Ben-Davies & Moore v. Blibaum & Associates, P.A.Annotate this Case
When a landlord sues a tenant for breach of contract based on a residential lease and the trial court enters judgment in the landlord’s favor and the judgment includes damages for unpaid rent and other expenses, a post-judgment interest rate of six percent applies pursuant to Md. Code Ann., Cts. & Jud. Proc. (“CJ”) 11-107(b) rather than the post-judgment interest rate of ten percent under CJ 11-107(a).
Landlords initiated actions for breach of contract against Tenants. The district court entered judgments in Landlords' favor, but the judgments did not delineate the portions thereof that were comprised of unpaid rent, as opposed to other expenses. Thereafter, Debt Collector engaged in collections activity on Landlords’ behalf. Debt Collector sought to apply the post-judgment interest rate of ten percent under CJ 11-107(a). Tenants filed complaints against Debt Collector, arguing that CJ 11-107(b) applied. The federal district court certified the question of which legal rate of post-judgment interest on the judgment awarded applied. The Supreme Court answered as set forth above.