Rohrbaugh v. Estate of Stern

MURPHY, Chief Judge.

Maryland Code (1981 Repl.Vol.), § 8-203(f)(4) of the Real Property Article, provides that “[i]f the landlord, without a reasonable basis, fails to return any part of the security deposit, plus accrued interest, within 45 days after the termination of the tenancy, the tenant has an action of up to threefold of the withheld amount, plus reasonable attorney’s fees.” 1 We granted certiorari to resolve an ambiguity in this statutory provision: whether the amount subject to treble damages is the entire amount withheld by the landlord or only the amount withheld without a…