Maryland Security Deposit Judgment Collection — How to Collect After Winning

You sued your former landlord (or tenant) over a security deposit in Maryland District Court and won. The judge entered judgment in your favor. Now the other side isn't paying. This is one of the most common small claims scenarios in Maryland — and one where people most often assume the court will handle collection for them.

It won't. Maryland District Court enters the judgment. Collecting it is entirely your job.

The Typical Security Deposit Collection Scenario

Most security deposit judgments involve a tenant who sued their landlord for wrongful withholding. Under Maryland Real Property Article § 8-203, if the landlord withholds any portion of the deposit, the landlord must send an itemized list of damages and costs within 45 days. If the landlord, without a reasonable basis, fails to return any part of the deposit plus accrued interest within 45 days, the tenant may recover up to three times the amount withheld plus reasonable attorney's fees.

Less commonly, a landlord wins a judgment against a former tenant for unpaid rent or damages exceeding the deposit. Either way, the enforcement process is the same once you have a judgment.

Start With the 10-Day Wait

Maryland Rule 3-632(a) imposes an automatic 10-day stay after judgment entry. No enforcement action — no garnishment, no lien, no writ of execution — can happen during this period. Use those 10 days to figure out what assets the other side has.

Collecting From a Former Landlord

If your judgment is against a landlord or property management company, you often have an advantage: they're a known business with identifiable bank accounts and, in many cases, rental income flowing through those accounts.

Bank garnishment (Form DC-CV-060) is usually the fastest route. If you know where the landlord banks — check your old rent payment records, cancelled checks, or lease agreement — file a Request for Garnishment of Property Other Than Wages. The $10 filing fee plus a $60 sheriff/constable service fee or $20 if the clerk mails it gets the writ served on the bank, which holds funds up to your judgment amount.

Wage garnishment (Form DC-CV-065) works if the landlord is an individual who works a regular job. Property management companies and LLCs don't have "wages" to garnish, so this tool is only useful against individual landlords with employers.

Judgment lien against rental property is a strong long-term play. File Form DC-CV-035 to transmit the judgment to the Circuit Court Land Records in the county where the landlord's property sits. The $15 filing fee covers the Notice of Lien; the Circuit Court records it. The lien may affect the landlord's ability to sell or refinance the property. For landlords who own real estate (which they obviously do), this creates real pressure to pay.

Collecting From a Former Tenant

Collecting from a former tenant is typically harder. They've moved, their forwarding address may be unreliable, and they may have limited attachable assets.

Wage garnishment is usually the strongest tool here. If you know where the tenant works, file Form DC-CV-065. Maryland law allows garnishment of the lesser of 25% of disposable earnings or the amount exceeding 30 times the state minimum wage ($450/week).

Limits on court discovery: For a small-claims judgment against an individual, Maryland courts cannot compel the former tenant to answer interrogatories or appear for an examination (CJP § 11-704). Other post-judgment discovery rules apply outside that limit.

Costs vs. Recovery

Security deposit judgments in Maryland are capped at $5,000 on the small claims docket (though treble damages under § 8-203 can push the actual amount awarded higher if the case was filed on the regular District Court civil docket up to $30,000). Enforcement costs add up:

• Garnishment filing: $10 + $60 sheriff/constable service fee or $20 clerk-mail service per writ
• Judgment lien filing: $15 (Form DC-CV-035)
• Oral examination: $10 + $60 sheriff/constable service fee or $20 clerk-mail service; an individual cannot be compelled to attend for a small-claims judgment

For a $1,500 judgment, spending $50–$100 on enforcement is reasonable. For a $500 judgment, the math gets tighter — but the legal rate is generally 10% annually; a judgment for residential rent accrues at 6%.

Our Maryland judgment collection guide covers every enforcement tool with the exact forms, fees, and deadlines — including a section on collecting from business entities like property management companies.

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