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Rule 3-132.Striking of attorney’s appearance

District Court · Last amended July 1, 2015 · Last verified July 13, 2026

In one sentenceRule 3-132 sets the three ways an attorney's appearance in a District Court case ends: filing a notice of withdrawal, filing and winning a motion to withdraw, or letting the appearance automatically terminate after the appeal period runs.

Full Text of Rule 3-132

Text sizeJump to: (a) (b) (c)

(a) By notice. — An attorney may withdraw an appearance by filing a notice of withdrawal when (1) the client has another attorney of record; or (2) the attorney entered a limited appearance pursuant to Rule 3- 131(b), and the particular proceeding or matter for which the appearance was entered has concluded.
(b) By motion. — When an attorney is not permitted to withdraw an appearance by notice under section
(a) of this Rule, the attorney wishing to withdraw an appearance shall file a motion to withdraw. Except when the motion is made in open court, the motion shall be accompanied by the client’s written consent to the withdrawal or the moving attorney’s certificate that notice has been mailed to the client at least five days prior to the filing of the motion, informing the client of the attorney’s intention to move for withdrawal and advising the client to have another attorney enter an appearance or to notify the clerk in writing of the client’s intention to proceed in proper person. Unless the motion is granted in open court, the court may not order the appearance stricken before the expiration of the time prescribed by Rule 3-311 for requesting a hearing. The court may deny the motion if withdrawal of the appearance would cause undue delay, prejudice, or injustice.
(c) Automatic termination of appearance. — When no appeal has been taken from a final judgment, the appearance of an attorney is automatically terminated upon the expiration of the appeal period unless the court, on its own initiative or on motion filed prior to the automatic termination, orders otherwise.

Amendment History

Amended March 3, 2015, effective July 1, 2015.

Committee Note & Source

Source. This Rule is derived as follows:

Section (a) is derived from former M.D.R. 125 a.

Section (b) is in part derived from former M.D.R. 125 a and is in part new.

Section (c) is derived from former M.D.R. 125 b.

Plain-English Summary

Rule 3-132 governs how an attorney gets out of a case once they're in it. Section (a) allows the easiest route, a simple notice of withdrawal, but only in two situations: the client already has another attorney of record, or the attorney's appearance was a limited appearance under Rule 3-131(b) and the specific matter it covered has wrapped up. Outside those situations, section (b) requires a motion to withdraw. Unless the attorney makes that motion in open court, it must come with either the client's written consent or the attorney's certificate confirming that notice was mailed to the client at least five days before filing — notice that warns the client the attorney intends to withdraw and advises the client to line up new counsel or tell the clerk in writing that they intend to proceed without one. Even after the motion is filed, the court generally can't strike the appearance until the time to request a hearing under Rule 3-311 has passed, unless the withdrawal is granted in open court. And the court can deny the motion outright if withdrawal would cause undue delay, prejudice, or injustice.

Section (c) handles the case where nobody files anything: once a final judgment is entered and no appeal is taken, the attorney's appearance automatically terminates when the appeal period expires. The court can override that automatic termination, on its own initiative or on a motion filed before the period runs out, if it wants the attorney to stay in the case for some further purpose.

Frequently Asked Questions

When can an attorney withdraw just by filing a notice, without a motion?

Only when the client already has another attorney of record, or when the withdrawing attorney entered a limited appearance under Rule 3-131(b) and the particular matter or proceeding that appearance covered has concluded.

What has to accompany a motion to withdraw?

Unless the motion is made in open court, it must include either the client's written consent to the withdrawal or the attorney's certificate that notice was mailed to the client at least five days before filing, informing the client of the intended withdrawal and advising the client to retain new counsel or notify the clerk of an intent to proceed without one.

Can a court refuse to let an attorney withdraw?

Yes. The court may deny a motion to withdraw if allowing the withdrawal would cause undue delay, prejudice, or injustice.

Does an attorney's appearance end automatically after a case is over?

Yes, under certain conditions. When a final judgment is entered and no appeal is taken, the attorney's appearance automatically terminates once the appeal period expires, unless the court orders otherwise on its own initiative or on a motion filed before that period runs out.

How soon can the court strike an appearance after a motion to withdraw is filed?

Unless the withdrawal is granted in open court, the court may not order the appearance stricken before the time prescribed by Rule 3-311 for requesting a hearing has expired.

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 withdrawal District Courtmotion to withdraw as counselstriking appearance Marylandautomatic termination of appearancelimited appearance conclusion withdrawal