2026-09-12 · Maryland · Courts

What happened. A homeowner lost an assessment case to his community association in the District Court, appealed for a fresh trial in the circuit court, and did not turn up. The circuit court dismissed the appeal — and then entered a new money judgment larger than the one the District Court had given.

On 23 January 2026 the Supreme Court of Maryland granted certiorari and vacated that order. Dismissing the appeal terminated the circuit court's ability to go any further; the District Court's judgment stands as it was.¹

The case is Ramez Ghazzaoui v. Russett Community Association, Inc., Petition No. 407, September Term 2025, from the Circuit Court for Anne Arundel County, in a per curiam order signed by Chief Justice Matthew J. Fader.

Why this reaches almost every Maryland association

Because of where assessment collection actually happens. Most Maryland condominium and HOA assessment claims are brought in the District Court, and a defendant's route of challenge is an appeal to the circuit court for a de novo trial — the whole case heard again. Appeals where the homeowner then fails to appear are routine.

What the circuit court did here is the natural-seeming thing: the appeal is dismissed under Maryland Rule 7-114(c)(4), the association is plainly owed money, and by now more has accrued, so enter judgment for the current figure.

That is what the Supreme Court held it may not do. The dismissal does not put the circuit court in the position of a trial court with a live case; it ends the appeal. The order of 15 October 2025 was vacated and the matter remanded with instructions to clarify that the appeal is dismissed with prejudice and that the District Court judgment stands.¹

1. Ramez Ghazzaoui v. Russett Community Association, Inc., Petition No. 407, September Term 2025, Supreme Court of Maryland — per curiam order filed 23 January 2026, signed by Chief Justice Matthew J. Fader; Circuit Court for Anne Arundel County No. C-02-CV-25-002097; Maryland Rule 7-114(c)(4); the 15 October 2025 order vacated ↩
2. Kourmadas v. Brinkwood Community Association, Inc., No. 358, September Term 2025, Appellate Court of Maryland — UNREPORTED opinion by Arthur, J., filed 29 April 2026; Circuit Court for Montgomery County No. C-15-CV-24-004508; not precedent under Md. Rule 1-104 ↩
3. Carey v. Kingsport Community Association, Inc., No. 420, September Term 2025, Appellate Court of Maryland — UNREPORTED opinion by Nazarian, J., filed 11 August 2026; Circuit Court for Anne Arundel County No. C-02-CV-18-003339; not precedent under Md. Rule 1-104 ↩
4. Thomas v. Patriot Square Homeowners' Association, Inc., No. 2189, September Term 2023, Appellate Court of Maryland — UNREPORTED opinion by Harrell, J. (Senior Judge, Specially Assigned), filed 5 February 2025; Circuit Court for Talbot County No. C-20-CV-22-000075; not precedent under Md. Rule 1-104 ↩
5. Vargas v. Franklin Farms Homeowners Association, Inc., No. 282, September Term 2024, Appellate Court of Maryland — UNREPORTED opinion by Sharer, J. (Senior Judge, Specially Assigned), filed 22 April 2025; Circuit Court for Prince George's County No. CAE21-10014; not precedent under Md. Rule 1-104 ↩