How does a Maryland landlord lawfully end a tenancy, and when may a tenant leave early?

The State termination rules in the Real Property Article reach rental property everywhere in Maryland. Property in Baltimore City is governed by those rules and, alongside them, by subtitle 9 of the Code of Public Local Laws of Baltimore City, which supplies its own rules for serving and wording a termination notice, its own 30-day tenant's notice to quit, a 72-hour move-out notice, a schedule of grounds carrying shorter or longer periods, and holdover damages of up to double the rate of rent. The State's paragraph on the tenant's oral notice does not apply in the City at all. Everywhere else in Maryland the Real Property Article stands alone.

The switch is simply where the property sits. Section 8-402, subsection (c)(3)(ii) removes Baltimore City from the tenant's oral-notice paragraph by name, and section 8-406, subsection (b) recognizes a repossession complaint brought under the City's own subtitle 9 beside one brought under the State sections; the Court of Appeals applied the City's 60-day notice rule on that footing. A reader whose property lies inside the City limits reads both bodies of law and takes the stricter requirement where they differ; a reader outside them reads the Real Property Article alone. The City's own provisions are carried on the locality pages rather than here.

The switch changes: ending a month-to-month tenancy; a tenant who stays past the end; and how a termination notice is delivered.

Landlord: 60 days (given before the end of a rental period). Tenant: 30 days.

Every period in the schedule is measured backwards from the end of the tenancy, not forwards from the day the notice is delivered. A 60-day notice given in the middle of a month therefore does not end a month-to-month tenancy 60 days later; it ends it at the next expiration of the tenancy that is at least 60 days away, so a notice given on March 10 for a tenancy that runs to the last day of each month ends the tenancy on May 31 rather than May 9. The same backwards count governs the 90-day and 180-day yearly tiers, both week-to-week tiers, and the shorter foreclosure track, and the tenant's periods are counted the same way.

The termination date must fall on a rental-period boundary or a rent-due date.

Tiers: Sixty days for a month-to-month tenancy or a written lease for a stated term longer than one week. Ninety days for a tenancy from year to year, including a tobacco farm tenancy. One hundred eighty days for any other farm tenancy from year to year. Seven days for a week-to-week tenancy where the parties have a written lease, and 21 days where they do not. A separate and shorter foreclosure track gives 30 days for a month-to-month or week-to-week tenancy and 60 days for a year-to-year tenancy, but only where the landlord has received a notice of intent to foreclose and the property is not in Baltimore City or Montgomery County, the landlord does not offer five or more residential dwelling units for rent in the State, and the property is not subject to an order to docket. The tenant's own periods are 30 days for every tenancy except a year-to-year tenancy, which takes 90 days, and a farm tenancy, which takes 180 days.

Only a longer period may be agreed. A lease may lengthen the notice period but may never shorten it. Section 8-208, subsection (d)(5) bars a landlord from using a lease in which the tenant agrees to a shorter period for the landlord's notice to quit than the law requires, while expressly allowing the parties to agree to a longer one, and a prohibited provision is unenforceable by the landlord, who is also liable for the tenant's actual damages and reasonable attorney's fees for tendering or trying to enforce it. Section 8-501 supplies the other half of the rule: no written agreement between landlord and tenant may require a longer notice period from the tenant than the one required of the landlord.

A statute requires the landlord's and tenant's periods to be equal, or bars a lease from imposing a longer period on one side.

Source of the period: a termination-notice statute states it.

The landlord ends a periodic tenancy by giving written notice of the intent to terminate it by the deadline for that tenancy type, and the statute puts the expiration of a stated term inside the same schedule. The notice is what opens the courthouse door: a landlord may file for repossession after the tenancy ends only if the notice was given, and before entering judgment the court must find that the tenancy is fully ended and that due notice to quit was given. The tenant's side is drafted the other way round. Section 8-402, subsection (c)(3) says that where the tenant gives notice by word of mouth at least 30 days before the end of the lease or tenancy, 90 days for a tenancy from year to year and 180 days for a farm tenancy, and the landlord proves that notice by competent testimony, the landlord need not serve its own written notice. Maryland has no separate section stating a duty on the tenant to give notice, so those are the periods a tenant's notice must meet for the landlord to take the benefit, and the paragraph does not apply in Baltimore City. A landlord who offers five or more dwelling units for rent in the State and rents without a written lease is treated as having let the unit for a term of one year from the tenant's first occupancy, and the tenant may end that tenancy earlier by giving one month's written notice.

No: no statewide rule requires a reason, and no statute expressly authorizes local ordinances.

Local ordinances: no statute or decision addresses them. No Maryland statute preempts local just-cause or eviction-control measures, and none authorizes them either. The Real Property Article preempts local law on exactly two narrow subjects, neither of them grounds for ending a tenancy: the tenant's right of first refusal, and the deposit of rent into escrow because of lead paint. Elsewhere the article runs the other way, providing that its terms are no bar to supplementary rights given by a public local law or a municipal ordinance so long as the local measure does not cut down a right the section grants, and it recognizes Baltimore City's own repossession route by name. On the separate question of local limits on the amount of rent, Maryland does not preempt local regulation at all; that posture is carried on the rent-increase page.

No reason is required to end a periodic tenancy in Maryland or to let a fixed term expire. The landlord gives the notice the tenancy type calls for, and once the period has run the tenancy is over; the court that hears a holdover complaint asks only whether the tenancy is fully ended and whether due notice to quit was given. There is no statewide good-cause statute, no statutory list of no-fault grounds, no relocation payment tied to a no-fault termination, and no statute letting a county or city impose a ground requirement of its own. A bill that would have authorized local good-cause termination rules was introduced and failed in each of the 2024, 2025 and 2026 sessions.

A statute requires notice before a fixed term ends, or notice of non-renewal (60 days).

The landlord must give written notice of the intent to terminate at least 60 days before a written lease for a stated term longer than one week expires; a year-to-year lease takes 90 days and a farm lease 180. The notice is not a formality. A landlord who wants the property back after the term may file only if the notice was given, and the court must find that it was before entering judgment for possession. The tenant is under no separate duty to give notice at the end of a stated term, but a tenant who gives 30 days' notice, even by word of mouth, relieves the landlord of serving its own.

After the term, a statute supplies what a holdover becomes. Where the landlord consents to the tenant staying on after the term, the tenant becomes a week-to-week tenant if the tenancy was week to week before, and a month-to-month tenant in every other case. The trigger is the landlord's consent rather than the acceptance of rent: a payment accepted after a notice to quit is expressly not a waiver of the notice unless the parties agree otherwise in writing. The parties may contract out of the conversion only by a term stated otherwise in the written lease and initialed by the tenant.

A stated-term lease does not simply lapse in Maryland. The 60-day notice schedule reaches tenancies at the expiration of a stated term as well as periodic tenancies, so a landlord who wants possession at the end of the term must say so in writing 60 days out, and the court must find the notice was given before it will order restitution. Maryland requires no reminder before an automatic-renewal clause takes effect, but it polices the clause at signing: except where the renewal period is one month or less, an automatic-renewal provision must be set distinctly apart from the rest of the lease with a space for the tenant's written acknowledgment, and a provision not accompanied by the tenant's initials, signature or witnessed mark is unenforceable by the landlord.

A tenant who stays on with the landlord's consent becomes a periodic tenant, week to week if the tenancy was week to week and month to month otherwise. Without that consent the landlord's route is the summary repossession action, and the landlord may not simply take the property back: possession may be retaken only under a warrant of restitution issued by a court and executed by a sheriff or constable, or where the tenant has abandoned or surrendered possession.

Damages: Actual damages, with the rent as a floor. Qualifiers: the statutory figure is a minimum, not a ceiling.

A tenant who unlawfully holds over beyond the expiration of the lease or the termination of the tenancy is liable for the actual damages caused by holding over, and the award may not be less than the rent for the holdover period apportioned at the lease rate. There is no multiple and no enhancement for a wilful holdover, and the statute preserves whatever other remedies the lease or other law gives the landlord. The claim may be brought in the repossession case or in a separate suit in any court with jurisdiction over the amount, and a money judgment against a residential tenant requires that the tenant was personally served with a summons. Rent accepted after the notice but before eviction is not a waiver of the notice or of a judgment for possession unless the parties specifically agree otherwise in writing; it is applied first to rent through the date the landlord recovers possession, then to court costs, awarded damages and legal fees, then to the rent lost through the holdover, and any excess is returned to the tenant the way a security deposit is, though without the deposit penalties. In Baltimore City the local law gives the landlord more: damages of up to double the rate of rent, and double rent at the landlord's election against a tenant who fails to quit after notice.

Yes: a statute imposes the duty.

When it attaches: The duty runs to whichever side is the aggrieved party in a breach of the lease, and it attaches on any of three events: the landlord's failure to supply possession of the dwelling unit, the tenant's failure or refusal to take possession at the beginning of the term, and the ending of occupancy before the end of the term. Nothing else has to happen first. There is no notice of abandonment to serve and no election of remedies to make before the duty bites.

Burden of proof: no authority allocates it.

The standard: The landlord must exercise reasonable diligence to re-let the premises. Listing the vacated dwelling for sale alone does not satisfy the duty; listing it for sale or rent, and later for rent, does, and the Court of Appeals said the statute requires no more than that the landlord seek out a reputable real estate broker and list the property for rent with that broker. Whether the effort was enough is normally left to the trier of fact, and a landlord has not necessarily failed simply because no new tenant was found. The landlord is under no obligation to show or lease the vacated unit in preference to other available units. A landlord who re-lets may recover the brokerage commission as a necessary expense of mitigation, apportioned where the new tenancy runs beyond the departing tenant's own term.

No authority addresses a clause accelerating the remaining rent.

The lease may not waive the duty.

Maryland's duty to mitigate is statutory and has been since July 1, 1974, when the General Assembly abolished the common-law rule that let a landlord sit idle and sue for the whole term. Section 8-207 says the aggrieved party in a breach of a lease has a duty to mitigate damages where they result from a failure to supply possession, a failure or refusal to take possession at the beginning of the term, or the ending of occupancy before the end of the term. The section sits in the subtitle that applies only to residential leases, so it is a residential rule; the subtitle does not reach a tenancy arising after the sale of owner-occupied residential property where the seller stays in possession for no more than 60 days after settlement. No provision of the section may be waived in any lease, and the prohibited-terms section separately voids any clause by which the tenant gives up a right or remedy the law provides. Where the tenant wrongly refuses to take possession or leaves before the end of the term, the landlord may sublet the unit without prior notice to the tenant in default, and that tenant stays secondarily liable for rent for the term of the original agreement, together with consequential damages, provided the landlord promptly tells the tenant of any default by the subtenant. Who must prove that reasonable efforts were or were not made is unsettled: the Court of Appeals noted the split among states that impose the duty and expressly declined to place the burden. No Maryland statute addresses a lease clause accelerating the remaining rent on default.

No statute addresses a fee a landlord may charge for ending a lease early; the general damages rules govern.

Cap on damages after an early departure: Two months' rent, and only on the medical ground. A tenant who gives the landlord the statutory certification from a Maryland-licensed physician or psychologist together with a written notice stating the date of leaving owes no more than two months' rent after the date of vacating. No general cap applies to an ordinary early departure, where the mitigation rules govern instead.

No Maryland statute authorizes, caps or bars a fee or liquidated sum for ending a residential lease early. The one number the law attaches to such a clause is a benchmark rather than a limit: a lease whose early-termination or liquidated-damages clause requires notice to vacate of one month or less and imposes liability of no more than two months' rent after the tenant leaves switches off the medical-condition protection in section 8-212.2, while a harsher clause simply leaves that protection in place for a qualifying tenant. Other limits do bind a Maryland lease. It may not have the tenant give up any right or remedy the law provides; it may not set a late-payment penalty above five percent of the rent due for the delinquent period, or, where rent is paid weekly, above three dollars a week and twelve dollars a month; and it may not require more than the security deposit and the first month's rent to start the tenancy and take occupancy. A prohibited provision is unenforceable by the landlord, who is also liable for the tenant's actual damages and reasonable attorney's fees for tendering or trying to enforce one. The State's administrative regulations were read as well, and nothing in them regulates a termination charge.

Early-exit rights by ground: domestic violence and related grounds, a statutory right to end the lease; military service beyond the federal act, a spouse or dependent may terminate in their own right and a deployment or transfer threshold below the federal act's; death of the tenant, related duties only, no termination right; and other statutory grounds.

Domestic violence and related grounds: a victim may end the lease on notice.

Who qualifies: The tenant, or a legal occupant, who is a victim of abuse. A legal occupant is someone who lives on the premises with the landlord's actual knowledge and permission, so the right is not confined to the person named on the lease. Abuse takes its meaning from the Family Law Article: an act causing serious bodily harm; an act placing a person eligible for relief in fear of imminent serious bodily harm; assault in any degree; rape or a sexual offense under the criminal statutes named there, or an attempt; false imprisonment; stalking; and the distribution of intimate images without consent. Child abuse and the abuse of a vulnerable adult are included by cross-reference. Human trafficking is not on that list, so a trafficking victim qualifies only where the conduct is also one of the acts named. The subtitle borrows only the definition of abuse, not the relationship requirement that goes with a protective order, so a victim with no qualifying family or household relationship reaches the same right through a peace order or a report from a qualified third party.

Documentation: The written notice must include one of three things: a copy of a final protective order issued for the benefit of the tenant or legal occupant; a copy of a final peace order issued for their benefit where the underlying act was an act of abuse; or a copy of a report by a qualified third party, with the alleged perpetrator's name and physical description removed, signed by that third party within the preceding 60 days. The list is closed, and the trap is the word final: an interim or temporary order does not qualify. A qualified third party is a physician, a psychologist, a social worker or caseworker of any public or private health or social services agency or provider, or an advocate from a domestic violence or sexual assault prevention or assistance program. The report must say that the tenant or legal occupant is seeking assistance as a result of an act of abuse and is a victim of abuse, give the date, time, location and a brief description of the incident, name and describe the alleged offender if known, name the third party's employer and, where the third party must be licensed, the licensing body and license number, and be signed by the third party under the seal of a notary public and signed and acknowledged by the tenant or legal occupant under penalty of perjury. The notice and the documentation go to the landlord together.

Window: 60 days; the incident or documentation must fall within that window before the notice. The 60-day window applies only to the qualified third party's report, which must have been signed within the 60 days before the notice is given. A final protective order and a final peace order carry no recency limit at all, so an older order still supports a termination. A separate 60-day window governs the related eviction defense, where the alleged breach of the lease must have occurred within 60 days of the date the report was signed.

Notice: 30 days; no more than that many days. The tenant gives the landlord written notice with the qualifying document attached and then has 30 days from the date of that notice to leave. The 30 days are an outer limit rather than a waiting period: the tenant may go sooner, and the lease liability ends when the tenant actually vacates. A tenant who has not left within the 30 days loses the protection of the section and faces the landlord's election described below.

Rent owed: The tenant is responsible for rent only for the time from giving the notice until actually leaving, up to a maximum of 30 days. Cutting the bill short by leaving early takes a further step, and the step has teeth: the tenant must give the landlord written notice, signed by the tenant and notarized, by first-class mail or hand delivery, stating that the tenant has vacated. The landlord must then inspect and give the tenant a written statement confirming the departure, stating the rent the tenant owes and stating what is still owed or what overpaid rent will be refunded. The date of leaving is taken to be the postmark date or the date of hand delivery. A tenant who leaves early but does not send that notarized notice owes the full 30 days.

Cost to the tenant: There is no statutory fee or penalty for the termination itself. The tenant's costs are the rent for the period up to leaving, capped at 30 days, the notarization of the early-departure notice, and, where a lock change is requested, a landlord's charge that may not exceed the reasonable cost of changing the locks. The security deposit is returned under the general deposit rules.

Other tenants on the lease: the lease continues for the other tenants. The statute speaks to one other tenant only: the person who was the respondent in the action that produced the victim's protective or peace order. Ending the victim's future liability does not terminate or in any way affect that respondent's own liability, so the lease continues against the respondent. It is not a bifurcation and it gives the landlord no ground to evict the respondent; it simply keeps the respondent on the hook. Co-tenants who are not the respondent are not addressed at all, so what happens to them turns on the lease.

Locks: The victim may require the landlord to change the locks. The tenant may require a lock change by written request attaching a final protective or peace order, but only where the order requires the respondent to refrain from entering or to vacate the residence. The landlord must change the locks by the close of the next business day after receiving the request. If the landlord does not, the tenant may have a certified locksmith change them without the landlord's permission and must give the landlord a duplicate key by the close of the next business day. A landlord who does change them must give the tenant a key at a mutually agreed time within 48 hours and may charge the tenant no more than the reasonable cost of the change, payable within 45 days, after which the landlord may charge it as additional rent or take it out of the security deposit.

Later screening: no statutory protection.

The landlord must keep the victim's documentation or status confidential.

Deadline to move out: The tenant must actually leave within 30 days of giving the notice. A tenant who does not gives the landlord a choice, exercised on written notice: the landlord may pursue every remedy available against a tenant holding over, or may treat the tenant's notice of intent to vacate as rescinded and the original lease as in full force.

The landlord's side: The landlord may require the qualifying document with the notice, and may hold the tenant to the 30-day deadline by electing either the holdover remedies or the revival of the original lease. Against that sit two duties. The landlord may not disclose any information the tenant provides under the subtitle to anyone else unless the tenant consents in writing or a law or court order requires it. And in a possession action brought for a breach of the lease, a tenant who produces a final protective order, a qualifying final peace order, or a qualified third party's report on a breach that happened within 60 days of the report's signing is treated as having raised a rebuttable presumption that the breach does not warrant an eviction; the court may also enter judgment for a tenant who produces none of that.

Lease disclosure: Maryland requires no notice of the abuse-victim termination right in the lease itself. What every residential lease must include is a copy of the current Maryland Tenants' Bill of Rights published by the Office of Tenant and Landlord Affairs, a general disclosure that describes how a tenancy ends but is not specific to victims.

A tenant, or a legal occupant living there with the landlord's knowledge and permission, who is a victim of abuse may end future liability under a residential lease. The tenant gives the landlord written notice with one qualifying document attached: a final protective order, a final peace order for an act of abuse, or a notarized report from a qualified third party signed within the preceding 60 days with the perpetrator's identifying details removed. The tenant then has 30 days from the notice to leave and owes rent only for the days until leaving, capped at 30, provided a tenant who goes early sends a notarized written statement that the unit has been vacated. There is no fee or penalty for the termination. The victim may require the landlord to change the locks where the order excludes the respondent, and the landlord must keep everything the tenant supplies confidential. The termination does not release the respondent to the order from the lease; no other co-tenant is addressed. A tenant who stays past 30 days can be treated as a holdover or held to the original lease, at the landlord's election.

Military service: A spouse or dependent may terminate in their own right and a deployment or transfer threshold below the federal act's.

When the state rights attach: The Maryland provision is a cap on liability rather than a notice-and-terminate procedure, so there is no statutory notice period to run: liability stops 30 days after written notice and proof of the change of assignment reach the landlord. It applies whether the change of assignment comes before or after the service member takes occupancy, and it operates despite anything else in the title. Who counts is settled by the State Government Article's definitions, which run on the uniformed services generally rather than on the federal act's narrower National Guard conditions.

Where an active service member or the service member's spouse takes a residential lease and the service member then receives a change of assignment, liability for rent under the lease may not exceed the rent and lawful charges then due and payable plus 30 days' rent after written notice and proof of the change of assignment are given to the landlord, together with the cost of repairing damage the tenant caused. A change of assignment includes permanent change of station orders, temporary duty orders for a period exceeding 90 days, orders requiring a move into quarters on a military installation, and a release from active duty by retirement, by separation or discharge under honorable conditions, or by demobilization of an activated reserve-component member who had served at least 180 consecutive days on active-duty orders. Three of those go beyond the federal act: the spouse holds the right in his or her own right rather than only on the service member's death or catastrophic injury, temporary duty orders and orders into on-base quarters have no federal counterpart, and Maryland attaches no minimum length to the orders where the federal act requires 90 days. Separation and retirement are not Maryland-only grounds; the federal act reaches those too. Maryland's other servicemember contract-termination statute supplements the federal act but covers telecommunication, internet, television, gym and satellite-radio contracts, not leases.

Death of the tenant: A statute addresses the deposit, rent, or property after death but gives no termination right. No Maryland statute lets an estate, a personal representative or a co-tenant end a residential lease because the tenant died, and none caps the estate's liability for the remaining rent. Two statutes address what happens afterwards. Where a tenant dies intestate and without next of kin, the landlord may bring a summary ejectment action against the tenant named in the lease notwithstanding the death, certifying in the written complaint that, to the best of the landlord's knowledge, the tenant is deceased, intestate and without next of kin; property or income from property the landlord then holds for that tenant is presumed abandoned under the unclaimed-property law, and what becomes of it is covered separately. The other runs against a landlord: where a landlord holding only an estate for life dies and the death ends the leasehold, the personal representative may recover the full rent if the death falls on the day rent is payable and a proportionate share if it falls before.

Other grounds: Three further statutory grounds let a Maryland tenant leave early. The first is a medical one. A tenant who gives the landlord a written certification from a Maryland-licensed physician or psychologist, on that professional's letterhead or printed prescription form, in the form the statute sets out, together with a written notice stating the date of leaving, owes no more than two months' rent after the date of vacating. The certification must say the patient can no longer live at the premises because of a medical condition that substantially restricts the patient's physical mobility within the unit or in entering and leaving it, requires a move to a home, facility or institution for a higher level of care than the unit can provide, or is a mental disorder that makes continued occupancy unfeasible or unsustainable or requires such a move, and that the condition is expected to last beyond the lease's termination date. The patient may be a named party to the lease or an authorized occupant under it. The protection falls away where the lease already contains a liquidated-damages or early-termination clause requiring notice to vacate of one month or less and imposing liability of no more than two months' rent. The second is the conversion of a senior apartment facility. At least 180 days before converting a senior apartment facility to housing for the general population the landlord must give each tenant written notice, and that notice must tell the tenant of the right to end the lease at any time before the conversion date on at least one month's written notice; the landlord must allow it and may not keep any part of the deposit for rent that would have come due after the termination. A senior apartment facility is a building or complex of four or more dwelling units that is housing for older persons under federal law, excluding a nursing home or an assisted living facility. The third is the landlord's failure to deliver possession: rent abates until possession is given, and the tenant may terminate, cancel and rescind the lease on written notice before possession is delivered, recovering all prepaid rent, deposit or security and any consequential damages actually suffered. There is no job-transfer ground and no general age or disability ground beyond the two above. Ending a lease because the landlord has not kept the unit fit to live in is covered on the habitability page.

No statute treats absence as ending the tenancy; the common law governs.

Maryland treats abandonment as an operative fact without ever defining it. There is no presumption built on a stated absence and unpaid rent, no notice of belief of abandonment for the landlord to serve, no window for the tenant to answer one, and no statutory date on which the tenancy is deemed to have ended. What the word does is unlock one thing. A landlord may retake possession only under a warrant of restitution issued by a court and executed by a sheriff or constable, or where the tenant has abandoned or surrendered possession of the dwelling unit; and a lease may authorize the landlord to take the premises or the tenant's belongings without formal legal process only once the lease has ended by the parties' action or by operation of law and the belongings have in fact been abandoned. A landlord who judges it wrong is liable for the tenant's actual damages together with reasonable attorney's fees and costs, and those remedies are not exclusive. The one safety valve is that a landlord may take temporary measures, including changing the locks, to secure an unsecured residential property, provided the landlord makes good-faith attempts to give the tenant reasonable notice that the tenant may promptly be restored to possession. What may be done with property a tenant leaves behind is covered separately.

Maryland prescribes no method for delivering a termination notice. The statute requires only that the landlord provide written notice of the intent to terminate the tenancy by the deadline for the tenancy type. There is no personal-delivery requirement, no posting-and-mailing cascade, no certified-mail rule, no proof-of-service rule and no statutory form, so how the notice travels is left to the lease and to the landlord's own need to prove that it arrived. The constable and sheriff rules, and the rule that posting on the property plus first-class mail is conclusively good service, attach to the court summons in the repossession case rather than to the notice that ends the tenancy. Baltimore City is the exception: its local law does prescribe how the notice is served and what it must contain.

Electronic delivery: the termination statute is silent on it.

What the notice must contain: The notice must be in writing and must state the intent to terminate the tenancy. No ground, no recital of the tenant's rights and no particular form is required. Where the tenant gives the oral notice the statute contemplates, it must state the intention to move at the end of the period and to surrender possession then, and the landlord must prove it by competent testimony. Maryland also has no requirement that a termination notice be given in any language other than English.

Maryland's termination sections cite no federal statute. The state's own military liability cap runs on Maryland definitions of active duty and active service member rather than on the federal servicemember act, and the one Maryland statute that says in terms that it supplements that federal act covers telecommunication, internet, television, athletic club or gym, and satellite-radio contracts, not residential leases. Nothing in the state's termination law is keyed to federally assisted housing.

The federal CARES Act 30-day notice to vacate for covered properties, as read in this state's courts: no state appellate decision construes it. No Maryland appellate decision construes the CARES Act's 30-day notice provision for covered dwellings, and Maryland has not written it into its own law: the Act is named nowhere in the landlord-tenant title. The only Maryland appellate decisions that mention the Act at all are an attorney-discipline case and a contract case turning on the implied duty of good faith and fair dealing, neither of which reaches the notice question, and there is no standing court order or published practice a Maryland landlord would meet on filing. A landlord of a covered dwelling therefore follows the federal provision as written. (Appellate picture read as of September 2, 2026.)

Wilson v. Ruhl, 277 Md. 607, 356 A.2d 544 (Court of Appeals of Maryland, 1976; residential lease; bears on the duty to re-let): The statutory duty to mitigate requires the landlord to exercise reasonable diligence to re-let the premises, a duty the General Assembly created in 1974 by abolishing the landlord's old option of doing nothing and suing for the whole term. Listing a vacated house for sale did not satisfy the duty, but listing it for sale or rent and later for rent did, and the statute asks no more than that the landlord seek out a reputable real estate broker and list the property for rent with that broker. Whether the effort suffices is normally for the trier of fact. The court noted the split among states on who must prove mitigation and expressly declined to place the burden.

Millison v. Clarke, 287 Md. 420, 413 A.2d 198 (Court of Appeals of Maryland, 1980; arose from a commercial lease; bears on the duty to re-let): In a landlord's action for rent under a commercial lease, the court held that a re-letting beyond the original term is not the acceptance of a surrender as a matter of law where there is evidence from which the trier of fact could find that the landlord did not intend that result. Because the case arose from a commercial lease it is not the authority for Maryland's residential duty to mitigate, which rests on the statute and on Wilson v. Ruhl; it is often cited in that role and should not be.

Velicky v. The Copycat Building LLC, 476 Md. 435 (Court of Appeals of Maryland, 2021; residential lease; bears on ending a periodic tenancy): The court declined to bar an unlicensed landlord from seeking possession at the expiration of a tenancy under the holdover statute. In doing so it applied Baltimore City's own public local law, which required the landlord to give 60 days' notice before filing a holdover action at a time when the State statute required only one month, and it records that the 2021 act took the State period to 60 days for all tenants.