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We do not interpret contractual language in a vacuum. Instead, we interpret that
language “in context, which includes not only the text of the entire contract but also the
contract’s character, purpose, and the facts and circumstances of the parties at the time of
execution.” Credible Behav. Health, 466 Md. at 394 (internal quotation marks omitted)
(quoting Ocean Petroleum, Co. v. Yanek, 416 Md. 74, 88 (2010)). Although providing
relevant context may necessarily require consultation of evidence beyond the “four
corners” of the contract itself,
This Court has, in the past, sometimes stated that in the absence of ambiguity, its
review of a contract is limited to the “‘four corners’ of the agreement.” Impac Mortg.
Holdings, Inc., 474 Md. at 506 (quoting Cochran v. Norkunas, 398 Md. 1, 17 (2007)); see
also, e.g., Smith v. Johns E. Co., 269 Md. 267, 276 (1973) (stating that the objective test
“limits the Court to the ‘four corners’ of the contract” (quoting Ruppert v. Cumberland
Brewing Co., 269 Md. 56, 61 (1973)); Walton v. Mariner Health of Maryland, Inc., 391
Md. 643, 660 (2006) (stating that “when seeking to interpret the meaning of a contract our
search is limited to the four corners of the agreement”). In context, those statements were
addressed to extrinsic evidence of the parties’ subjective intent, such as documentation of
their course of dealings in negotiating the contract at issue or other agreements, not to
information about the context in which the contract at issue was entered. See, e.g., Ocean
Petroleum, Co., 416 Md. at 86, 88 (noting both that a court looks to the “four corners” of
an agreement and that contract provisions must be considered in context, which includes
the facts and circumstances of the parties at the time of execution); John L. Mattingly
Const. Co. v. Hartford Underwriters Ins. Co., 415 Md. 313, 326, 334 (2010) (stating that
contract interpretation is limited to the “four corners” of an agreement and explaining that
“extrinsic evidence” for consideration after finding of ambiguity could involve facts about
party negotiations, such as which party proposed the form contract used and the other form
contracts that were available); Impac Mortg. Holdings, Inc., 474 Md. at 506, 534 & n.32
(stating that contract interpretation is limited to the four corners of the agreement and later
explaining that “information on the context as to the type of contract or transaction can be
informative,” though the “particular subjective intent of the parties” is not part of that
context absent a finding of ambiguity); see also Calomiris v. Woods, 353 Md. 425, 436
(1999) (“[W]hile evidence of prior intentions and negotiations of the parties is
inadmissible, the parol evidence rule would not bar a court from considering the context of
the transaction or the custom of the trade in a determination of ambiguity.”).