No Right of Redemption in Baltimore City: The Four-Judgment Rule Explained for Landlords (2026)

Maryland gives tenants one of the strongest pay-to-stay rights in the country: until the sheriff has physically completed the eviction, a tenant with a Failure to Pay Rent judgment can cancel it by paying everything owed. For most Baltimore City landlords dealing with a chronically late tenant, that means winning in rent court four, five, six times and never actually regaining possession.

No Right of Redemption (NRR) is the exception built for exactly that pattern. And Baltimore City runs it on a stricter count than the rest of the state: four prior judgments in 12 months, not three. This is the deep dive: what the rule is, how to plead it on DC-CV-082, what evidence proves it, and what actually changes on eviction day.

NRR is not a punishment for owing rent. It is the statute's answer to serial redemption: the tenant who treats rent court as a payment plan, redeeming at the door every quarter. Baltimore City just makes the landlord prove the pattern one judgment longer.

The Baseline: Redemption Runs Until Execution

The right of redemption lives at Md. Code, Real Property § 8-401. After a judgment for possession in an FTPR case, the tenant can "redeem" the tenancy by tendering all past-due rent, all court-determined late fees, and all court-awarded costs, in cash, certified check, or money order. The right runs to the moment of actual execution. Not to the warrant filing, not to sheriff scheduling: to the moment possession physically changes hands. A tenant with a certified check at the door while the sheriff is standing there has a valid tender.

We cover the tender mechanics, acceptable payment forms, and partial payment traps in Right of Redemption in Maryland: A Landlord's Guide. This post is about the exception.

The Exception: Three Judgments Statewide, Four in Baltimore City

Section 8-401's redemption provision does not apply when the tenant has accumulated enough prior FTPR judgments inside a 12-month window:

• Statewide default: 3 prior judgments of possession for unpaid rent in the 12 months before the current filing. The fourth case in a year can be filed with an NRR request.
• Baltimore City: 4 prior judgments under the city's stricter local rule (Baltimore City's public local landlord-tenant laws). NRR is available starting with the fifth case in a year.

This is not folklore; it is printed on the court form itself. The tenant notice on the current DC-CV-082 reads: "If there have been three (3) prior judgments (four (4) in Baltimore City) against you in rent court for this property in the past twelve (12) months, the judgment of possession will be without right of redemption."

Note two things buried in that sentence. First, the form frames the count around judgments in rent court for this property: the prior cases are the ones you filed against this tenant at this tenancy, not unrelated judgments from a previous address. Second, the count is of judgments, not filings. A case you filed and the tenant cured before judgment does not add to the count. A case dismissed for a defective notice does not add to the count. This is one more reason clean filings matter: every dismissal is not just lost time, it is a missing tally mark on the road to NRR.

How to Plead NRR on DC-CV-082

NRR is requested on the complaint, at filing, or not at all. The current form gives it a dedicated line. Line 9 of DC-CV-082 states:

"The landlord requests foreclosure of the tenant's rights of redemption due to prior judgments; prior case numbers and judgment dates within the past 12 months."

Followed by space for the case numbers and judgment dates. To plead it properly:

1. List every qualifying prior case number and its judgment date. In Baltimore City you need at least four; statewide, three.
2. Verify each entry against the docket in Maryland Judiciary Case Search before filing. Transposed case numbers are a common self-inflicted wound.
3. File as usual at Baltimore City rent court, 500 N. Calvert Street (relocated from 501 E. Fayette Street effective October 14, 2025). The Baltimore City summary ejectment filing fee is $60 under the current District Court cost schedule, DCA-109 (Rev. 03/2026), plus a $5 service fee per location and $5 per tenant if personal service is requested.

The rest of the complaint follows the normal rules covered in our field-by-field DC-CV-082 guide: every tenant named, filing-date amounts only, late fees capped at 5%, licensing and lead certificate current. Baltimore City judges check the prerequisites before they ever reach line 9, and an expired rental license or lead paint certificate dismisses the NRR case exactly as fast as any other.

One thing you cannot do: add NRR later. If judgment enters without the request, the tenant holds the redemption right for that case, full stop. The next filing is your next opportunity.

Proving the Prior Judgments at the Hearing

Line 9 is a pleading, not proof. At the hearing, expect the judge to want the docket history substantiated:

• Case Search printouts for each prior case, showing the case number, the parties, the judgment for possession, and the judgment date. Certified copies from the clerk are stronger if the count is likely to be contested.
• Your own case file for each prior judgment: the complaint and the judgment notice, if you have them.
• A one-page summary listing each case number, filing date, judgment date, and outcome. Judges process NRR requests faster when the pattern is legible at a glance.

The judgment section of the current DC-CV-082 gives the court a dedicated disposition option: judgment for possession entered with "No right of redemption" checked. That checkbox is the whole game. If it is checked, the eviction proceeds regardless of tender. If it is not, the tenant can still pay and stay.

What NRR Changes on Eviction Day, and What It Doesn't

It is worth being precise, because NRR changes exactly one thing.

What changes: payment no longer stops the eviction. A tenant who arrives with a money order for the full judgment amount has no statutory right to cancel the execution. You may accept the payment and call off the eviction if that outcome works for you, but the choice is yours, not the tenant's.

What does not change:

• The appeal window. The tenant can still appeal within 4 days of judgment, and a bonded appeal stays the warrant until the appeal is resolved.
• The warrant timeline. You still wait the statutory 7 days after judgment (treated in practice as 7 business days under Md. Rule 1-203) before filing DC-CV-081, still must request the warrant within 60 days of judgment, and the warrant must still be executed within 60 days of issuance.
• Baltimore City's eviction-date notice. The city requires notice of the scheduled eviction date: 14 days by first-class mail with a certificate of mailing, plus 7 days of posting at the property. NRR does not shorten either clock.
• Eviction day logistics. The sheriff still executes, you still need your crew and the logistics covered in Maryland Eviction Day: What Happens When the Sheriff Arrives.

In other words, NRR does not accelerate anything. It removes the last-second reversal. For a landlord who has been through four redemptions in a year, that is the entire point: the fifth judgment is finally final.

Is NRR Worth Requesting?

If the tenant qualifies, almost always yes, for three reasons:

1. It costs nothing extra to plead. Line 9 is on the form you are filing anyway. The only added work is pulling the docket history.
2. It changes tenant behavior even when unused. A tenant facing an NRR judgment knows that this time, paying at the door will not work. Serial redeemers often cure earlier, or negotiate a real move-out, once the redemption right is off the table.
3. The alternative is indefinite repetition. Without NRR, there is no legal ceiling on how many times a tenant can redeem. The statute's only exit from that loop is the prior-judgment count.

The discipline it demands is record-keeping. NRR eligibility is built one clean judgment at a time, which means every notice served correctly, every complaint accurate, every judgment documented. A platform that keeps the full case history in one place is not a luxury here; it is how you prove the pattern when the count finally reaches four.

How EvictPro Handles Baltimore City NRR Cases

EvictPro tracks every case outcome in your portfolio, which means the prior-judgment history that NRR runs on is already assembled when you need it. For Baltimore City landlords:

• Free Notice of Intent (DC-CV-115) at evictpro.us/notice-of-intent: the required 10-day predicate for every FTPR filing, NRR or not.
• Filing with Court: $99, base court filing fee included, Maryland's per-tenant service fee billed at cost. The complaint carries the line 9 NRR request with each prior case number and judgment date.
• Full Eviction Service package: $749 for NRR cases, covering the case end to end: notice, filing, court hearing representation by an experienced Maryland agent, tenant response handling, warrant of restitution, sheriff scheduling, and eviction day coordination, with every court fee included in the package stages.
• Baltimore City compliance checks built in: rental license and lead certificate verification before filing, the $60 city filing fee applied correctly, and the city's 14-day mail plus 7-day posting eviction-date notice handled on schedule.

Whether you manage one rowhouse or five hundred units, the pattern is the same: the landlords who get NRR granted are the ones whose paper trail was clean for the whole preceding year.

Related reading:

• Right of Redemption in Maryland: A Landlord's Guide to the Tender Rule
• How to Fill Out DC-CV-082: A Field-by-Field Maryland Filing Guide
• Maryland Eviction Day: What Happens When the Sheriff Arrives
• Baltimore City vs. Baltimore County Evictions
• How an Expired Baltimore Rental License Gets Evictions Dismissed

Building toward an NRR case starts with a clean judgment history, and a clean judgment history starts with a compliant notice: