(a) By notice. — An attorney may withdraw an appearance by filing a notice of withdrawal when (1) the client has another attorney of record; or (2) the attorney entered a limited appearance pursuant to Rule 2- 131 (b), and the particular proceeding or matter for which the appearance was entered has concluded.
Rule 2-132.Striking of attorney’s appearance
Circuit Court · Last amended July 1, 2015 · Last verified July 13, 2026
In one sentenceSets the process for an attorney to withdraw from a Maryland case — by simple notice in easy situations, by motion with client notice in harder ones — and says when an appearance ends automatically.
Full Text of Rule 2-132
(b) By motion. — When an attorney is not permitted to withdraw an appearance by notice under section
(a) of this Rule, the attorney wishing to withdraw an appearance shall file a motion to withdraw. Except when the motion is made in open court, the motion shall be accompanied by the client’s written consent to the withdrawal or the moving attorney’s certificate that notice has been mailed to the client at least five days prior to the filing of the motion, informing the client of the attorney’s intention to move for withdrawal and advising the client to have another attorney enter an appearance or to notify the clerk in writing of the client’s intention to proceed in proper person. Unless the motion is granted in open court, the court may not order the appearance stricken before the expiration of the time prescribed by Rule 2-311 for responding. The court may deny the motion if withdrawal of the appearance would cause undue delay, prejudice, or injustice.
(c) Notice to employ new attorney. — When, pursuant to section (b) of this Rule, the appearance of the moving attorney is stricken and the client has no attorney of record and has not mailed written notification to the clerk of an intention to proceed in proper person, the clerk shall mail a notice to the client’s last known address warning that if new counsel has not entered an appearance within 15 days after service of the notice, the absence of counsel will not be grounds for a continuance. The notice shall also warn the client of the risks of dismissal, judgment by default, and assessment of court costs.
(d) Automatic termination of appearance. — When no appeal has been taken from a final judgment, the appearance of an attorney is automatically terminated upon the expiration of the appeal period unless the court, on its own initiative or on motion filed prior to the automatic termination, orders otherwise.
Amendment History
Amended March 3, 2015, effective July 1, 2015.
Committee Note & Source
Source. This Rule is derived as follows:
Section (a) is new.
Section (b) is in part derived from former Rule 125 a and the last sentence of c 2 and is in part new.
Section (c) is derived from former Rule 125 d.
Section (d) is derived from former Rule 125 e.
Plain-English Summary
An attorney who has entered an appearance doesn't get to walk away from a case with no formality. This rule gives two paths off, depending on the circumstances, plus a rule for when representation ends on its own.
The easy path is withdrawal by notice, available in two situations: the client already has another attorney of record, or the attorney's appearance was a limited one under Rule 2-131(b) and the specific matter it covered has wrapped up. Outside those situations, the attorney has to file a motion to withdraw instead. That motion needs either the client's written consent or the attorney's certificate confirming that notice was mailed to the client at least five days before filing, telling the client the attorney intends to withdraw and urging them to find new counsel or notify the clerk they'll proceed on their own. Unless the motion is granted right there in open court, the judge can't strike the appearance before the response period under Rule 2-311 runs out — and can deny the motion outright if withdrawal would cause undue delay, prejudice, or injustice.
Once a motion withdrawal is granted and the client has no other lawyer of record and hasn't told the clerk they'll proceed alone, the clerk sends the client a warning: get new counsel within 15 days, because after that, not having a lawyer won't be grounds for a continuance. The notice also flags the real risks of going forward without one — dismissal, a default judgment, or being assessed court costs.
Finally, an attorney's appearance can end without anyone filing anything. Once a final judgment is entered and no appeal is taken, the appearance automatically terminates when the appeal period runs out — unless the court, on its own or on a motion filed before that deadline, orders otherwise.
Frequently Asked Questions
Can my lawyer drop my case whenever they want?
No. An attorney who has entered an appearance can only withdraw through the process this rule sets — either by simple notice in limited circumstances, or by motion, and the court can deny a motion to withdraw if it would cause undue delay, prejudice, or injustice.
What's the difference between withdrawing "by notice" and "by motion"?
Withdrawal by notice is available only when the client already has another attorney of record, or when a limited appearance's assigned task has concluded. Every other withdrawal requires a motion, along with the client's consent or proof the client got advance notice.
What notice does a client get before their lawyer withdraws by motion?
Unless the client already consented in writing, the attorney has to certify that notice was mailed to the client at least five days before filing the motion, informing the client of the planned withdrawal and advising them to get new counsel or tell the clerk they'll proceed without one.
Can a judge refuse to let an attorney withdraw?
Yes. The court may deny a motion to withdraw if allowing it would cause undue delay, prejudice, or injustice, and generally can't strike the appearance before the response period under Rule 2-311 has run unless the withdrawal is granted in open court.
What happens after the court lets my lawyer withdraw and I don't have a new one?
The clerk mails you a notice warning that you have 15 days to get new counsel, that the absence of a lawyer after that won't excuse you from deadlines or justify a continuance, and that you risk dismissal, a default judgment, or being charged court costs.
Does an attorney's appearance ever end automatically, without a withdrawal filing?
Yes. After a final judgment where no appeal is taken, the attorney's appearance automatically terminates once the appeal period expires, unless the court orders otherwise on its own initiative or on a motion filed before that deadline.
Source & verification. Rule text, Committee Note, Source note, and
amendment history are reproduced verbatim from the Maryland Rules, adopted by the
Supreme Court of Maryland. Last verified July 13, 2026. ·
Official source
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