Gregory Smith v. Wakefield, LP

For three centuries, Maryland law has provided that an action seeking payment of back rent for a residential lease is to be brought before the expiration of a three-year period of limitations. That period of limitations is currently reflected in Maryland Code, Courts & Judicial Proceedings Article ("CJ"), § 5-101. In recent decades, the question has arisen whether the period of limitations for such an action may be extended to 12 years by converting a residential lease into a "contract under seal" so that it might be regarded as a "specialty" - a type of action for which another statute, CJ §…