This case addressed the claims of Etta Haynie Maddox that she should be allowed to sit for the bar examination and receive admission to the bar despite a Maryland state statute limiting bar admission to “male citizens of Maryland.” The Maryland Court of Appeals denied her application, stating that the court did not have the power to enact legislation. Thus until the legislative branch declared that women could be admitted to the bar, the court did not have any power to admit Maddox.