(a) Court decision. — In a contested court trial, the judge, before or at the time judgment is entered, shall prepare and file or dictate into the record a brief statement of the reasons for the decision and the basis of determining any damages.
Rule 2-522.Court decision — Jury verdict
Circuit Court · Last amended January 1, 2014 · Last verified July 13, 2026
In one sentenceRequires a judge to explain the reasoning behind a bench-trial decision and sets the rules for unanimity, written findings, polling, and preserving objections when a jury returns a verdict.
Full Text of Rule 2-522
(b) Verdict. —
(1) Unanimity. — Unless the parties stipulate at any time that a verdict or finding of a stated majority shall be taken as the verdict or finding of the jury, the verdict of a jury shall be unanimous.
(2) Verdict Containing Written Findings. —
(A) Court May Require. — The court may require a jury to return a verdict in the form of written findings upon specific issues. For that purpose, the court may use any method of submitting the issues and requiring written findings as it deems appropriate, including the submission of written questions susceptible of brief answers or of written forms of the several special findings that might properly be made under the pleadings and evidence. The court shall instruct the jury as may be necessary to enable it to make its findings upon each issue.
(B) Omission of Issue. — If the court fails to submit any issue raised by the pleadings or by the evidence, all parties waive their right to a trial by jury of the issues omitted unless before the jury retires a party demands its submission to the jury. As to an issue omitted without such demand, the court may make a finding or, if it fails to do so, the finding shall be deemed to have been made in accordance with the judgment entered.
(3) Return in Open Court. — A verdict shall be returned in open court. If the verdict is in the form of written findings pursuant to subsection (b)(2) of this Rule, the verdict sheet shall be handed to and examined by the judge prior to the announcement of the verdict or any harkening or polling. If there is any material inconsistency between the verdict as announced and the written findings, the court shall inform the jury and the parties of the inconsistency and invite and consider, on the record, the parties’ position on any response.
(4) Polling. — On request of a party or on the court’s own initiative, the jury shall be polled before it is discharged. If the poll discloses that the jury, or stated majority, has not concurred in the verdict, the court may direct the jury to retire for further deliberations or may discharge the jury.
(5) Objections; Waiver. — No party may assign as error the submission of issues to the jury, the instructions of the court, or the refusal of the court to submit a requested issue unless the party objects on the record before the jury retires to consider its verdict, stating distinctly the matter to which the party objects and the grounds of the objection. Upon request of any party, the court shall receive objections out of the hearing of the jury.
Amendment History
Added Nov. 1, 2001, effective Jan. 1, 2002; Nov. 12, 2003, effective Jan. 1, 2004; Dec. 4, 2007, effective Jan. 1, 2008; Nov. 21, 2013, effective Jan. 1, 2014.
Committee Note & Source
Source. This Rule is derived as follows:
Section (a) replaces former Rule 18 b from which it is in part derived.
Section (b) is in part new and in part derived from former Rules 560 and 759 a and e; from the 1937 version of Fed. R. Civ. P. 48 and from 1963 version of Fed. R. Civ. P. 49 (a).
Plain-English Summary
In a contested case tried without a jury, the judge has to put the reasoning on the record — filing or dictating a brief statement of why the court decided as it did and how it figured any damages — before or at the same time judgment is entered.
For jury trials, a verdict has to be unanimous unless the parties have stipulated that a stated majority will count as the verdict. The court can require the jury to answer specific written questions or make special findings instead of a general verdict, using whatever method of submission it thinks appropriate, and must instruct the jury on how to make those findings. If the court leaves out an issue that the pleadings or evidence raised, the parties lose their right to a jury trial on that issue unless someone demands it before the jury retires; an omitted issue left undemanded can be decided by the court, and if the court doesn't decide it, the finding is treated as consistent with the judgment that gets entered.
A verdict has to be returned in open court. If it's in the form of written findings, the judge reviews the verdict sheet before announcing the verdict or doing any harkening or polling, and if the written findings don't line up with the verdict as announced, the judge has to flag the inconsistency and get the parties' input on the record before moving forward. Any party can ask for the jury to be polled before it's discharged, and the court can do so on its own; if polling shows the jury (or the required majority) hasn't agreed, the court can send the jurors back to deliberate more or discharge them. To preserve an objection to the issues submitted, the instructions given, or a refusal to submit a requested issue, a party must object on the record before the jury retires, stating distinctly what's being objected to and why — and can ask to do so outside the jury's hearing.
Frequently Asked Questions
Does a judge have to explain a bench-trial ruling?
Yes. In a contested court trial, the judge must file or dictate into the record a brief statement of the reasons for the decision and the basis for any damages award, before or when judgment is entered.
Must a Maryland civil jury verdict be unanimous?
Yes, unless the parties stipulate that a verdict or finding of a stated majority will count as the jury's verdict.
What are written findings in a verdict?
Instead of a general verdict, the court can require the jury to answer specific written questions or make special findings on the issues, with instructions on how to complete them.
What happens if the court leaves an issue out of the jury's verdict form?
The parties waive their right to a jury trial on that issue unless a party demands its submission before the jury retires. If no one demands it, the court may decide the issue itself, or the finding is deemed consistent with the judgment entered.
What happens if jury polling shows the jury didn't agree?
The court can send the jury back for further deliberations or discharge it.
When must a party object to preserve an issue about the jury's instructions or verdict form?
Before the jury retires to deliberate, stating distinctly the matter objected to and the grounds for the objection.
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
Also known as: unanimous jury verdict marylandjury polling maryland rulespecial verdict written findings marylandbench trial statement of reasons marylandjudge's findings civil trial maryland