Dismissal Was Not an Implied Ruling on a MD Rule 1-341 Sanctions Motion

Plaintiffs filed a Maryland Rule 1-341 motion for sanctions and an order to docket foreclosure on Defendant’s real property.  Later, they filed a motion for voluntary dismissal.  The motion was granted and the case dismissed without prejudice.  However, the court “never entered an order specifically addressing the motion for sanctions.”

Plaintiffs then filed a motion requesting a ruling on the Rule 1-341 sanctions motion.  The trial court denied that motion, holding that, because the matter was dismissed, all of the pending motions were deemed moot.

The appellate court disagreed.  McClain v. Savage, 2026 WL 48226 (Appl. Ct. Md. Feb. 20, 2026)(unreported; per curiam).[1] It vacated the sanctions ruling and remanded to consider the sanctions motion.

The sole issue on appeal was “whether the court erred in declining to rule on [plaintiffs’] motion for sanctions.”  In the Court’s words, appellees argued “that the court implicitly denied appellant’s motion for sanctions when it dismissed the foreclosure case.” The Court disagreed, writing:

To be sure, the denial of a motion may be implied by the entry of a final judgment or of an order inconsistent with the granting of relief. But Rule 1-341 motions are “independent proceeding[s] supplemental to the original proceeding,” and the conclusion of the original proceeding does not divest the circuit court of jurisdiction to consider such motions…. In other words, the issue of whether appellant was entitled to sanctions was entirely collateral to the merits of the foreclosure action and could thus have been resolved after the termination of the foreclosure action. As such, we decline to view the dismissal of the foreclosure action as an implicit denial of appellant’s motion for sanctions. [emphasis added].

Rule 1-341 motions seek remedial sanctions for bad faith or unjustified proceedings:

In any civil action, if the court finds that the conduct of any party in maintaining or defending any proceeding was in bad faith or without substantial justification, the court, on motion by an adverse party, may require the offending party or the attorney advising the conduct or both of them to pay to the adverse party the costs of the proceeding and the reasonable expenses, including reasonable attorneys’ fees, incurred by the adverse party in opposing it.

They are distinct from discovery sanctions under Rule 2-433.

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[1] This is a per curiam opinion. Under Rule 1-104, the opinion is not precedent within the rule of stare decisis nor may it be cited as persuasive authority.