A drive-in movie theater sued an adjoining farm, alleging that the light emanating from the farm constituted a private nuisance damaging the theater. A jury awarded the theater $830,000 in damages to construct a fence to block the light, but the trial court granted the farm’s motion for judgment notwithstanding the verdict. The trial court found that there was insufficient evidence for the jury to find a private nuisance. On appeal the court affirmed, ruling that the standard commercial lights employed by the farm were very typical and ordinary lights used by a business. They could not, as a matter of law, have constituted an unreasonable and substantial interference with the theater’s property rights. A private nuisance action could not be maintained based upon a plaintiff’s special sensitivities. Rather, the inconvenience would have to be one that is “objectively unreasonable” to the ordinary plaintiff. Blue Ink v. Two Farms, Inc., No. 01487, 2014 Md. App. LEXIS 73 (Md. Ct. Spec. App. Jul. 30, 2014).