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Rule 2-643.Release of property from levy

Circuit Court · Last amended July 1, 2026 · Last verified July 13, 2026

This rule prints two full, separately-dated versions in the official compilation (a pending-amendment straddle); both are shown below.

In one sentenceRule 2-643 lets a judgment debtor, or someone else with a stake in the property, get it released from a levy through payment, bond, an exemption election, or a motion to the court.

Full Text of Rule 2-643

Text sizeEffective until July 1, 2026 — jump to: (a) (b) (c) (d) (e) (f)

Effective July 1, 2026 — jump to: (a) (b) (c) (d) (e) (f)

Rule 2-643. Release of property from levy — Effective until July 1, 2026
(a) Upon satisfaction of judgment. — Property is released from a levy when the judgment has been entered as satisfied and the costs of the enforcement proceedings have been paid.
(b) Upon posting bond. — The judgment debtor may also obtain release of property from a levy by filing a bond in an amount sufficient to satisfy the judgment and enforcement costs.
(c) Upon motion of judgment debtor. — Upon motion of the judgment debtor, the court may release some or all of the property from a levy if it finds that (1) the judgment has been vacated, has expired, or has been satisfied, (2) the property is exempt from levy, (3) the judgment creditor has failed to comply with these rules or an order of court regarding the enforcement proceedings, (4) property sufficient in value to satisfy the judgment and enforcement costs will remain under the levy after the release, (5) the levy upon the specific property will cause undue hardship to the judgment debtor and the judgment debtor has delivered to the sheriff or made available for levy alternative property sufficient in value to satisfy the judgment and enforcement costs, or (6) the levy has existed for 120 days without sale of the property, unless the court for good cause extends the time.
The motion and any response to the motion may be accompanied by a request for court review of the sheriff’s appraisal made at the time of the levy.
(d) Upon election of exemption by judgment debtor. — By motion filed within 30 days after a levy, the judgment debtor may elect to exempt from execution of the judgment selected items of property or cash not exceeding in amount the cumulative value permitted by law. The motion and any response to the motion may be accompanied by a request for court review of the sheriff’s appraisal made at the time of the levy. The court shall release from the levy items of cash or property selected by the debtor to the extent required by law.
(e) Upon claim of a third person. — A person other than the judgment debtor who claims an interest in property under levy may file a motion requesting that the property be released. The motion shall be served on the judgment creditor and, if reasonably feasible, on the judgment debtor. If the judgment debtor is not served and does not voluntarily appear, the claimant shall file an affidavit showing that reasonable efforts have been made to ascertain the whereabouts of the judgment debtor and to provide the judgment debtor with notice of the motion. The court may require further attempts to notify the judgment debtor. The judgment creditor or the judgment debtor may file a response to the motion.
(f) Hearing. — A party desiring a hearing on a motion filed pursuant to this Rule shall so request pursuant to Rule 2-311 (f) and, if requested, a hearing shall be held promptly.
Rule 2-643. Release of property from levy — Effective July 1, 2026
(a) Upon satisfaction of judgment. — Property is released from a levy when the judgment has been entered as satisfied and the costs of the enforcement proceedings have been paid.
(b) Upon posting bond. — The judgment debtor may also obtain release of property from a levy by filing a bond in an amount sufficient to satisfy the judgment and enforcement costs.
(c) Upon motion of judgment debtor. — Upon motion of the judgment debtor, the court (1) shall release the property from a levy if it finds that the judgment has been vacated, has expired, or has been satisfied or the property is exempt from levy, and (2) may release some or all of the property from a levy if it finds that:
(A) the judgment creditor has failed to comply with these rules or an order of court regarding the enforcement proceedings,
(B) property sufficient in value to satisfy the judgment and enforcement costs will remain under the levy after the release,
(C) the levy upon the specific property will cause undue hardship to the judgment debtor and the judgment debtor has delivered to the sheriff or made available for levy alternative property sufficient in value to satisfy the judgment and enforcement costs, or
(D) the levy has existed for 120 days without sale of the property, unless the court for good cause extends the time.
The motion and any response to the motion may be accompanied by a request for court review of the sheriff's appraisal made at the time of the levy.
(d) Upon election of exemption by judgment debtor. —
(1) Generally. — By motion filed within 30 days after a levy, the judgment debtor may elect to exempt from execution of the judgment selected items of property or cash not exceeding in amount the cumulative value permitted by law. The motion and any response to the motion may be accompanied by a request for court review of the sheriff's appraisal made at the time of the levy. If subsection (d)(2) of this Rule is applicable, or if no party timely files a response to the motion or request for a hearing, the court may proceed without a hearing. The court promptly shall release from the levy items of cash or property selected by the debtor to the extent required by law. Promptly upon receipt of an order of release from the levy, the person in possession of the property shall comply.
(2) Release of Funds in Deposit Accounts Totaling $6,000 or Less. — If, by motion filed pursuant to subsection (d)(1) of this Rule, the judgment debtor elects up to the maximum exemption permitted by Code, Courts Article, § 11-504(b)(6) for deposit accounts listed in the motion, the court, no later than ten days after the motion was filed, and without holding a hearing or awaiting a response from the judgment creditor, shall order the prompt release from the levy of aggregate account funds totaling $6,000 or less, provided that the record reflects that this exemption has not already been exhausted.
(e) Upon claim of a third person. — A person other than the judgment debtor who claims an interest in property under levy may file a motion requesting that the property be released. The motion shall be served on the judgment creditor and, if reasonably feasible, on the judgment debtor. If the judgment debtor is not served and does not voluntarily appear, the claimant shall file an affidavit showing that reasonable efforts have been made to ascertain the whereabouts of the judgment debtor and to provide the judgment debtor with notice of the motion. The court may require further attempts to notify the judgment debtor. The judgment creditor or the judgment debtor may file a response to the motion.
(f) Hearing. — A party desiring a hearing on a motion filed pursuant to this Rule shall so request pursuant to Rule 2-311 (f). If the party is entitled to a hearing, it shall be held promptly.
End

Amendment History

Effective July 1, 2026

Amended February 19, 2026, effective July 1, 2026.

Committee Note & Source

Effective until July 1, 2026

Source. This Rule is derived as follows:

Section (a) is new. Section (b) is derived from former Rule G51. Section (c) is derived from former Rule G51. Section (d) is new. Section (e) is new. Section (f) is new.

Effective July 1, 2026

Source. This Rule is derived as follows:

Section (a) is new.

Section (b) is derived from former Rule G51.

Section (c) is derived from former Rule G51.

Section (d) is new.

Section (e) is new.

Section (f) is new.

Plain-English Summary

A levy doesn't have to be permanent. Property comes off automatically once the judgment is marked satisfied and the enforcement costs are paid, and a debtor can also buy release by posting a bond large enough to cover the judgment and those costs. Beyond that, a debtor can move the court for release on several grounds: the judgment has been vacated, has expired, or has been satisfied; the property is exempt from execution; the creditor hasn't followed the rules or a court order governing the enforcement proceedings; enough other property remains under the levy to cover the debt; levying on this particular property causes undue hardship and the debtor has offered acceptable substitute property; or the levy has sat for 120 days without a sale and the court hasn't extended that window for good cause. A 2026 amendment reorganizes these grounds so that a vacated, expired, or satisfied judgment, or exempt property, triggers release automatically once found, while the remaining grounds stay within the court's discretion — a distinction worth checking in the version of the rule that applies to your filing date.

Separately, a debtor can elect to exempt specific items of property or cash up to the value the law allows, by motion filed within 30 days after the levy. Starting July 1, 2026, that election gets a fast lane for smaller stakes: if the debtor claims the exemption for deposit account funds up to the statutory cap, the court must order their release within ten days — without a hearing or waiting on the creditor's response — so long as the debtor hasn't already used up that exemption elsewhere. A third person claiming an interest in the levied property can also move for release, serving the creditor and, if feasible, the debtor; if the debtor can't be found, the claimant has to file an affidavit describing the effort made to locate and notify the debtor. Anyone wanting a hearing on one of these motions has to ask for it under Rule 2-311(f), and where a hearing is warranted, it's held promptly.

Frequently Asked Questions

What are the basic ways to get property released from a levy?

Paying off the judgment and costs, posting a bond covering the judgment and costs, filing a motion asking the court to release it, or electing a statutory exemption for specific property or cash.

What grounds can support a motion to release levied property?

A vacated, expired, or satisfied judgment; an exemption; the creditor's noncompliance with the rules or a court order; enough remaining property to cover the debt; undue hardship paired with acceptable substitute property; or a levy that has sat 120 days without a sale.

How does a debtor claim an exemption for specific property?

By filing a motion within 30 days after the levy identifying the property or cash to be exempted, up to the value permitted by law.

Is there a faster process for exempting money in a bank account?

Starting July 1, 2026, yes. If the debtor's exemption motion covers deposit account funds up to the statutory cap, the court must order the release within ten days without holding a hearing or waiting for the creditor to respond.

Can someone other than the debtor get levied property released?

Yes. A third party claiming an interest in the property can file a motion for release, and must serve the creditor and, where feasible, the debtor.

Is a hearing automatic on a motion under this rule?

No. A party who wants a hearing has to request one under Rule 2-311(f); once requested or otherwise warranted, it is held promptly.

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: release property from levy marylandexemption from execution motionmotion to release levythird party claim to levied propertydeposit account exemption garnishment marylandelection of exemption 30 days