Revising a Maryland judgment: thirty days of broad power, then only three grounds
Maryland procedure · Last verified August 17, 2026
Maryland's post-judgment rule is unusually clean. For thirty days after entry the court has broad revisory power and you do not need a reason beyond persuading it. After thirty days that power collapses to three words — fraud, mistake, irregularity — and those words are read narrowly.
The whole strategy is therefore about which side of day thirty you are on.
The thirty-day window
Md. Rule 2-535(a):
Generally. — On motion of any party filed within 30 days after entry of judgment, the court may exercise revisory power and control over the judgment and, if the action was tried before the court, may take any action that it could have taken under Rule 2-534. A motion filed after the announcement or signing by the trial court of a judgment or the return of a verdict but before entry of the judgment on the docket shall be treated as filed on the same day as, but after, the entry on the docket.
Note what is not in that sentence. No enumerated grounds. No requirement to show excusable neglect, newly discovered evidence, or anything else. Within thirty days the court simply "may exercise revisory power and control over the judgment."
The trigger is entry of judgment — the docket entry. And the rule solves the early-filing problem for you: a motion filed after the judgment is announced or signed but before it hits the docket is treated as filed the same day as entry, but after it. Filing early does not cost you the motion.
In a court-tried case, the thirty-day motion also unlocks everything in Rule 2-534:
In an action decided by the court, on motion of any party filed within ten days after entry of judgment, the court may open the judgment to receive additional evidence, may amend its findings or its statement of reasons for the decision, may set forth additional findings or reasons, may enter new findings or new reasons, may amend the judgment, or may enter a new judgment. A motion to alter or amend a judgment may be joined with a motion for new trial.
Rule 2-534 has its own ten-day deadline when used directly. But Rule 2-535(a) lets the court "take any action that it could have taken under Rule 2-534" on a motion filed within thirty days — so in a bench trial the thirty-day route reaches the same relief.
Newly discovered evidence: also thirty days
Rule 2-535(c) carries the same window:
Newly-discovered evidence. — On motion of any party filed within 30 days after entry of judgment, the court may grant a new trial on the ground of newly-discovered evidence that could not have been discovered by due diligence in time to move for a new trial pursuant to Rule 2-533.
Two conditions: thirty days, and evidence that could not have been discovered by due diligence in time for a Rule 2-533 new trial motion.
After thirty days: fraud, mistake, or irregularity
Rule 2-535(b) is the only route once the window closes, and it has no deadline at all:
Fraud, mistake, irregularity. — On motion of any party filed at any time, the court may exercise revisory power and control over the judgment in case of fraud, mistake, or irregularity. Committee note. — This section is intended to be as comprehensive as Code, Courts Article § 6-408.
"Filed at any time" — there is no outer limit. But the price of that is the narrowness of the three grounds. This is not a general reconsideration provision; it is a targeted remedy, and Maryland reads each of the three terms in a technical sense.
| Timing | What you can ask for |
|---|---|
| Within 30 days | broad revisory power, no grounds required; in a bench trial, everything in Rule 2-534; new trial for newly discovered evidence |
| After 30 days | fraud, mistake, or irregularity only — but with no deadline |
| Any time | correction of clerical mistakes under (d) |
Clerical mistakes are separate
Rule 2-535(d) sits outside both regimes:
Clerical mistakes. — Clerical mistakes in judgments, orders, or other parts of the record may be corrected by the court at any time on its own initiative, or on motion of any party after such notice, if any, as the court orders. During the pendency of an appeal, such mistakes may be so corrected before the appeal is docketed by the appellate court, and thereafter with leave of the appellate court.
The court can do this on its own initiative, at any time. Once an appeal is docketed, it takes the appellate court's leave.
Do not use (d) to fix a substantive problem — a clerical mistake is an error in recording what the court decided, not a disagreement with what it decided.
The District Court equivalent
Maryland's rules run in parallel Titles: Title 2 for the Circuit Courts and Title 3 for the District Court. Rule 3-535 is the District Court counterpart to Rule 2-535, and anyone working on a District Court judgment should read that rule rather than this one — the numbering is deliberately parallel, but the two Titles are not interchangeable.
How Maryland compares
| Maryland | Kentucky | Colorado | Federal | |
|---|---|---|---|---|
| Broad, no-grounds window | 30 days | none | none | 28 days (Rule 59(e)) |
| Grounds after that | fraud, mistake, irregularity | six lettered grounds | five numbered grounds | six numbered grounds |
| Outer limit on those grounds | none | 1 year on (a)–(c) | 182 days on (1)–(2) | 1 year on (1)–(3) |
| Newly discovered evidence | 30 days | 1 year | 182 days | 1 year |
| Early-filed motion protected | yes, expressly | — | — | — |
| Court may fix clerical errors on its own | yes, any time | yes | yes | yes |
Maryland is the mirror image of most states here: a shorter period of broad power, but no outer limit on the narrow grounds.
A short checklist
- Find the date of entry on the docket. Every deadline in this rule runs from it.
- If you are inside thirty days, move under 2-535(a) — and do not over-plead. You are not required to fit a ground.
- If the case was tried before the court, say so — the thirty-day motion reaches all the Rule 2-534 relief, including reopening to take additional evidence.
- Do not worry about filing before the docket entry. The rule treats it as filed the same day, but after, entry.
- For newly discovered evidence, move within thirty days, and be ready to show it could not have been found by due diligence.
- After thirty days, you need fraud, mistake, or irregularity — and you should name which one. There is no deadline, but there is no general reconsideration either.
- Use 2-535(d) only for genuine clerical errors, and remember the court can act on its own.
- If the judgment is a District Court judgment, work from Rule 3-535, not 2-535.
Where these rules live
- Md. Rule 2-311 — Motions
- Md. Rule 2-533 — Motion for new trial
- Md. Rule 2-534 — Motion to alter or amend a judgment — Court decision
- Md. Rule 2-535 — Revisory power
- Md. Rule 3-535 — Revisory power (District Court)
This page explains what the rules say. It isn't legal advice, and what constitutes fraud, mistake or irregularity under Rule 2-535(b) is developed in case law this site doesn't cover.