In this Chapter, except as otherwise provided or necessary implication requires:
Rule 2-701.Definitions
Circuit Court · Last amended January 1, 2014 · Last verified July 13, 2026
In one sentenceRule 2-701 defines “attorneys’ fees” and “related expenses” for every rule in Maryland’s attorneys’-fees chapter, giving paralegal and law clerk time its own labeled category instead of folding it into the fee itself.
Full Text of Rule 2-701
(a) “Attorneys’ fees” includes related expenses; and
(b) “Related expenses” means expenses related to and incurred as part of the provision of legal services, including compensation for the services of paralegals and law clerks.
Amendment History
Added effective January 1, 2014.
Committee Note & Source
Committee note. In Friolo v. Frankel, 373 Md. 501, 530 (2003), the Court held, for purposes of a claim under the Wage Payment Law, which allowed an award of reasonable “counsel fees,” that charges for paralegals and law clerks were subsumed within the attorneys’ fees and should not be separately charged as attorneys’ fees. It appears that most courts do allow compensation for paralegals and law clerks to be included in a statutory fee-shifting claim. The intent of this Rule is to allow the compensation paid to paralegals and law clerks for work done in connection with a claim permitting the recovery of attorneys’ fees to be included as a separately identified related expense. This is intended to reduce the amounts claimed for attorneys’ fees by encouraging attorneys to permit lower-paid paralegals and law clerks to perform tasks they properly can perform that otherwise would have to be done by the attorneys and would avoid the anomaly of labeling compensation paid to non-attorneys as attorneys’ fees.
Source. This Rule is new. Editor’s note. —The 2013 rules order is effective January 1, 2014, and applies only to actions commenced on or after January 1, 2014.
Plain-English Summary
This definitions rule sets the vocabulary for the whole attorneys’-fees chapter. It says “attorneys’ fees” includes “related expenses,” so a claim or award of attorneys’ fees under this chapter automatically reaches those related expenses unless another rule or the court says otherwise. “Related expenses” covers costs tied to and incurred while providing legal services, and the rule specifically calls out compensation for paralegals and law clerks as an example.
The definition responds to a Maryland appellate decision holding that paralegal and law clerk work fell inside the “attorneys’ fees” a party could recover under a wage-law fee-shifting statute, rather than counting as a separate expense. By giving that work its own label — related expenses — the rule lets a party itemize and bill it separately from attorney time. That separation matters in practice: it lets attorneys hand off tasks that paralegals and law clerks can properly handle without having to describe that lower-cost work as “attorneys’ fees,” which keeps the fee request itself smaller and more accurate.
Frequently Asked Questions
Does “related expenses” cover paralegal and law clerk time?
Yes. The rule names compensation for paralegals and law clerks as an example of a related expense — work connected to and incurred as part of providing legal services.
If I ask for “attorneys’ fees,” do I also need to separately request “related expenses”?
Not necessarily. The rule defines attorneys’ fees to include related expenses, so a claim for attorneys’ fees under this chapter reaches related expenses too, unless a specific rule or court order treats them differently.
Does this rule give me a right to recover attorneys’ fees?
No. It only defines terms used elsewhere in the chapter. Whether a party can recover fees at all, and which chapter procedures apply, depends on Rule 2-702 and the specific law or contract creating the fee claim.
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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