(a) Generally. — When a person fails to comply with a judgment prohibiting or mandating action, the court may order the seizure or sequestration of property of the noncomplying person to the extent necessary to compel compliance with the judgment and, in appropriate circumstances, may hold the person in contempt pursuant to Rules 15-206 and 15-207. When a person fails to comply with a judgment mandating action, the court may direct that the act be performed by some other person appointed by the court at the expense of the person failing to comply. When a person fails to comply with a judgment mandating the payment of money, the court may also enter a money judgment to the extent of any amount due.
Rule 2-648.Enforcement of judgment prohibiting or mandating action
Circuit Court · Last amended January 1, 2004 · Last verified July 13, 2026
In one sentenceRule 2-648 gives a court tools to force compliance when someone ignores a judgment ordering them to do something, stop doing something, or pay money.
Full Text of Rule 2-648
(b) Against transferee of property. — If property is transferred in violation of a judgment prohibiting or mandating action with respect to that property, and the property is in the hands of a transferee, the court may issue a subpoena for the transferee. If the court finds that the transferee had actual notice of the judgment at the time of the transfer, the transferee shall be subject to the sanctions provided for in section
(a) of this Rule. If the court finds that the transferee did not have actual notice, the court may enter an order upon such terms and conditions as justice may require.
Amendment History
Amended Apr. 7, 1986, effective July 1, 1986; June 5, 1996, effective Jan. 1, 1997; July 23, 1997; Nov. 12, 2003, effective Jan. 1, 2004.
Committee Note & Source
Source. This Rule is in part new and in part derived from former Rule 685 a and the 1937 version of Fed. R. Civ. P. 70.
Plain-English Summary
Not every judgment is about money. Some order a party to do something — hand over property, remove a structure, sign a document — or to stop doing something. Rule 2-648 covers what happens when that party does not comply. The court can seize or sequester the noncomplying person's property to the extent needed to force compliance, and it can hold that person in contempt. If the judgment ordered an act to be performed and the person refuses, the court can appoint someone else to do it, at the refusing party's expense. And if the judgment required payment of money and it has not been paid, the court can enter a plain money judgment for the amount still owed.
The rule also closes an obvious loophole: what if the property at the center of the dispute gets handed off to someone else before the judgment is satisfied? If property is transferred in violation of a judgment that prohibited or mandated action regarding it, and it ends up with a transferee, the court can subpoena that transferee. If the court finds the transferee knew about the judgment when the transfer happened, that transferee is exposed to the same sanctions available under the rule against the original noncomplying party. If the transferee did not have actual notice, the court still is not powerless — it can enter whatever order the circumstances require, tailored to what is fair given the transferee's innocent position.
Frequently Asked Questions
What can a court do if someone ignores a judgment ordering them to act or stop acting?
The court may seize or sequester the person's property to the extent necessary to compel compliance, and it may hold the person in contempt.
What if the judgment required the person to perform some act and they refuse?
The court can direct that someone else perform the act, at the refusing party's expense.
Can the court just convert the order into a money judgment?
If the underlying judgment required payment of money and it remains unpaid, yes — the court may enter a money judgment for the amount due.
What happens if the property covered by the judgment gets transferred to someone else?
The court may issue a subpoena for the transferee. A transferee who had actual notice of the judgment at the time of the transfer is subject to the same sanctions as the original noncomplying party.
What if the transferee did not know about the judgment?
The court may still enter an order, but on terms and conditions that account for the transferee's lack of actual notice.
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: enforcing an injunction Marylandcontempt for violating a judgmentjudgment ordering a party to actseizure of property to compel compliancetransferee liable for violating court order