Legal Opinion

Hallam v. New Life Evang. Baptist Church

Court of Appeals of Maryland

Decided June 22, 2026No. 15/25Published

1Opinion of the Court

William L. Hallam v. New Life Evangelical Baptist Church, Inc., et al., No. 15, September Term, 2025. Opinion by Biran, J. MARYLAND RULES 14-211 AND 14-305 – FORECLOSURE – POST-SALE EXCEPTIONS – The Supreme Court of Maryland held that a borrower who contends a lien is invalid or that a lienholder otherwise lacks the right to foreclose on property for any reason must raise such a defense under Maryland Rule 14-211 before the foreclosure sale occurs, provided the borrower knows or reasonably should know the pertinent facts giving rise to such a defense before the sale. A borrower may not raise…

2Cases cited19 opinions

  1. Barbre v. PopeCourt of Appeals of Maryland · 2007
  2. Lockshin v. SemskerCourt of Appeals of Maryland · 2010
  3. BOARD OF ED. OF BALTIMORE CTY. v. Zimmer-RubertCourt of Appeals of Maryland · 2009
  4. Anderson v. Council of Unit Owners of Gables on Tuckerman CondominiumCourt of Appeals of Maryland · 2008
  5. Bottini v. Dept. of Finance, Montgomery Co.Court of Appeals of Maryland · 2016

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