphasized that, in interpreting enactmen ts and other legal provisions, we give them their most reasonab le interpretation, in accord with logic and common sense, and that we avoid constructions that are illogical, unreasonable, or inconsistent with common sense. Johnson v. Nationwide, 388 Md. 82, 89, 878 A.2d 615, 619 (2005), quoting Greco v. State, 347 Md. 423, 429, 701 A.2d 419, 422 (1997), and Frost v. State, 336 Md. 125, 137, 647 A.2d 106, 112 (1994). The Court refrains from a construction of enactmen ts that leads to consequences [that] would be quite strange . Ponte v. Investors Alert, 382 Md. 689, 717, 857 A.2d 1, 18 (2004). See also, e.g., Stoddard v. State, 395 Md. 653, 663, 911 A.2d 1245, 1260 (2006); Twine v. State, 395 Md. 539, 550, 910 A.2d 1132, 1138 (2006); Oakland v. Moun tain Lake, 392 Md. 301, 316, 896 A.2d 1036, 1045 (2006); Gwin v. Motor Vehicle Administration, 385 Md. 440, 462, 869 A.2d -19822, 835 (2005). This principle is violated by the plurality s interpretation of Article V, § 4, requiring something more than ten-year Maryland residency and tenyear membe rship in the Maryland Bar for one to be Attorney General. The plurality opinion could result in the exclusion of numerous Maryland lawyers who have been, for ten years or more, Maryland residents and members of the Maryland Bar. For example, it would apparently render ineligible for Attorney General ten-year Maryland residents and Maryland lawyers who, for part of the tenyear period, were employed by federal government agencies in the District of Columb ia or law firms in the District of Columb ia or in nearby states.7 The plurality opinion, if ever adopted by the majority of this Court, could also lead to an unprecedented and totally unreason able non-judicial function to be performed by this Court every four years. To reiterate, the opinion takes the position that, even if Mr. Perez had been a member of the Maryland Bar, rather than the New York [B]ar for the past 17 years and possessed the same 7 Another group of ten-year Maryland Bar members who might be ineligible to be Attorney General under the plurality opinion consists of appellate, circuit, and district judges who did not practice law in Maryland, in accordance with the plurality s standards, for ten years prior to becoming judges. Although the Chief Judge s opinion says that [i]t is not inconceivable that judicial service might well be included in its definition of practice of law (slip opinion at 67, n.54), it is clear that judges are by law prohibited from practicing law. Maryland Code (1974, 2006 Repl. Vol.), § 1-203(a) of the Courts and Judicial Proceedings Article, provides in pertinent part as follows: [N]o judge may during his term of office practice law, maintain an office for the practice of law, or have any interest in an office for the practice of law, whether conducted in whole or in part by himself or by others. * * * -20qualific ations, his practice would not qualify as practicing law in this State for [ten years], within the contemplation of Article V, § 4. (Slip opinion at 51, n.47, 66). This conclusion is based on the plurality s evaluation of the nature of Mr. Perez s professional activ ity, upon discounting Mr. Perez s law practice in Maryland as an attorney for the United States Department of Justice, and upon the view that appearance in Maryland state courts to attend to the interests of the United States is not the practice [of] law in this State for purposes of Article V, § 4. (Id. at 57). The type of professional evaluation indulged in by the plurality could well set a precedent for future elections for Attorney General. Every four years, long-time members of the Maryland Bar, filing certificates of candidacy for the office of Attorney General, could be challenged in court on the theory that their ten years or more professional activity in Maryland was qualitatively insufficient for them to be eligible Attorney General candidates. In light of the nature of such cases, they will alw ays find their way to this Court. I cannot believe that the framers of Article IV or Article V, § 4, of the Maryland Constitution ever contemplated that the courts should be involved in this type of politically-charged evaluation activ ity. This is for the electorate; it is not the appropriate business of the judi ciary. (d) It is a settled principle that a court will, whenever reasonab ly possible, construe and apply [an enactmen t] to avoid casting serious doubt upon its constitutionality. Burch v. United Cable Television, 391 Md. 687, 703, 895 A.2d -21980, 989 (2006), quoting Yangming Marine Transport v. Revon Produc ts U.S.A ., Inc., 311 Md. 496, 509, 536 A.2d 633, 640 (1988). [T]his Court will prefer an interpretation that allows us to avoid reaching a constitutional questio n. Nationsbank v. Stine, 379 Md. 76, 86, 839 A.2d 727, 733 (2003). As Chief Judge Murphy for the Court stated in Curran v. Price, 334 Md. 149, 172, 638 A.2d 93, 104-105 (1994), [i]f a [provision] is susceptible of two reasonab le interpretations, one of which would involve a decision as to its con stitu tion ality, the preferred construction is that which avoids the determination of constitu tionality. See also, e.g., Rios v. Montgomery Cou nty, 386 Md. 104, 121, 872 A.2d 1, 10 (2005); Ponte v. Investors Alert, supra, 382 Md. at 718, 857 A.2d at 18; Edwards v. Corbin , 379 Md. 278, 293-294, 841 A.2d 845, 854 (2004); Montrose Christian School v. Walsh, 363 Md. 565, 594-595, 770 A.2d 111, 128 (2001). It is also a well-established principle of constitutional law that [a] state regulation is invalid . . . if it . . . discriminates against the Federal Government or those with whom it deals. North Dakota v. United States, 495 U.S. 423, 435, 110 S.Ct. 1986, 1995, 109 L.Ed.2d 420 (1990), and cases there cited. See also, e.g., Harper v. Virginia , 509 U.S. 86, 113 S.Ct. 2510, 125 L.Ed.2d 74 (1993); Davis v. Michigan Department of Treasury, 489 U.S. 803, 817, 109 S.Ct. 1500, 1509, 103 L.Ed.2d 891 (1989) (state enactment favoring retired state and local government employees over retired federal employees held unconstitutional). Under the plurality opinion, a Maryland attorney employed by the Maryland Attorney General s office, a Maryland State s Attorney s office, a Maryland county -22attorney s office, or another Maryland government agen cy, would be practicing law in Maryland for purposes of eligibility under Article V, § 4. On the other hand, a Maryland attorney employed by the United States Department of Justice or other federal agency located in the Nation s Capital, and working in Maryland as well as elsewhere, would not be practicing law in Maryland under the plurality opinion. The discrimination between state government employment and federal government employme nt, under the plurality s interpretation of Article V, § 4, and would present a serious issue as to the constitutiona lity of Article V, § 4, under the United States Constitution. Under settled principles, an interpretation of Article V, § 4, which avoids this federal constitutional issue would be preferred. Judge Raker joins this opinion, and Judges Harrell and Greene join Parts I and II of this opinion. IN THE COURT OF APPEALS OF MARYLAND No. 142 September Term, 2005 ______________________________________ STEPHEN N. A B R A M S v. LINDA H. LAMONE, et al. ______________________________________ Bell, C.J. Raker *Wilner Cathell Harrell Greene Eldridge, John C. (Retired, specially assigned), JJ. ______________________________________ Concurring Opinion by Wilner, J. ______________________________________ Filed: March 26, 2007 *Wilner, J., now retired, participated in the hearing and conference of this case while an active member of this Court; after being recalled pursuant to the Constitution, Article IV, Section 3A, he also participated in the decision and adoption of this opinion. -1- I concur with and join Chief Judge Bell s Opinion and write separately only to respond to Judge Eldridge s peculiar conclusions that the Constitution does not mean what it plainly says and that, even if it did, the Court shouldn t say so. Article V, § 4 of the Constitution states with marvelous clarity and simplicity that a person is not eligible to the office of Attorney General who has not practiced law in this State for at least ten years. Now, one may fairly debate whether, for purposes of that provision, certain conduct constitutes the practice of law in this State teaching law at a law school, for example, or serving as a judge or arbitrator, or administrative law judge or hearing examiner. But to conclude that it does not require the practice of law at all in Maryland is simply extr aord inar y. Judge Eldridge thinks that all that is required is that a person have been admitted to the Maryland Bar for ten years. That is not what the Constitution says, however. As Chief Judge Bell points out, in other sections, the Constitution explicitly makes membe rship in the Maryland Bar the effective criterion. In defining the qualifications of the Attorney General, however, the People deliberately chose a different requireme nt. Upon the recommendation of the Convention delegates, they determined that, to be eligible for the office of Attorney General, a person must have actually practiced law in this State for ten years. Under Judge Eldridge s view, a person could pass the Bar Examination, be admitted to practice, open a liquor store, never do anything that could con ceiv ably, under any definition, constitute the practice of law, become politically active, and ten years later be elected as Attorney General of Maryland. The notion that that is what the Convention delegates or the People had in mind in 1864 and 1867 is really absurd. It is belied by the plain language of the Constitutional provision and is belied as well by the debates in the Constitutional Conventions. The challenge to Mr. Perez s candidacy was that he had not practiced law in Maryland for ten years. The focus on his not being admitted to the Maryland Bar for that period was part of the argument by Abrams that Perez had not lawfully practiced law here, for, except to the extent that a person is permitted by Federal law to appear in Federal courts and before Federal agencies without being admitted to the Bar of the State in which such appearances are made or is admitted pro hac vice to participate in a particular case, one must ordinarily be admitted to the Bar of Maryland by this Court before he or she may lawfully practice law here. That Mr. Perez had not been admitted to practice for the requisite ten years is strong evidence that he had not, in fact, practiced law here for that period. Chief Judge Bell correctly concludes that the two go together; the Constitution anticipates that a candidate for Attorney General will have lawfully practiced law in Maryland for ten years, and that necessarily requires that the candidate have been admitted to practice here for that period. Because the condition of eligibility is that the candidate have practiced law, and because the sole challenge to Mr. Perez s candidacy is that he had not done so, it is necessary that this Court examine and -3- resolve whether he engaged in lawful practice in Maryland for that period. Merely holding that Mr. Perez had not been admitted for ten years does not answer the question presented and therefore does not adequate ly or properly decide the case. Judge Eldridge suggests, without any support, that a ten-year practice requirement may create Federal Constitutional issues because it discriminates against persons in Federal Government employme nt. I am not aware that the Supreme Court has ever held, or even intimated, that a State could not impose such a requirement for its chief legal officer, chosen to advise and represent the State and its officials and agencies, but even if such a requirement did raise such issues, they would be raised as well by a requirement that the person practice law here, or even be admitted to practice law here, for one year. The conjured ghost of a Federal issue is, to me, the reddest of red herrings. If the General Assemb ly believes that the requirement should be changed that ten years is too long or that practiced law in this State should be better defined -- it may propose to the People an appropriate amendment to Article V, § 4. -4- IN THE COURT OF APPEALS OF MARYLAND No. 142 September Term, 2005 STEPHEN N. A B R A M S v. LINDA H. LAMONE, et al. Bell, C.J. Raker *Wilner Cathell Harrell Greene Eldridge, John C. (retired, specially assigned), JJ. Concurring Opinion by Harrell and Greene, JJ. Filed: March 26, 2007 *Wilner, J., now retired, participated in the hearing and conference of this case while an active member of this Court; after being recalled pursuant to the Constitution, Article IV, Section 3A, he participated also in the decision and adoption of this opinion. W e agree generally with Parts I and II of Judge Eldridge s concurring opinion. Mr. Perez failed to satisfy the threshold requirement of Art. V, Sec. 4 of the Maryland Constitution in that he had not been admitted to the Bar of Maryland for at least ten years. That is as far as the Court need (and ought) go in order to decide the present case. The criterion that is dispositive of this matter is thus straightforward and easy for all to understand. The State Board of Elections may administer such a requirement by reference to the objective Bar admission records of this Court.
Some case metadata and case summaries were written with the help of AI, which can produce inaccuracies. You should read the full case before relying on it for legal research purposes.
This site is protected by reCAPTCHA and the Google Privacy Policy and Terms of Service apply.
