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

Baltimore City requires 4 prior FTPR judgments in 12 months for No Right of Redemption, not the statewide 3. How to plead and prove NRR in court.

- Published: 2026-09-29
- Author: Jordan Walsh
- Canonical: https://www.evictpro.us/blog/baltimore-city-nrr-four-judgment-rule

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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.

  - **3 vs 4**: prior judgments for NRR (statewide default vs Baltimore City)
  - **12 months**: lookback window (judgment dates before current filing)
  - **Line 9**: where NRR is pled (on DC-CV-082, at filing only)

> 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 short version:**
  Statewide, a landlord can request judgment without right of redemption when the tenant
  has 3 prior judgments of possession for unpaid rent in the prior 12 months. Baltimore
  City requires 4. Request it on line 9 of DC-CV-082 at filing, listing each prior case
  number and judgment date, and bring Case Search printouts or certified copies to the
  hearing. If granted, payment no longer cancels the eviction. The appeal window, warrant
  timeline, and Baltimore City's eviction-date notice rules stay exactly the same.

## The Baseline: Redemption Runs Until Execution

The right of redemption lives at
[Md. Code, Real Property § 8-401](https://mgaleg.maryland.gov/mgawebsite/Laws/StatuteText?article=grp&section=8-401&enactments=false).
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](/blog/right-of-redemption-maryland-tenant).
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](https://www.mdcourts.gov/sites/default/files/import/district/forms/civil/dccv082.pdf)
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.

**Count judgment dates, not filing dates:**
  The 12-month lookback runs from the current filing back to each prior judgment date.
  A case filed 13 months ago but decided 11 months ago counts. A judgment entered 12
  and a half months ago does not. Pull the exact judgment dates from the docket before
  you claim the count on line 9; an overstated count is an easy credibility hit at the
  hearing.

## 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)](https://www.mdcourts.gov/sites/default/files/court-forms/dca109.pdf),
   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](/blog/dc-cv-082-how-to-fill-out):
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.

**NRR cases are what the Full Eviction Service is for**: https://www.evictpro.us/pricing

## 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](/blog/maryland-eviction-day-sheriff).

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](/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.

**The Baltimore City NRR rule in one paragraph:**
  Baltimore City requires 4 prior judgments of possession for unpaid rent within the 12
  months before filing; the rest of Maryland requires 3. Request NRR on line 9 of
  DC-CV-082 at filing, list each prior case number and judgment date, and prove them
  with docket records at the hearing. If granted, payment no longer cancels the
  eviction. Appeal rights, the 7-business-day warrant wait, the two 60-day warrant
  clocks, and Baltimore City's 14-day mail plus 7-day posting eviction notice all remain
  unchanged.

**Not legal advice**: This article is general educational information about Maryland landlord-tenant law and procedure. It is not legal advice and does not create an attorney-client relationship. Laws, court fees, and local rules change over time. For advice on your specific situation, consult a licensed Maryland attorney or a qualified housing counselor.

**Related reading:**

- [Right of Redemption in Maryland: A Landlord's Guide to the Tender Rule](/blog/right-of-redemption-maryland-tenant)
- [How to Fill Out DC-CV-082: A Field-by-Field Maryland Filing Guide](/blog/dc-cv-082-how-to-fill-out)
- [Maryland Eviction Day: What Happens When the Sheriff Arrives](/blog/maryland-eviction-day-sheriff)
- [Baltimore City vs. Baltimore County Evictions](/blog/baltimore-city-vs-baltimore-county-eviction)
- [How an Expired Baltimore Rental License Gets Evictions Dismissed](/blog/baltimore-rental-license-dismissed-eviction)

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

**Start every case with a free, compliant Notice of Intent**: https://www.evictpro.us/notice-of-intent

## Frequently asked questions

### How many prior judgments does No Right of Redemption require in Baltimore City?

Four prior judgments of possession for unpaid rent entered against the tenant in the 12 months before the current filing. The statewide default under Md. Code, Real Property section 8-401 is three prior judgments in 12 months; Baltimore City applies a stricter local rule requiring four. The current DC-CV-082 form's tenant notice states the rule directly: three prior judgments, or four in Baltimore City, within the past twelve months.

### What does No Right of Redemption actually change?

Normally a tenant with an FTPR judgment can cancel the eviction at any moment before it is physically executed by tendering all past-due rent, court-determined late fees, and court costs in cash, certified check, or money order. When judgment is entered without right of redemption, that escape hatch closes: even full payment before eviction day does not stop the eviction. The landlord may still choose to accept payment and stop, but is no longer required to.

### How do I request NRR on the DC-CV-082 complaint?

Line 9 of the current DC-CV-082 states: 'The landlord requests foreclosure of the tenant's rights of redemption due to prior judgments' and provides space for the prior case numbers and judgment dates within the past 12 months. Fill that line in at filing, and bring proof of each prior judgment to the hearing. If line 9 is blank when judgment enters, the tenant keeps the redemption right for that case.

### Can I add NRR after the judgment is entered?

No. NRR must be requested on the original complaint at the time of filing. Once a judgment is entered with the redemption right intact, the landlord cannot retroactively remove it. If the tenant redeems and then defaults again, the next DC-CV-082 is where NRR can be requested, assuming the tenant has accumulated the required prior judgments by then.

### What counts as a prior judgment for the NRR count?

A judgment of possession for unpaid rent entered against the tenant within the 12 months before the current filing. The current DC-CV-082 tenant notice frames the count as judgments in rent court for this property in the past twelve months. Dismissed cases, cases resolved before judgment, and cases outside the 12-month lookback do not count. Pull the docket history from Maryland Judiciary Case Search and bring printouts or certified copies showing each case number, judgment date, and outcome.

### Does NRR affect the tenant's right to appeal?

No. The tenant can still appeal an FTPR judgment to the Circuit Court within 4 days, and an appeal with the required bond stays the eviction until the appeal is decided. NRR removes the pay-to-stay option; it does not shorten the appeal window, change the warrant timeline, or eliminate Baltimore City's eviction-date notice requirements.

### Does an NRR judgment change the warrant of restitution process?

The mechanics are the same: after judgment the landlord waits the statutory 7 days (treated in practice as 7 business days), files the DC-CV-081 petition for warrant of restitution within 60 days of judgment, and the warrant must be executed within 60 days of issuance. Baltimore City also requires notice of the scheduled eviction date: 14 days by first-class mail with certificate of mailing plus 7 days of posting. What changes with NRR is eviction day itself: payment no longer cancels it.

### How much does it cost to file an FTPR case in Baltimore City?

Under the current District Court cost schedule (DCA-109, Rev. 03/2026), the Baltimore City summary ejectment filing fee is $60, compared with $50 in the rest of Maryland. Baltimore City also charges a $5 service fee per location, with an additional $5 per tenant if personal service is requested. Baltimore City rent court now sits at 500 N. Calvert Street, relocated from 501 E. Fayette Street effective October 14, 2025.
