(a) Statutory lien. — An attorney who has a lien under Code, Business Occupations and Professions Article, § 10-501, may assert the lien by serving a written notice by certified mail or personal delivery upon the client and upon each person against whom the lien is to be enforced. The notice shall claim the lien, state the attorney's interest in the action, proceeding, settlement, judgment, or award, and inform the client or other person to hold any money payable or property passing to the client relating to the action, proceeding, settlement, judgment, or award.
Rule 2-652.Enforcement of attorney’s liens
Circuit Court · Last amended January 1, 2023 · Last verified July 13, 2026
In one sentenceRule 2-652 spells out how a Maryland attorney asserts a statutory lien for fees and how disputes over that lien get decided.
Full Text of Rule 2-652
(b) Adjudication of rights and lien disputes. —
(1) When a Circuit Court Action has been Filed. — If a lien asserted pursuant to this Rule relates to an action that has been filed in a circuit court of this State, on motion filed by the attorney, the attorney's client in the action, or any person who has received a notice pursuant to section (a) of this Rule, the court shall adjudicate the rights of the parties in relation to the lien, including the attorney's entitlement to a lien of the attorney's claim.
(2) When No Circuit Court Action has been Filed. — If a lien is asserted pursuant to this Rule and a related action has not been filed in a circuit court of this State, the attorney, the attorney's client, or any person who has received a notice pursuant to section (a) of this Rule may file a complaint with a circuit court to adjudicate the rights of the parties in relation to the lien, including the attorney's entitlement to a lien of the attorney's claim. Cross reference. — For venue of a complaint filed pursuant to this section, see Code, Courts Article, §§ 6-201 – 203.
Amendment History
Added Sept. 11, 1995, effective Jan. 1, 1996; amended Oct. 31, 2002, effective Jan. 1, 2003; Feb. 8, 2005, effective July 1, 2005; May 8, 2007, effective July 1, 2007; June 6, 2016, effective July 1, 2016; September 30, 2022, effective January 1, 2023.
Committee Note & Source
Cross reference. Code, Business Occupations and Professions Article, § 10-501(d).
Source. This Rule is new.
Plain-English Summary
Maryland law gives an attorney a statutory lien on money or property recovered for a client in certain matters. Rule 2-652 governs how that lien gets asserted and, when it is contested, how it gets resolved. An attorney who holds the lien asserts it by serving written notice — by certified mail or personal delivery — on both the client and anyone else the lien will be enforced against. That notice has to claim the lien, spell out the attorney's interest in the action, proceeding, settlement, judgment, or award, and tell the recipient to hold any money or property passing to the client that relates to it, rather than pay or transfer it out.
Disputes over the lien are handled differently depending on whether a case is already in court. If the lien relates to an action already filed in a circuit court, the attorney, the client, or anyone who received the notice can file a motion in that same case, and the court adjudicates the parties' rights regarding the lien, including whether the attorney is entitled to it and its amount. If no circuit court action has been filed at all, the same set of people can instead file a complaint with a circuit court to get the lien dispute resolved, starting a case where none existed before. Venue for that kind of complaint follows the general venue provisions in the Courts Article.
Frequently Asked Questions
How does an attorney assert a lien under this rule?
By serving written notice, by certified mail or personal delivery, on the client and on each person against whom the lien will be enforced. The notice must claim the lien, describe the attorney's interest in the matter, and direct the recipient to hold any money or property relating to it.
What if a circuit court case is already pending?
The attorney, the client, or anyone who received the notice can file a motion in that case, and the court will decide the parties' rights regarding the lien, including whether the attorney is entitled to it.
What if no case has been filed yet?
The attorney, the client, or a notice recipient can file a complaint with a circuit court to have the lien dispute adjudicated.
Where does a lien-dispute complaint get filed when there is no pending action?
Venue follows the general venue provisions of the Courts Article referenced in the rule.
What must the notice asserting the lien tell the recipient?
It must claim the lien, state the attorney's interest in the action, proceeding, settlement, judgment, or award, and instruct the recipient to hold any money payable or property passing to the client that relates to it.
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: attorney lien Marylandenforcing an attorney charging lienlien on settlement proceeds Marylandattorney fee lien noticedispute over attorney lien on judgment