County, 366 Mich. 250, 114 N.W.2d 205, 208 (1962). 19 . State v. Putman, 552 A.2d 1247, 1249 (Del.Super.Ct.1988). 20 . Poynter, 177 A.2d at 646. See 56 Am.JuR.2d Municipal Corporations, Etc. § 329 (2005). 21 . See Fogle v. H & G Restaurant, Inc., 337 Md. 441, 654 A.2d 449, 460 (1995) ("A state law may preempt a local law or regulation in one of three ways: 1) by conflict, 2) expressly, or 3) by implication.”). The Court of Appeals of Maryland defined implied preemption as "when the legislature ... so forcibly expresses] its intent to occupy a specific field of regulation that the acceptance of the doctrine of pre-emption by implication is compelled.” Id. 22 . See, e.g., Goodell v. Humboldt County, 575 N.W.2d 486, 493 (Iowa 1998). 23 . See Hayward v. Gaston, 542 A.2d 760, 767 (Del.1988) (<HOLDING>). See also Goodell, 575 N.W.2d at 493 ("Implied
holding that the kent county zoning ordinance was not preempted by chapter 90 of the delaware code because they were not inconsistent holding that because the board of aldermen only decided whether to grant a variance under the zoning ordinance the superior court erred by determining the question of the constitutionality of the zoning ordinance which was never raised or considered by the board of aldermen holding that setback and height requirements in zoning ordinance were not preempted by the solid waste act because they related to land use and not operation of a landfill holding that county of delaware was not a person for purposes of fca liability holding that the city was not estopped from enforcing a zoning ordinance when a zoning department employee mistakenly stamped the plaintiffs application for a license to operate a laundromat to indicate compliance with the ordinance