Rule 2-303.Form of pleadings

Rule 2-303 tells a drafter how a pleading has to look and read, not what it has to say on the merits. Every averment of a claim or defense goes in a numbered paragraph, and each paragraph should stay limited, so far as practical, to a single set of circumstances — later pleadings can then refer back to a paragraph by number instead of repeating it. Each separate cause of action gets its own numbered count, and each separate defense gets its own numbered defense, so the court and the other side can tell exactly which claim or defense a given paragraph supports.

Substantively, the rule asks for economy: every averment should be simple, concise, and direct, without technical pleading forms. A pleading should include only the factual statements needed to show entitlement to relief or a ground of defense — no argument, no unnecessary recitations of law, no evidence, and nothing immaterial, impertinent, or scandalous. A party isn't locked into one theory, either. Two or more claims or defenses can be pleaded in the alternative or hypothetically, and if one of several alternative statements would be sufficient on its own, the pleading isn't defective just because another alternative wouldn't hold up. A party can plead as many separate claims or defenses as it has, regardless of whether they're consistent with each other or mix legal and equitable grounds.

Pleadings can also incorporate material from elsewhere: a statement made in one part of a pleading or paper of record can be adopted by reference in another part of the same document or in a different pleading or paper, and a written instrument attached as an exhibit becomes part of the pleading for all purposes. Finally, Rule 2-303 directs courts to construe pleadings to do substantial justice — favoring resolution on the merits over dismissal for a drafting slip.