Maryland's post-judgment interest rate is 10% per year — the second highest fixed rate in the United States, behind only Massachusetts at 12%. Under Md. Code Ann., Cts. & Jud. Proc. § 11-107(a), this rate applies automatically to all money judgments in the state, without any action required by the creditor.
There is one significant exception. When a landlord obtains a judgment specifically for unpaid rent on residential premises, the rate drops to 6% under § 11-107(b). The Maryland Court of Appeals confirmed this in Ben-Davies v. Blibaum & Associates (2018): the 6% rate applies to residential rent judgments even when the judgment includes other damages beyond unpaid rent.
The practical consequence of a 10% rate is substantial. A $100,000 judgment accrues $10,000 in interest every year. Over the 12-year lien period available in Maryland Circuit Court, that same judgment could grow to $220,000 before collection — making Maryland one of the highest-cost states in the country for judgment debtors.
Maryland's 10% Rate: Second Highest in the U.S.
Maryland does not index its post-judgment interest rate to Treasury yields, prime rates, or inflation. The legislature chose a fixed statutory percentage that applies uniformly to money judgments unless a specific exception applies. That fixed percentage is 10% per year under Md. Code Ann., Cts. & Jud. Proc. § 11-107(a).
Among the fifty states, only Massachusetts publishes a higher fixed post-judgment rate — 12% under Mass. Gen. Laws ch. 231, § 6B. Maryland's 10% sits alone in second place among fixed-rate jurisdictions. Many neighboring and peer states use lower fixed percentages or variable formulas tied to market instruments. The result is that Maryland judgment debtors face one of the steepest statutory accrual schedules in the country on ordinary civil money judgments.
The statute requires no election by the creditor. Unlike some states where a party must request interest in a motion or include a specific prayer for relief, Maryland's 10% attaches by operation of law to qualifying money judgments. A creditor who obtains a Circuit Court or District Court money judgment for unpaid invoices, breach of contract, tort damages, or other general civil claims does not need to file a separate interest application to start the clock — the rate is built into the statutory framework.
Simple interest, not compound: Maryland post-judgment interest under § 11-107 is simple interest. Each year, interest accrues only on the unpaid principal balance of the judgment, not on interest that has already accumulated. There is no statutory provision for annual compounding of post-judgment interest in the general money-judgment context. This distinction matters enormously when modeling long-running judgments. A $100,000 judgment at 10% for five years produces $50,000 in interest ($10,000 × 5), not a compounded figure that would exceed that amount.
Critical comparison on a $100,000 judgment (annual simple interest at each state's representative post-judgment rate): — Maryland: 10% → $10,000 per year — Illinois: 9% → $9,000 per year — Ohio: 5% contract / higher categories vary; planning comparison often uses 7% on many commercial judgments → $7,000 per year — Virginia: 6% → $6,000 per year
On that $100,000 principal, Maryland's annual accrual exceeds Virginia's by $4,000, Ohio's by roughly $3,000, and Illinois's by $1,000. Over five years of non-payment, the Maryland-vs-Virginia gap alone is $20,000 in interest — before collection costs, attorney fees awarded in the judgment, or lien renewal procedures.
Why legislatures set high fixed rates: Post-judgment interest serves multiple policy goals. It compensates judgment creditors for the time value of money while collection proceeds. It discourages strategic delay by judgment debtors who might otherwise treat an unpaid judgment as indefinite free financing. It also creates settlement pressure — every month of non-payment adds measurable cost. Maryland's 10% rate reflects a legislative judgment that creditors should receive a substantial return during the often-lengthy enforcement phase.
Property tax judgments — a separate statutory lane: Money judgments arising from property tax liens and related tax-sale proceedings are not governed solely by § 11-107's 10% default. Under Md. Code Ann., Tax-Property §§ 14-603 and 14-702, interest on certain property tax judgments is calculated at the greater of the rates specified in those sections. Practitioners handling tax-sale or property tax deficiency judgments must read §§ 14-603 and 14-702 alongside § 11-107 before applying the 10% planning rate. A tax judgment file is not interchangeable with an ordinary breach-of-contract file.
Official sources for verifying the statutory text: — Maryland General Assembly: mgaleg.maryland.gov (Courts and Judicial Proceedings Article, § 11-107) — Maryland Judiciary: mdcourts.gov (forms, self-help resources, and court procedural guidance)
For planning estimates on ordinary money judgments, use TheLegalCalc's Maryland Judgment Interest Calculator at /judgment-interest-calculator/maryland. Enter the principal, start date, and applicable rate (10% general or 6% residential rent). The calculator applies simple interest consistent with § 11-107.
The Residential Rent Exception: When 6% Applies Instead
Not every Maryland money judgment earns 10%. Subsection (b) of Md. Code Ann., Cts. & Jud. Proc. § 11-107 creates a deliberate exception for a narrow but common category of landlord-tenant disputes.
The statutory text reduces the post-judgment interest rate to 6% per year when the judgment is obtained by a landlord against a tenant specifically for rent due on residential premises. Read that limitation carefully — three elements must align: — The creditor must be a landlord (or equivalent lessor party in the rent relationship) — The debtor must be a tenant on residential premises (not commercial lease rent) — The judgment must be specifically for rent due under the residential lease
When all three conditions are met, § 11-107(b) replaces the 10% general rate with 6%. The reduction is significant in long-running cases. On a $30,000 unpaid residential rent judgment, the difference between 10% and 6% is $1,200 per year — $3,600 over three years of non-payment.
Example — $30,000 residential rent judgment at the reduced rate for two years: Principal: $30,000 Rate: 6% (§ 11-107(b)) Annual interest: $30,000 × 0.06 = $1,800 Two-year simple interest: $1,800 × 2 = $3,600 Total owed after two years (principal + interest): $33,600
The same $30,000 judgment at the general 10% rate would accrue $3,000 per year and $6,000 over two years — nearly double the interest cost. Landlords and tenants negotiating payoffs on residential rent judgments must confirm which subsection applies before using a payoff figure.
What "residential premises" means in practice: Maryland landlord-tenant law distinguishes residential from commercial tenancies throughout the Real Property Article and related regulations. A judgment for unpaid rent on an apartment, single-family home, condominium, or other dwelling unit leased for residential occupancy generally falls within the exception. Rent on office space, retail storefronts, warehouses, and industrial leases typically does not — those commercial rent judgments generally remain at the 10% general rate under § 11-107(a).
The exception is rate-specific, not remedy-specific: § 11-107(b) lowers the interest rate; it does not eliminate interest altogether. Residential rent judgment creditors still earn post-judgment interest — just at 6% instead of 10%. Debtors who assume "residential means no interest" are mistaken. The statute reduces the cost of delay; it does not remove it.
Interaction with other lease-related damages — the Ben-Davies question: Landlords often sue for more than back rent. A typical residential unlawful detainer or rent-and-damages complaint may seek unpaid rent, late fees, property damage beyond normal wear, attorney fees, and court costs. The critical legal question — resolved by Maryland's highest court in Ben-Davies v. Blibaum & Associates (2018) — is whether a judgment that includes those additional items still qualifies for the 6% rate when the underlying dispute is a residential rent case. The Court of Appeals answered yes: the 6% rate applies to the residential rent judgment even when the entered judgment includes other lease-breach damages beyond unpaid rent alone. That holding is developed in the next section of this guide.
When in doubt, classify the judgment by its core nature: Is this a landlord's residential rent judgment? If yes, model at 6% unless counsel identifies a reason the exception does not apply. Is this a commercial lease, contract, tort, or other civil judgment? Model at 10%.
Partial payments and rate consistency: Maryland simple interest runs on the unsatisfied principal balance. If a tenant pays down part of a residential rent judgment, future interest accrues on the reduced balance at the same 6% rate — the rate does not revert to 10% on the remaining unpaid portion of a qualifying residential rent judgment.
Ben-Davies v. Blibaum: The Case That Defines the Exception
Before Ben-Davies v. Blibaum & Associates, 462 Md. 614 (2018), landlords and tenants across Maryland disputed how far § 11-107(b)'s 6% rate extended when a residential rent judgment included more than a straight rent arrearage line item. Trial courts and practitioners reached inconsistent results. The Court of Appeals resolved the conflict with a holding that remains the definitive Maryland authority in 2026.
The case arose from a landlord-tenant dispute on residential premises. The landlord obtained a judgment that encompassed unpaid rent and additional damages flowing from the tenant's breach of the residential lease — not merely the base rent figure. The tenant argued that once the judgment included non-rent damages, the entire award should accrue at the general 10% rate under § 11-107(a). The landlord argued the 6% residential rent rate applied to the judgment as a whole because the case remained fundamentally a landlord's judgment for rent due on residential premises.
The Court of Appeals sided with the landlord's rate position. The 6% rate under § 11-107(b) applies to residential rent judgments even when the judgment includes other damages beyond unpaid rent. The court's reasoning centered on the statutory language and legislative purpose: subsection (b) addresses the category of judgment — a landlord's judgment against a tenant for rent on residential premises — not a mathematical partition of the judgment into "rent dollars" versus "other dollars" with different rates applied line by line.
Practical consequences for landlords: A residential landlord who wins a composite judgment — back rent plus damage to the unit, lease-break costs, or other lease-related items — can calculate post-judgment interest at 6% on the entire unsatisfied judgment balance, not 10%. That materially reduces the interest component over multi-year collection efforts compared to treating non-rent damages at the higher rate.
Practical consequences for tenants: A judgment debtor who assumed that "extra" damage awards would accrue at 10% while only the rent portion earned 6% will find the entire balance growing at the lower rate in a qualifying residential case. Payoff negotiations should use 6% simple interest unless the judgment is clearly outside the residential rent category (for example, a pure property-damage tort judgment unrelated to a rent claim).
What Ben-Davies did not hold: The case defines the scope of § 11-107(b) within the landlord-tenant residential rent context. It does not convert commercial lease judgments to 6%. It does not apply the residential rent rate to homeowner association assessments, condo fees unrelated to a landlord-tenant rent relationship, or credit-card judgments against tenants. The classification question remains: is this judgment "obtained by a landlord against a tenant specifically for rent due on residential premises"?
Litigation strategy after Ben-Davies: — Landlords drafting judgments and payoff demands on residential cases should cite § 11-107(b) and Ben-Davies when asserting 6% accrual on composite lease-breach judgments. — Tenants challenging interest calculations should verify whether the underlying judgment truly falls within the residential rent category before conceding 6%; if the case was reclassified as a general civil judgment unrelated to rent, § 11-107(a) may still apply. — Both sides should read the actual judgment order: the rate follows from the nature of the claims adjudicated, not from how a party labels the judgment in a collection letter.
Relationship to attorney fees and costs: Ben-Davies addressed the rate applicable to residential rent judgments that include damages beyond rent. Separately, practitioners should confirm which judgment components constitute the interest-bearing principal under Maryland law and court practice. Fees and costs awarded in the judgment may affect the base amount on which the 6% or 10% rate runs. The interest rate and the interest base are related but distinct calculation inputs.
For historical and statutory research, the opinion is reported at 462 Md. 614 (2018), and the underlying statute is available through mgaleg.maryland.gov under Courts and Judicial Proceedings § 11-107. Maryland Judiciary resources at mdcourts.gov provide landlord-tenant forms and procedural guidance that contextualize how rent judgments are entered and enforced in District and Circuit Courts.
Step-by-Step: Calculating Maryland Judgment Interest
Maryland post-judgment interest calculation is straightforward once you identify the correct rate and principal. The formula is simple interest — the same structure used in most fixed-rate states.
Core formula: Interest = Principal × Annual Rate × Time
For a period measured in days: Interest = Principal × Annual Rate × (Days ÷ 365)
For a period measured in whole years (planning shorthand): Interest = Principal × Annual Rate × Years
Step 1 — Identify the applicable rate: — General money judgments: 10% under Md. Code Ann., Cts. & Jud. Proc. § 11-107(a) — Residential rent judgments (landlord vs tenant, residential premises): 6% under § 11-107(b), as interpreted in Ben-Davies v. Blibaum & Associates (2018) — Property tax-related judgments: consult Tax-Property §§ 14-603 and 14-702 for the greater-of rate structure before using 10%
Step 2 — Determine the principal balance: Use the unsatisfied portion of the money judgment as entered — including awarded damages, and any fees or costs that the judgment includes as part of the monetary award, subject to the specific judgment language. Partial payments reduce the principal for subsequent accrual periods.
Step 3 — Determine the accrual start date: Post-judgment interest under § 11-107 generally runs from the date of judgment entry (see the "When Does Maryland Judgment Interest Start?" section below for nuances). Count days or years from that date to the payoff date or present date.
Step 4 — Apply simple interest (no compounding): Multiply principal × rate × time. Do not add each year's interest back into the principal unless a separate legal basis requires it — § 11-107 post-judgment interest on ordinary money judgments is simple.
Step 5 — Sum and verify: Total payoff ≈ Remaining principal + Accrued post-judgment interest + Any separately awarded costs not yet paid. Cross-check with /judgment-interest-calculator/maryland.
Worked Example A — $50,000 general judgment, 10%, 365 days: Principal: $50,000 Rate: 10% (0.10) Annual interest: $50,000 × 0.10 = $5,000 Daily interest: $50,000 × 0.10 ÷ 365 = $13.70 per day One year (365 days): $5,000 total interest
Worked Example B — $100,000 general judgment, 10%, five years: Annual interest: $100,000 × 0.10 = $10,000 Five-year simple interest: $10,000 × 5 = $50,000 Total after five years: $100,000 + $50,000 = $150,000
Worked Example C — $30,000 residential rent judgment, 6%, two years: Annual interest: $30,000 × 0.06 = $1,800 Two-year simple interest: $1,800 × 2 = $3,600 Total after two years: $33,600
Worked Example D — Partial payment mid-accrual: $100,000 judgment at 10%, unpaid for two years → $20,000 interest, $120,000 balance Debtor pays $50,000 at year two → remaining principal $70,000 (assuming payment applied to principal first per judgment allocation rules) Year three interest on $70,000: $7,000 (not $10,000) Always recalculate from the reduced base after partial satisfaction
Daily rate reference at 10%: — $50,000 → $13.70/day — $100,000 → $27.40/day — $200,000 → $54.79/day
Daily rate reference at 6% (residential rent): — $30,000 → $4.93/day — $50,000 → $8.22/day — $100,000 → $16.44/day
Common errors to avoid: — Using 10% on a qualifying residential rent judgment (overstates interest by 4 percentage points annually) — Applying compound interest when § 11-107 calls for simple interest — Ignoring partial payments when projecting total payoff — Using the general 10% rate on property tax judgments without checking Tax-Property §§ 14-603 and 14-702 — Forgetting that Massachusetts at 12% is the only higher fixed U.S. rate — Maryland's 10% is already at the high end; miscalculations hurt debtors quickly
The Maryland calculator at /judgment-interest-calculator/maryland automates these steps. Enter principal, rate category, and dates to produce a planning estimate consistent with the formulas above.
The 12-Year Lien Period and How Interest Compounds Over Time
In Maryland Circuit Court, a money judgment creates a lien on the judgment debtor's real property. Under Md. Code Ann., Cts. & Jud. Proc. § 11-402, that lien generally lasts for twelve years from the date the judgment was entered. During those twelve years — and potentially longer if the lien is renewed — post-judgment interest continues to accrue on the unpaid balance at the applicable § 11-107 rate.
This section addresses a frequent misunderstanding. The heading references how interest grows "over time," but Maryland post-judgment interest under § 11-107 is simple interest, not annual compounding. Over a twelve-year lien period, interest does not compound on prior interest accruals. Each year's interest is calculated only on the unpaid principal (as reduced by partial payments).
Correct twelve-year model — $100,000 judgment at 10% simple interest: Annual interest: $100,000 × 0.10 = $10,000 per year Twelve years of simple interest: $10,000 × 12 = $120,000 Total after twelve years (if nothing paid): $100,000 + $120,000 = $220,000
Incorrect compound model (do not use for § 11-107 planning): Annual compounding at 10% on $100,000 over twelve years would produce total interest well above $120,000 and a payoff total exceeding $220,000. That compound figure overstates Maryland statutory accrual. Unless a separate contract or statute mandates compounding — which is not the general § 11-107 rule — use simple interest.
Why the $220,000 figure matters: Judgment debtors who treat a $100,000 Circuit Court judgment as static debt may be surprised to learn that the statutory lien period alone can more than double the obligation. Creditors evaluating whether to renew liens, pursue supplementary proceedings, or accept a discounted payoff similarly need the twelve-year horizon in view. At 10%, time is aggressively on the creditor's side.
Lien duration under § 11-401 and related provisions: Maryland law provides mechanisms for creating and maintaining judgment liens against real property. The twelve-year period commonly discussed in Circuit Court practice reflects the statutory framework for how long a properly docketed judgment lien can bind real estate, subject to renewal procedures and competing liens. Exact lien mechanics depend on whether the judgment was entered in Circuit Court or District Court, whether the judgment was transcribed to another county, and whether the creditor timely renewed the lien before expiration.
Renewal and continued accrual: If a creditor renews a judgment lien under Maryland's renewal statutes before the original lien expires, collection against real property may continue beyond the initial twelve-year window — and post-judgment interest typically continues running on the unpaid judgment balance during the renewal period as well. Debtors cannot assume the debt "expires" when the first lien period ends if the creditor diligently renews.
Residential rent judgments over twelve years — the 6% comparison: $100,000 residential rent judgment at 6% simple interest for twelve years: Annual interest: $6,000 Twelve-year interest: $72,000 Total: $172,000 Compared to $220,000 at 10%, the residential rent rate saves $48,000 in interest over the same twelve-year simple-accrual horizon — illustrating why Ben-Davies classification matters on long-running landlord-tenant collections.
Partial payments over long horizons: Any payment toward the judgment reduces future simple-interest accrual. A debtor who pays $10,000 per year on a $100,000 judgment at 10% slows but does not stop interest on the declining balance. Modeling twelve years with intermittent payments requires period-by-period recalculation — the calculator at /judgment-interest-calculator/maryland handles this more reliably than a single lump formula.
Interaction with wage garnishment and bank levies: A judgment lien on real property is one enforcement tool. Maryland creditors may also pursue wage garnishment, bank account levies, and other collection remedies under the Maryland Rules and applicable exemptions. Interest accrues on the judgment balance regardless of which enforcement method is active, unless the judgment is satisfied or legally stayed.
Planning takeaway: When evaluating a Maryland money judgment, always ask two questions together — what is the rate (10% or 6%), and how long can enforcement continue (twelve-year lien baseline, plus renewal potential). The combination makes Maryland one of the highest-cost states for long-unpaid judgments among its regional peers.
Maryland vs Neighboring States: VA 6%, PA 6%*, DC variable
Geography does not determine post-judgment interest rate — the state (or district) whose law governs the judgment does. Maryland judgment holders and debtors who compare their situation to neighbors should use each jurisdiction's own statute, not assume regional uniformity.
Virginia — 6% fixed rate: Virginia Code § 6.2-302 establishes a 6% post-judgment interest rate on most judgments unless a contract specifies a different lawful rate. On a $100,000 judgment, Virginia accrues $6,000 per year in simple interest. Maryland accrues $10,000 on the same principal — a $4,000 annual advantage for Maryland creditors and a $4,000 annual cost for Maryland debtors compared to Virginia.
Pennsylvania — 6% post-judgment on many judgments (*with exceptions): Pennsylvania's Judiciary Code sets 6% as the post-judgment rate on many money judgments under 42 Pa.C.S. § 8101, with a 9% rate applicable to certain classes of judgments including some landlord-tenant and consumer contexts under § 8102. The asterisk in any regional comparison is important: Pennsylvania splits rates by judgment type. A Pennsylvania residential landlord judgment may accrue at 9% while a general civil judgment accrues at 6% — the inverse of Maryland's pattern where residential rent is lower (6%) and general judgments are higher (10%). Always classify the judgment before comparing.
District of Columbia — variable rate: The District of Columbia does not use Maryland's fixed 10%. D.C. Code § 28-3302 ties post-judgment interest to a variable rate adjusted by the District's CFO based on United States Treasury yields — similar in concept to federal § 1961, not to Maryland's fixed statutory percentage. D.C.'s rate changes over time; Maryland's 10% remains constant until the legislature amends § 11-107. Cross-border disputes involving D.C. and Maryland parties require separate calculations for each forum's judgments.
West Virginia — 10% on many judgments: West Virginia shares Maryland's 10% rate on many money judgments under W. Va. Code § 56-6-31, making the two states comparable on rate — though lien duration, exemption rules, and collection procedure differ.
Delaware — 5% legal rate with judgment-specific rules: Delaware's framework differs from Maryland's; practitioners handling multi-state portfolios should not import Maryland's 10% into Delaware files.
Side-by-side annual simple interest on $100,000: — Maryland (general): $10,000/year at 10% — Massachusetts: $12,000/year at 12% (highest fixed U.S. rate) — Illinois: $9,000/year at 9% — Ohio: approximately $7,000/year at 7% on many commercial judgments (rate varies by claim type) — Virginia: $6,000/year at 6% — Pennsylvania: $6,000/year at 6% on many general judgments; 9% on certain categories — Maryland (residential rent): $6,000/year at 6% under § 11-107(b)
Five-year cost of delay on $100,000 (general judgments, simple interest): — Maryland: $50,000 interest — Virginia: $30,000 interest — Difference: $20,000 — enough to change settlement posture in commercial disputes
Why neighbors matter for Maryland practitioners: Baltimore-Washington corridor businesses and residents frequently litigate in Maryland Circuit Court, Virginia state court, D.C. Superior Court, and the federal District of Maryland depending on venue, citizenship, and claim type. A corporate credit manager comparing "what happens if we don't pay" should run separate models. Maryland's 10% fixed rate is an outlier on the high side relative to Virginia and Pennsylvania's 6% baseline.
Forum shopping and choice of law: The rate comparison above assumes a Maryland-governed Maryland judgment. Contract choice-of-law clauses, federal diversity cases, and judgments from other states domesticated in Maryland raise separate conflict-of-laws questions beyond this guide's scope. Consult Maryland counsel when a foreign judgment is being enforced in Maryland or when a Maryland judgment is being enforced elsewhere.
Official verification: — Maryland: mgaleg.maryland.gov (§ 11-107); mdcourts.gov — Virginia: Virginia General Assembly legislative site for § 6.2-302 — Pennsylvania: 42 Pa.C.S. §§ 8101–8102 — D.C.: D.C. Code § 28-3302 and CFO rate publications
Use /judgment-interest-calculator/maryland for Maryland-specific estimates; compare manually or with other state calculators for neighbor jurisdictions.
When Does Maryland Judgment Interest Start?
Post-judgment interest under Md. Code Ann., Cts. & Jud. Proc. § 11-107 accrues on money judgments from the date the judgment is entered — not from the date of injury, contract breach, or complaint filing (unless a separate prejudgment interest statute or contract provision applies to the pre-judgment period, which is a different analysis from § 11-107 post-judgment accrual).
The entry date is the controlling event for § 11-107 purposes. When the clerk enters judgment on the docket, the post-judgment clock begins at either 10% or 6% depending on judgment classification. Creditors who delay docketing or fail to obtain a clear money judgment order may lose months of accrual they assumed were running.
Judgment entry vs verdict date: A jury may return a verdict in January; the court may enter judgment in March after post-trial motions. Post-judgment interest under § 11-107 runs from March (entry), not January (verdict), unless the court's order specifies otherwise or prejudgment interest on a different basis covers the gap. Always use the docket's judgment entry date as the default start.
Default judgments: When a defendant defaults and the clerk enters judgment under Maryland Rule 2-613 or equivalent procedures, interest accrues from that entry date on the default judgment amount.
Consent and stipulated judgments: Parties who negotiate a consent judgment should understand that post-judgment interest begins accruing on the entered amount from the entry date even if the underlying dispute dates back years. Settlement agreements that waive post-judgment interest must do so explicitly in the agreement and judgment language — § 11-107 does not silently waive itself.
Appeals and stays: Filing an appeal does not automatically stop post-judgment interest accrual under § 11-107 in most circumstances. Maryland appellate practice may involve supersedeas bonds or other mechanisms that affect enforcement, but the statutory interest rate continues to apply to the unpaid judgment balance unless a court order or settlement expressly provides otherwise. Debtors appealing large judgments should model interest accrual during the appellate period — at 10%, a two-year appeal adds $20,000 per $100,000 of principal.
Partial satisfaction and judgment amendments: If the court amends the judgment amount (for example, after remittitur or a modified damages award), the interest start date and principal base may change. Recalculate from the amended entry when the amended judgment is docketed.
Prejudgment interest — separate track: Maryland law may allow prejudgment interest in specific contexts under statutes or contracts distinct from § 11-107. Section 11-107 addresses post-judgment accrual after entry. Do not conflate a contractual pre-judgment rate in a commercial note with the § 11-107 post-judgment rate — they may stack sequentially but are analytically separate.
District Court vs Circuit Court: Both courts enter money judgments that can accrue post-judgment interest under § 11-107. The rate (10% or 6%) follows the judgment type, not the court level. A $15,000 residential rent judgment in District Court accrues at 6%; a $500,000 tort judgment in Circuit Court accrues at 10%. Lien duration and collection tools differ by court and amount, but the § 11-107 rate analysis is the same.
Practical checklist: 1) Locate the judgment entry date on the case docket at mdcourts.gov or the clerk's office 2) Confirm the entered principal amount (damages, fees, costs as awarded) 3) Classify the judgment: general (10%) or residential rent (6% under Ben-Davies) 4) Count days or years from entry date to payoff date 5) Apply simple interest formula 6) Verify with /judgment-interest-calculator/maryland
Tender of payment: Paying the full judgment amount including accrued interest stops further accrual on the satisfied balance. Partial tenders may not stop interest on the remaining unsatisfied portion. Document the payoff date carefully — interest is owed through the date of full satisfaction.
Maryland Courts and the Calculator
Maryland post-judgment interest is statutory law — not a court fee schedule, not a local rule variation, and not an optional add-on requested by motion. The rate is defined in Md. Code Ann., Cts. & Jud. Proc. § 11-107 and applies automatically to qualifying money judgments at 10%, or 6% for residential rent judgments under subsection (b) as interpreted in Ben-Davies v. Blibaum & Associates (2018).
Primary statute: Md. Code Ann., Cts. & Jud. Proc. § 11-107 — Subsection (a): 10% per year on money judgments — Subsection (b): 6% per year on judgments obtained by landlords against tenants for rent due on residential premises
Related lien duration statute: Md. Code Ann., Cts. & Jud. Proc. § 11-401 et seq. (judgment lien creation and renewal framework; twelve-year Circuit Court lien period commonly cited in practice under § 11-402)
Property tax judgment cross-reference: Md. Code Ann., Tax-Property §§ 14-603 and 14-702 (greater-of rate structure for certain property tax judgments — do not assume § 11-107's 10% applies without reading these sections)
Official legislative source: mgaleg.maryland.gov — search Courts and Judicial Proceedings Article, Title 11, for the current annotated text of § 11-107 and related lien provisions
Official court resources: mdcourts.gov — Maryland Judiciary homepage with access to: — District Court and Circuit Court self-help materials — Landlord-tenant forms and guidance — Case search tools for verifying judgment entry dates and amounts — Rules of civil procedure governing judgment entry and enforcement
Key case law: Ben-Davies v. Blibaum & Associates, 462 Md. 614 (2018) — residential rent judgments accrue at 6% even when the judgment includes damages beyond unpaid rent
Free planning calculator: /judgment-interest-calculator/maryland
How to use this guide with the calculator: 1) Confirm judgment classification — general 10% or residential rent 6% 2) Enter the unsatisfied principal from the entered money judgment 3) Enter the judgment entry date as the accrual start 4) Enter the payoff date or use today's date for a current balance estimate 5) Review the simple interest output — no compounding unless your specific judgment type requires a different treatment 6) For property tax judgments, stop and consult Tax-Property §§ 14-603 and 14-702 before relying on the 10% default
Three numbers every Maryland practitioner should remember: — 10%: general post-judgment rate under § 11-107(a) — second highest fixed rate in the U.S. after Massachusetts at 12% — 6%: residential rent exception under § 11-107(b), confirmed in Ben-Davies for composite lease-breach judgments — 12 years: baseline Circuit Court judgment lien period under § 11-402 — at 10% simple interest, a $100,000 judgment grows to $220,000 over twelve years if unpaid ($120,000 in interest)
Comparison anchor on $100,000 annual accrual: Maryland $10,000 | Illinois $9,000 | Ohio ~$7,000 | Virginia $6,000
This page provides planning estimates to support informed negotiation, collection strategy, and debtor budgeting. Maryland judgment interest law contains nuances — partial payments, renewed liens, fee allocations, property tax special rates, and appeal-related enforcement questions — that require judgment-specific review. Verify all figures against the docket, the entered order, and a licensed Maryland attorney before tendering payment, recording satisfaction, or relying on a payoff quote in court.
Maryland post-judgment interest is governed by Md. Code Ann., Courts and Judicial Proceedings § 11-107. The 10% rate applies to general money judgments; residential rent judgments carry 6%. This is a planning estimate — not legal advice. Consult a licensed Maryland attorney for your specific situation.
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Frequently asked questions
Maryland's post-judgment interest rate is 10% per year on general money judgments under Md. Code Ann., Cts. & Jud. Proc. § 11-107(a). That is the second highest fixed post-judgment rate in the United States, behind only Massachusetts at 12%. When a landlord obtains a judgment against a tenant for unpaid rent on residential premises, the rate is 6% under § 11-107(b). The rate applies automatically — no separate creditor application is required.
Under § 11-107(b), when a landlord obtains a judgment against a tenant specifically for rent due on residential premises, post-judgment interest accrues at 6% per year instead of 10%. The Maryland Court of Appeals held in Ben-Davies v. Blibaum & Associates (2018) that the 6% rate applies even when the judgment includes other damages beyond unpaid rent, such as lease-breach or property damage items arising from the same residential tenancy.
Maryland uses simple interest: Interest = Principal × Annual Rate × Time. For a general judgment at 10%, a $100,000 balance accrues $10,000 per year or about $27.40 per day. A $50,000 judgment accrues $5,000 per year or about $13.70 per day. A $30,000 residential rent judgment at 6% accrues $1,800 per year; over two years that is $3,600 in interest. Partial payments reduce the principal on which future interest runs.
No. Maryland post-judgment interest under § 11-107 is simple interest, not compound interest. Each year's accrual is calculated only on the unpaid principal balance, not on prior interest. Over twelve years, a $100,000 judgment at 10% produces $120,000 in total interest ($10,000 × 12), for a $220,000 payoff — not a higher compounded figure.
Post-judgment interest accrues from the date the judgment is entered until the judgment is satisfied. A Circuit Court money judgment also creates a real-property lien that generally lasts twelve years under Md. Code Ann., Cts. & Jud. Proc. § 11-402, with renewal available under § 11-401 et seq. Interest continues running during the lien period and any renewed period on the unsatisfied balance at the applicable rate — 10% general or 6% residential rent.
Related reading
- Ohio Late Fee Laws 2026: Rent Rules and Judgment Interest
Ohio: no statutory late-fee cap; courts test reasonableness. Judgment interest 7% (ORC § 1343.03); contract to 8%. Free OH calc.
- Judgment Interest by State 2026: Rates and How to Calculate
CA 10% (CCP § 685.010). NY 9% (CPLR § 5004). IL 9% (735 ILCS 5/2-1303). Federal ~4.02% (28 U.S.C. § 1961). Free calc.
- Michigan Late Fee Laws 2026: What Landlords Can Charge
Michigan has no statutory late fee cap — but courts apply a reasonableness standard. Judgment interest rate 4.725% in 2026 (MCL § 600.6013). Free calculator.