Md. Code Ann. Cts. & Jud. Proc. § 5-101

Section 5-101 gives Maryland civil actions a three-year limitations period measured from accrual.

Brown & Sturm v. Field Farms Ltd · filed 1997-08-11

The applicable statute of limitations for a civil action at law in Maryland is three years from the date of accrual of the cause of action. See Md. Code Ann., Cts. & Jud. Proc. § 5-101.

Section 5-101 generally requires a civil action at law to be filed within three years after it accrues unless another Code provision provides a different limitations period.

McNeal v. Montgomery County MD · filed 2009-01-20

The applicable Maryland Statute of Limitations requires that “a civil action at law shall be filed within three years from the date it accrues unless another provision of the Code provides a different period of time within which the action shall be commenced.” ... McNeal was required to file suit within three years of January 2001, which he failed to do.

Section 5-101 generally requires civil actions to be filed within three years after accrual; the court applied that period to bar state-law claims arising from property sales where the plaintiffs were on inquiry notice of their injuries more than three years before suit.

Layani v. Ouazana · filed 2022-10-20

Both the Fourth Circuit and Maryland apply the “injury discovery rule,” which dictates that the limitations period begins to run from “the time the plaintiff discovers, or through the exercise of due diligence, should have discovered, the injury.” ... Because Defendants’ conduct related to the marketing and sale of these properties is not actionable under RICO’s four-year statute of limitations, it follows that suit must also be barred by Maryland’s stricter three-year limitations period. Accordingly, Plaintiffs’ state law counts are dismissed to the extent that they relate to the marketing and sale of the North Hilton Street properties.

Section 5-101 supplies a three-year limitations period for civil actions, which applies to ERISA benefits claims analogous to contract actions.

Cross v. Bragg · filed 2009-07-24

On this point, the parties agree: the three-year Maryland statute of limitations for individual contract actions applies in this dispute. ... The plaintiffs filed their Complaint in the district court on January 3, 2005 — well before the 2008 limitations deadline imposed under Maryland law. We thus reject the defendants’ statute of limitations contention, and conclude that the Complaint was timely filed.

Section 5-101 provides a three-year statute of limitations for the Maryland state-law claims identified by the court, including malicious abuse of process, abuse of process, and conversion.

Rhoads v. State of Maryland Judiciary · filed 2013-10-15

With respect to any potential state law claims against Bank of America, including malicious abuse of process, abuse of process, and conversion, the District Court correctly concluded that Rhoads did not state any timely claims against Bank of America under Maryland law because the claims are governed by a three-year statute of limitations under Maryland law. See Md. Code Ann., Cts. & Jud. Proc. § 5-101. The events at issue occurred in 2003, and Rhoads did not bring this suit until 2013.

Section 5-101 generally requires civil actions to be filed within three years after the claims accrue, unless another limitations period applies.

Martin v. Baltimore City Police · filed 2015-12-17

Martin’s claims, whether brought under state law or 42 U.S.C. § 1983 (2012), were subject to, at longest, a three-year statute of limitations.

Section 5-101 bars the legal remedy for a debt after the limitations period runs, but it does not extinguish the underlying debt.

Dubois v. Atlas Acquisitions LLC · filed 2016-08-25

Under Maryland law, the statute of limitations “does not operate to extinguish [a] debt, but to bar the remedy.” Potterton v. Ryland Grp., Inc., 289 Md. 371, 424 A.2d 761, 764 (1981) (quotation omitted); see also Higginbotham v. Pub. Serv. Comm’n of Md., 412 Md. 112, 985 A.2d 1183, 1191 (2009) (“[W]e have regarded limitations as not denying the plaintiffs right of action, but only the exercise of the right.” (quotation omitted)). Indeed, a stale debt may be revived if the debtor sufficiently acknowledges the debt’s existence.

Section 5-101 provides a three-year limitations period for general civil claims, including the borrowed limitations period for § 1983 claims.

Martin v. Howard Walsh, III · filed 2016-11-23

Martin’s claims, whether brought under state law or 42 U.S.C. § 1983 (2012), were subject to, at longest, a three-year statute of limitations. See Md. Code Ann., Cts. & Jud. Proc. § 5-101 (2013) (general civil statute of limitations); Md. Code Ann., Cts. & Jud. Proc. § 5-105 (2013) (actions for assault and defamation); Owens v. Balt. City State’s Attorneys Office, 767 F.3d 379, 388 (4th Cir. 2014) (§ 1983 claims), cert. denied, 135 S. Ct. 1893 (2015).

Section 5-101 generally requires a civil action to be filed within three years after the claim accrues unless another Code provision provides otherwise.

Brilliant Semenova v. MD Transit Administration · filed 2017-01-10

Critically, however, the Maryland Law does not provide Appellant “the same rights and remedies” as the ADA because it does not provide a cause of action for disability discrimination in the provision of public services. Wolsky, 1 F.3d at 224. Rather, the closer state-law analog to such an ADA claim is Maryland’s more general statute of limitations, requiring plaintiffs to file civil actions “within three years from the date it accrues unless another provision of the Code provides” otherwise. *568Md. Code Ann., Cts. & Jud. Proc. § 5-101; see A Soc’y Without A Name, 655 F.3d at 347.

Section 5-101 supplies a three-year statute of limitations for the claims at issue.

Bailey-El v. Housing Authority of Baltimore · filed 2017-04-27

We first address whether the statute of limitations bars Bailey-El’s First Amendment and procedural due process claims. ... Bailey-El’s claims were subject to a three-year statute of limitations. See Md. Code Ann., Cts. & Jud. Proc. § 5-101 (LexisNexis 2013); Owens v. Baltimore City State’s Attorneys Office, 767 F.3d 379, 388 (4th Cir. 2014). ... We agree with the district court that Bailey-El’s First Amendment claims related to his termination were barred by the statute of limitations. However, we conclude that the untimeliness of Bailey-El’s procedural due process claim related to the denial of a post-termination arbitration hearing was not apparent from the face of the amended complaint.

Section 5-101 generally requires a civil action to be filed within three years after accrual, and under Maryland’s discovery rule a claim accrues when the plaintiff knew or should have known of the actionable harm.

Gillis v. Household Finance Corporation III · filed 2019-07-29

Household Finance’s argument that Plaintiffs’ MCDCA claims are barred by a three-year statute of limitations fails. Maryland law requires “a civil action at law [to be] filed within three years from the date it accrues unless another provision of the Code provides a different time period within which an action shall be commended.” Md. Code Ann., Cts. & Jud. Proc. § 5-101. In Maryland, the “discovery rule” is applied “generally in all civil actions.” Hecht v. Resolution Tr. Corp., 333 Md. 324, 333 (1994). The discovery rule provides that “a cause of action ‘accrues’ when plaintiff knew or should have known that actionable harm has been done to him.” Doe v. Maskell, 342 Md. 684, 690 (1996). As alleged, Plaintiffs did not learn that Household Finance violated the MCDCA until December 2015 when they discovered through discussions with Caliber’s representatives that Household Finance had continued to divert their payments towards unauthorized charges despite its May 2015 admission to this error. ECF No. 1-2 ¶¶ 32–33. Thus, Plaintiffs’ cause of action accrued in December 2015, less than three years before Plaintiffs filed suit in October 2018.

Section 5-101 provides a three-year statute of limitations measured from the date of the occurrence.

Shifflette v. Anzalone · filed 2019-07-31

In Maryland, the applicable statute of limitations is three years from the date of the occurrence. See Md. Code Ann., Cts. & Jud. Proc. § 5-101.

Section 5-101 imposes a three-year limitations period on Maryland Wage and Hour Law and Maryland Wage Payment and Collection Law claims.

Johnson v. Silver Diner, Inc. · filed 2019-08-07

A three-year statute of limitations applies to MWHL and MWPCL claims. See Md. Code Ann., Cts. & Jud. Proc. § 5-101. Plaintiff filed suit on October 2, 2018. See Compl. Therefore, it “is clear from the face of the complaint” that Johnson’s claims for wages from before October 3, 2015 are time-barred.

Section 5-101 supplies a three-year limitations period for claims under the Maryland Wage and Hour Law and Maryland Wage Payment and Collection Law.

Clayton v. Delmarva Community Services, Inc. · filed 2020-03-23

Unlike the FLSA, however, the statute of limitations for the MWHL and the MWPCL is three years. See Md. Code Ann., Cts. & Jud. Proc. § 5-101; see also Guerra v. Teixeira, Civ. No. CV TDC-16-0618, 2019 WL 330871, at *13 (D. Md. Jan. 25, 2019).

Section 5-101 imposes a three-year statute of limitations on civil claims, so a claim may be time-barred when the alleged breach occurred more than three years before suit; allegations of later breaches can make timeliness not apparent on the face of the complaint.

Smith v. Potomac Electric Power Company · filed 2020-04-17

PEPCO also raises a statute of limitations defense against all Plaintiffs, arguing that their claims arose in 2009 and were therefore initiated long after Maryland’s three-year statute of limitations on civil claims had run. See Md. Code Ann., Cts. & Jud. Proc. § 5-101 (LexisNexis 2013). As in Webb, the Court finds that where Plaintiffs McCullough and Powell continued to work for PEPCO in 2017, and the Complaint can be construed to assert that the alleged breach of implied contract included actions occurring in 2017, their breach of implied contract claims are not time-barred on the face of the Complaint, which was filed on June 17, 2019. See Webb, 2020 WL 1083402, at *7. ... Where this case was brought in 2019 and the allegations of Smith and Harris all relate actions taken prior to their retirement in 2015, the Court finds that the breach of implied contract claims of Smith and Harris are time-barred. The Court will therefore dismiss Count III as to Smith and Harris, while allowing Count III to proceed as to McCullough and Powell.

Section 5-101 generally requires a civil action to be filed within three years after it accrues.

Welshons v. Baltimore City Correctional Center · filed 2020-04-22

Because § 1983 does not have its own statute of limitations, the applicable limitations period is the state law statute of limitations for personal injury torts. Wallace v. Kato, 549 U.S. 384, 387 (2007). In Maryland, the applicable statute of limitations is three years. See Md. Code Ann., Cts. & Jud. Proc. § 5-101 (LexisNexis 2013). The question of when a cause of action has accrued under § 1983 is a federal question. See Nassim v. Md. House of Corr., 64 F.3d 951, 955 (4th Cir. 1995) (en banc). The date of accrual occurs “when the plaintiff possesses sufficient facts about the harm done to him that reasonable inquiry will reveal his cause of action.” Id. Here, Welshons was aware of his injury and the failure to transport him to the hospital on the date of the accident: February 4, 2015. Where he did not file this case until August 10, 2018, over three and a half years later, claims against BCCC personnel based on actions taken on the date of the incident are time-barred and will be dismissed.

Section 5-101 requires a civil action to be filed within three years after it accrues unless another statute provides a different limitations period.

White v. City of Hagerstown · filed 2020-06-05

Because Section 1983 does not include a statute of limitations, “courts borrow the statute of limitations from the most analogous state-law cause of action.” Owens v. Baltimore City State’s Attorneys Office, 767 F.3d 379, 388 (4th Cir. 2014). In Maryland, the applicable limitations period is three years. See id. (citing Md. Code Ann., Cts. & Jud. Proc. § 5-101). Here, it is uncontested that White’s Section 1983 claims accrued on October 17, 2015, when all the alleged violations occurred. White did not name Officers Filges and Routhier in his timely October 17, 2018 Complaint. Instead, he named those Defendants in the Amended Complaint filed on April 8, 2019—nearly six months after the three-year statute of limitations had expired. Therefore, on their face, the claims against these Defendants are untimely.

Section 5-101 supplies a three-year statute of limitations for claims under the Maryland Wage and Hour Law and Maryland Wage Payment and Collection Law.

Mendez v. Kuhlman · filed 2020-06-16

Similarly, the MWHL and MWPCL have a three year statute of limitations. See Md. Code Ann., Cts. & Jud. Proc. § 5- 101; Serrano v. Chicken-Out Inc., 209 F. Supp. 3d 179, 188 (D.D.C. 2016); Orellana v. Cienna Properties, LLC, 2012 WL 203421, at *5 (D. Md. Jan. 23, 2012). Plaintiff filed suit on February 26, 2019, and Parties have agreed on the overtime due to Plaintiff for weeks worked within the past three years. As such, the Court finds the amounts the Parties arrived at to be fair and reasonable.

Section 5-101 provides a three-year limitations period for § 1983 claims in Maryland, measured from the date of occurrence.

Gordon v. Wexford · filed 2020-06-26

In Maryland, the applicable statute of limitations is three years from the date of the occurrence. See Md. Code Ann., Cts. & Jud. Proc. § 5-101. ... Because Gordon filed his Complaint on June 5, 2019, claims that predate June 5, 2016 are barred by the statute of limitations. Gordon’s claims against Moss and Barrera arise out of acts and omissions that took place in 2002 and 2013, respectively. Accordingly, even if the Court declined to enter summary judgment in favor of Moss and Barrera, Gordon’s claims against them would nonetheless be dismissed as time barred.

Section 5-101 imposes a three-year limitations period on civil actions.

Brooks v. TVOne, LLC · filed 2020-07-07

Maryland’s three-year statute of limitations for civil actions applies to each of the claims. ... Here, as noted previously, Plaintiff does not contest that she reasonably should have known of the episode at issue when it was originally broadcast in March 2014 and that her defamation claim accrued at that time under existing Maryland law. ... Seeing no basis to depart from basic principles of timeliness, the Court concludes that each of Plaintiff’s remaining claims accrued at the time of the episode’s original broadcast and thus lapsed in March 2017, more than two years before Plaintiff filed her Complaint in this action.

Section 5-101 provides a three-year limitations period for civil actions in Maryland.

Canaan Christian Church v. Montgomery County, Maryland · filed 2020-09-30

All of the events in this case occurred in Maryland. Consequently, Maryland’s three-year statute of limitations for civil actions, Md. Code Ann., Cts. & Jud. Proc. § 5-101 (West 2013), applies to these claims.

Section 5-101 imposes a three-year limitations period on breach-of-contract and tortious-interference claims, and the period runs when the claim accrues.

KVC Waffles Ltd v. New Carbon Company, LLC · filed 2020-10-22

In Maryland, a breach of contract claim is subject to a three-year statute of limitations. Md. Code Ann., Cts. & Jud. Proc. § 5-101; ... The same statute of limitations applies to KVC Waffles’ tortious interference claims. ... The Court is unpersuaded. ... Drawing all inferences in favor of KVC Waffles, as the Court is obliged to do at this stage of the proceedings, the Court can reasonably conclude that KVC Waffles was not on notice that New Carbon was in breach until New Carbon’s letter of January 23, 2017, in which it informed KVC Waffles in no uncertain terms that it was terminating their business relationship. ... Accordingly, the Court cannot conclude at the 12(b)(6) stage that KVC Waffles’ breach of contract claim was untimely. For similar reasons, the Court will deny New Carbon’s motions to dismiss KVC Waffles’ tortious interference claims as untimely.

Section 5-101 provides a general three-year limitations period for civil actions when no more specific limitations period applies.

Joe Hand Promotions, Inc. v. Faruque · filed 2021-06-10

Because Pro Street concerned the same statutes under similar facts present here, the Court adopts its reasoning and applies the three-year limitations period provided in Md. Code Ann., Cts. & Jud. Proc. § 5-101 (West 2014).

Section 5-101 imposes a three-year limitations period on trespass claims, running from accrual when the plaintiff knows or should have known of the injury.

Hardie v. Deutsche Bank Trust Company America · filed 2021-06-16

Under Maryland law, however, a claim for trespass must be filed within three years from the date the action accrues. ... The action accrues when the “plaintiff knows or should have known of the injury giving rise to his or her claim.” ... Where the original Complaint was filed on May 4, 2020, more than three years after the date of the alleged trespass, the Court finds that any trespass claim in Count | based on the August 2016 Incident is time- barred.

Section 5-101 generally requires a civil action at law to be filed within three years after it accrues unless another Code provision sets a different period.

Collington v. Calvert County · filed 2021-07-26

Under Maryland law, “[a] civil action at law shall be filed within three years from the date it accrues unless another provision of the Code provides a different period of time within which an action shall be commenced.”

Section 5-101 supplies Maryland’s general three-year statute of limitations for battery and negligence claims.

Lancaster v. Smith · filed 2021-08-10

Under Maryland law, these claims are subject to the general three-year statute of limitations. Md. Code Ann., Cts. & Jud. Proc. § 5-101.

Section 5-101 provides a three-year limitations period for civil actions in Maryland, including § 1983 claims and detinue actions in this case.

Edokobi v. U.S. Department of Justice · filed 2019-08-21

Where the operative events in this case generally occurred in Maryland, the Court applies Maryland’s three-year statute of limitations for civil actions to § 1983 claims. See Md. Code Ann., Cts. & Jud. Proc. § 5-101 (West 2011); Owens, 767 F.3d at 388. This three-year limitations period also applies to Edokobi’s detinue claim. See Md. Code Ann., Cts. & Jud. Proc. § 5-101; Durst v. Durst, 169 A.2d 755, 757 (Md. 1961) (applying the three-year limitations period to a detinue action).

Section 5-101 gives trespass and conversion claims a three-year limitations period, measured under Maryland's discovery rule from when the plaintiff knew or should have known of the injury.

Hardie v. CIT bank · filed 2021-08-16

Maryland law provides three years to file a claim for trespass. Md. Code Ann., Cts. & Jud. Proc. § 5-101; Litz v. Md. Dep’t of Env’t, 76 A.3d 1076, 1086 (Md. 2013) (“Counts for . . . trespass . . . must be filed within three years from the date the action accrues.”). Maryland courts apply the discovery rule when determining when an action accrued, meaning the limitations period begins when the “plaintiff knows or should have known of the injury giving rise to his or her claim.” Litz, 76 A.3d at 1086. Plaintiffs were alerted “that intruders were breaking into the property” on May 30, 2017. ECF No. 9 ¶ 12. Plaintiffs filed this action on September 12, 2020, ECF No. 1, more than three years from the date the action accrued. Because Plaintiffs did not file suit within the three-year limitations period, their trespass claim will be dismissed.

Section 5-101 requires civil actions at law to be filed within three years after accrual, and that limitations period applies to § 1983 and common-law false-imprisonment claims.

Weiler v. Town of Berwyn Heights, Maryland · filed 2021-10-29

Maryland's statute of limitations provides that “‘[a] civil action at law shall be filed within three years from the date it accrues.’” Goodman, 494 F.3d at 464 (quoting Md. Code Ann., Cts. & Jud. Proc. § 5–101). ... Pursuant to Maryland’s statute of limitations, Plaintiff’s Section 1983 claim expired on June 14, 2017. See Md. Code Ann., Cts. & Jud. Proc. § 5-101; Goodman, 494 F.3d at 464. The cause of action accrued on June 14, 2014 when the confrontation between Plaintiff and Ignwoski occurred. Plaintiff’s makes reference to the fact that the charges against him were placed on a “stet docket” and expired on September 23, 2017, see ECF No. 1 ¶ 44, but that does not change the date of accrual of a cause of action for Section 1983 purposes. The complained of conduct happened on June 14, 2014, regardless of when the charges against him expired. ... Similarly, the same Maryland statute applies to Plaintiff’s common law false imprisonment claim. See Collington v. Maryland, No. 20-cv-966-GJH, 2021 WL 3172275, at *9 (D. Md. July 26, 2021) (applying Section 5-101 to common law false imprisonment claims). While it is not totally clear from the Complaint which alleged conduct constitutes false imprisonment, the Court presumes that the claim is related to either Plaintiff’s arrest and detention by Ignowski or Plaintiff’s 30-day incarceration before he was able to make bail. See ECF No. 1 ¶ 43. The detention then happened between June and July of 2014, but any claim related to detention before September 21, 2017 is time-barred because of Maryland’s statute of limitations.

Section 5-101 supplies a three-year limitations period for the Maryland false imprisonment/arrest claim and the federal § 1983 claims at issue.

Meredith v. Prince George's County · filed 2022-01-10

Maryland law establishes a three-year limitations period for both the false imprisonment/arrest claim and the Section 1983 claims. ... The limitations period therefore ran on Mr. Meredith’s claims on February 25, 2019.

Section 5-101 imposes a three-year limitations period on civil claims.

316 Charles, LLC v. Liberty Mutual Insurance Company · filed 2022-06-08

Ohio Security’s statute of limitations argument is also meritless. Maryland has a three-year limitations period for civil claims. Md. Code Ann., Cts. & Jud. Proc. § 5-101. ... Cazbar moved for leave to amend in March 2022, well within the three-year limitations period for any of these dates.

Section 5-101 requires civil actions at law to be filed within three years after accrual, including Maryland fraud and breach-of-fiduciary-duty claims.

Smith v. Martz · filed 2022-08-29

The statute of limitations in Maryland for fraud and breach of fiduciary duty claims is three years. See Md. Code Ann., Cts. & Jud. Proc. § 5-101 (“A civil action at law shall be filed within three years from the date it accrues . . .”); see also Ladzinski v. MEBA Pension Tr., 951 F. Supp. 570, 574 (D. Md. 1997) (applying the general three-year statute of limitations to breach of fiduciary duty claims).

Section 5-101 requires a civil action to be filed within three years after accrual, with accrual governed by Maryland’s discovery rule and inquiry notice.

Tate v. American General Life Insurance Company · filed 2022-09-13

These claims are untimely. In Maryland, a civil action must “be filed within three years of the date it accrues.” Md. Code Ann., Cts. & Jud. Proc. § 5-101. “In determining when an action accrues, Maryland courts [employ] the discovery rule.” Est. of Adams, 233 Md. App. at 25. Accordingly, “the cause of action accrues when the claimant in fact knew or reasonably should have known of the wrong.” Poffenberger v. Risser, 290 Md. 631, 636 (1981). “The concept of ‘inquiry notice’ controls when limitations begin to run.” Est. of Adams, 233 Md. App. at 25.

Section 5-101 provides a three-year statute of limitations, so claims accruing March 24, 2017 had to be filed by March 24, 2020.

Charette v. Wexford Health Sources Inc. · filed 2022-09-23

The latest date her claims against Rufael and Barry could have accrued is March 24, 2017, when Miller was released on parole. The applicable statute of limitations is three years, so any claim needed to be filed by March 24,2020. See Md. Code Ann., Cts. & Jud. Proc. § 5-101.

Section 5-101 provides a three-year limitations period for claims of this type under Maryland law, and claims based on the alleged mortgage conduct were untimely when filed in 2022.

Oliver v. Wells Fargo Bank, N.A. · filed 2022-12-27

Plaintiff asserts a claim for “predatory lending.” ECF 1 at 6. While the precise nature of her legal claims is not specified, the applicable statute of limitations for claims of this type, under Maryland law, is three years.1 Md. Code Ann., Cts. & Jud. Proc. § 5-101. Plaintiff’s complaint does not allege any actions taken by Wells Fargo after 2018, when it initiated foreclosure proceedings. Thus, any lawsuit contesting any of Wells Fargo’s actions, including its accounting of Plaintiff’s mortgage payments and its conduct surrounding the modification of Plaintiff’s loan, would have had to be filed by, at the latest, 2021. Plaintiff did not file the instant action until August 23, 2022.

Section 5-101 requires civil actions to be filed within three years after the date the action accrues.

Harris v. Wells Fargo Corporate Office Headquarters HQ · filed 2023-01-11

Under Maryland law, Civil actions such as this one must be filed within three years from the date it accrues. Md. Code Ann., Cts. & Jud. Proc. § 5-101. Plaintiff’s letter identifying that Cool Air Express was denied a loan is dated September 17, 2018. More than three years have passed since that date and the Court will therefore dismiss the Complaint with prejudice and without leave to amend.

Section 5-101 requires civil actions on standard contracts to be filed within three years after the claim accrues, unless another Code provision sets a different period.

JTH Tax LLC d/b/a Liberty Tax Service v. Irving · filed 2023-02-01

Maryland law has a three-year statute of limitations to bring suit for standard contracts. Md. Code Ann., Cts. & Jud. Proc. § 5-101. More specifically, “[a] civil action at law shall be filed within three years from the date it accrues unless another provision of the Code provides a different period of time within which an action shall be commenced.” Id. Because the Court has determined that the notes are not under seal and are not negotiable instruments, no other provision of the Maryland Code applies. Consequently, Plaintiffs’ claims concern standard contracts which are subject to a three-year statute of limitations.

Section 5-101 supplies a general three-year limitations period for MWHL and MWPCL claims.

Guillen v. Armour Home Improvement, Inc. · filed 2023-06-05

The MWHL and MWPCL use Maryland’s general three-year statute of limitations, Md. Code Ann., Cts. & Jud. Proc. § 5-101, with the quirk that MWPCL claims do not accrue until two weeks after a missed wage payment, Md. Code Ann., Lab. & Empl. § 3-507.2(a). The relevant period for the MWHL, therefore, extends to August 12, 2016, while the MWPCL effectively extends to July 29, 2016. Guillen received his final paycheck from Armour on August 6, 2018.

Section 5-101 generally requires a civil action to be filed within three years after it accrues unless another Code provision sets a different limitations period.

Chicago Title Insurance Company v. Delgado · filed 2023-07-14

Under Maryland law, a civil action must “be filed within three years from the date it accrues unless another provision of the Code provides a different period of time within which an action shall be commenced.” Md. Code Ann., Cts. & Jud. Proc. § 5-101. ... Chicago Title filed suit on December 7, 2022. Unjust enrichment claims in Maryland are subject to the three-year statute of limitations. See Jason v. Nat’l Loan Recoveries, LLC, 134 A.3d 421, 428 (Md. Ct. Spec. App. 2016). Thus, Chicago Title’s unjust enrichment claim is barred if it is apparent from the face of the complaint that the claim accrued before December 7, 2019. ... Under Hill, Chicago Title conferred a benefit on the Delgados when it paid the balance due on the Countrywide Loan. That payment occurred in November 2021. “[A] cause of action does not accrue until all of its elements are present.” Catler v. Arent Fox, LLP, 71 A.3d 155, 171 (Md. Ct. Spec. App. 2013) (citing Doe v. Archdiocese of Wash., 689 A.2d 634, 638–39 (Md. Ct. Spec. App. 1997)). Thus, the unjust enrichment claim did not accrue until November 2021 at the earliest. Chicago Title filed suit within three years of that date, so the unjust enrichment claim is timely.

Section 5-101 requires a civil action at law to be filed within three years after it accrues unless another Code provision sets a different limitations period.

Siantou v. DK Associates, LLC · filed 2023-07-20

In Maryland, “[a] civil action at law shall be filed within three years from the date it accrues unless another provision of the Code provides a different period of time within which an action shall be commenced.” See Md. Code Ann., Cts. & Jud. Proc. § 5-101. This three-year requirement applies to Wantou’s claims.

Section 5-101 requires a civil action at law to be filed within three years after the date it accrues.

Bailey-Bey v. Mosby · filed 2023-08-03

In Maryland, the applicable statute of limitations is three years from the date of the occurrence. See Md. Code Ann., Cts. & Jud. Proc. § 5-101 (providing that “[a] civil action at law shall be filed within three years from the date it accrues”).

Section 5-101 supplies a three-year limitations period for Maryland personal-injury actions, running from the date the cause of action accrues.

Charette v. Wexford Health Sources Inc. · filed 2023-09-11

As for Charette’s Eighth Amendment claim under Section 1983 (Count II), the Court applies “the statute of limitations for personal injuries of the state in which the alleged violations occurred.” See DePaola v. Clarke, 884 F.3d 481, 486 (4th Cir. 2018). A plaintiff in Maryland must bring a personal injury action within three years of the date the cause of action accrues. Owens v. Balt. City State’s Att’ys Off., 767 F.3d 379, 388 (4th Cir. 2014) (citing Md. Code Ann., Cts. & Jud. Proc. § 5-101).

Section 5-101 provides a three-year general civil limitations period in Maryland.

Grant v. Prince George's County, Maryland · filed 2023-09-18

Under this principle, for § 1983 claims brought in Maryland, courts apply Maryland’s general civil statute of limitations of three years.

Section 5-101 provides a three-year statute of limitations for fraudulent-concealment claims.

Jones v. Nationstar Mortgage LLC · filed 2023-09-29

However, the statute of limitations for fraudulent concealment is three years. Md. Code Ann., Cts. & Jud. Proc. § 5-101; Johnson v. Nadwodny, 461 A.2d 67, 68 (Md. Ct. Spec. App. 1983)).

Section 5-101 requires a civil action to be filed within three years after it accrues unless another Code provision sets a different limitations period.

Carter v. Lindsay Corporation · filed 2023-11-17

Maryland law provides that “[a] civil action at law shall be filed within three years from the date it accrues unless another provision of the Code provides a different period of time within which an action shall be commenced.” Md. Code Ann., Cts. & Jud. Proc. § 5-101. “Under the Maryland statutes, actions for . . . strict liability . . . are barred three years after the cause of action accrues.” ... Here, the cause of action accrued on February 7, 2018, the date of the accident that resulted in Mr. Carter’s death. ... Ms. Carter filed the Complaint on February 6, 2021, just within the three-year mark, which did not include a strict liability claim against L.S. Lee. ... Thus, the statute of limitations will bar her strict liability claim unless she can show that the proposed amended claim relates back to the original Complaint.

Section 5-101 generally provides a three-year limitations period for civil actions, beginning when the plaintiff knows or reasonably should know of the wrong.

Harden v. Budget Rent A Car System, Inc. · filed 2024-03-27

Under Maryland law, the three-year statute of limitations for civil actions and violations of the Maryland Consumer Protection Act starts to run when the plaintiff knows or reasonably should know of the wrong. See Md. Code Ann., Cts. & Jud. Proc. § 5-101; see also Md. Code Ann., Com. Law § 2-725.

Section 5-101 generally requires a civil action to be filed within three years after it accrues.

Schoberg v. Schwartzman · filed 2024-04-23

Statutes of limitations preclude Schoberg’s claims for false imprisonment and intentional infliction of emotional distress, which accrued on the date of his arrest, June 30, 2019. Under Maryland’s three-year statute of limitations, Schoberg therefore needed to file those claims by June 30, 2022. See Md. Code Ann., Cts. & Jud. Proc. § 5-101. However, Schoberg did not formally file his original complaint for over one year past that date, June 30, 2023, albeit with procedural deficiencies.

Section 5-101 requires a civil action to be filed within three years after it accrues, and that limitations period applies to declaratory-relief actions.

Fisher v. Dackman · filed 2024-07-15

In Maryland, a civil action at law must be filed within three years of the date on which it accrues. See Md. Code Ann., Cts. & Jud. Proc. § 5- 101. Maryland courts apply “the period of limitations applicable to ordinary actions at law and suits in equity . . . to actions for declaratory relief.” Com. Union Ins. Co. v. Porter Hayden Co., 698 A.2d 1167, 1193 (Md. Ct. Spec. App. 1997). If a plaintiff seeks declaratory relief “before there has been any breach of the obligation in respect to which said declaration is sought, . . . the right to such relief is not barred by lapse of time.” Jd.

Section 5-101 generally requires a civil tort action for damages to be filed within three years after it accrues, with accrual when the claimant knew or reasonably should have known of the wrong.

White v. Sheraton Hotel North, Beltsville, MD · filed 2024-07-26

In Maryland, a civil tort action for damages must generally be brought “within three years from the date it accrues.” Md. Code Ann., Cts. & Jud. Proc. § 5-101. “[T]he cause of action accrues when the claimant in fact knew or reasonably should have known of the wrong.” ... Here, White’s claim accrued on the date of the alleged tort—sometime in 2011—as that is when she knew of both the nature and cause of the injury. Thus, any claim for damages resulting from the employee’s allegedly tortious act should have been brought no later than 2014.

Section 5-101 requires a civil action to be filed within three years after it accrues, subject to a different statutory period, and the court applied that period from December 18, 2018 here.

Sens v. Whiteford Taylor & Preston, LLP · filed 2021-09-30

Section 5-101 of the Maryland Courts and Judicial Proceedings Article provides that “[a] civil action at law shall be filed within three years from the date it accrues unless another provision of the Code provides a different period of time within which an action shall be commenced.” ... The Court concludes that the limitations period on the Plaintiffs’ claim against the Defendants began to run on December 18, 2018 when the Circuit Court for Baltimore County granted summary judgment in favor of the Sureties in the Surety Lawsuit. Therefore, as detailed below, the Sens Parties timely filed the Initial Complaint on February 28, 2020 because it was filed less than three years later.

Section 5-101 supplies a three-year limitations period for a civil action, and a Maryland § 1983 claim accrues when the plaintiff knew or should have known of the injury and its cause.

Harrison v. DPSCS - Secretary · filed 2022-09-01

For a § 1983 claim arising in Maryland, the applicable statute of limitations is the general civil statute applicable to personal injury suits. See Jersey Heights Neighborhood Ass'n v. Glendening, 174 F.3d 180, 187 (4th Cir. 1999) (“It is well-settled that sections 1983 and 1985 borrow the state’s general personal injury limitations period, which in Maryland is three years.”); Md. Code Ann., Cts. & Jud. Proc. § 5-101 (West 2020) (‘A civil action at law shall be filed within three years from the date it accrues . . .’).

Section 5-101 requires civil claims to be filed within three years after the claims accrue.

Columbus Care and Rehabilitation Center, LLC v. Congressional Bank · filed 2023-01-18

Under Maryland law, civil claims must be filed within three years from the date on which the claims accrue. ... Thus, the Court finds the breach of contract and fraudulent misrepresentation claims to be barred under Maryland’s three-year statute of limitations.

Section 5-101 generally imposes a three-year limitations period on civil actions in Maryland, with accrual governed by the discovery rule.

McClain v. Wells Fargo Bank, N.A., Wells Fargo Home Mortgage · filed 2023-01-30

In Maryland, civil actions are generally subject to a three-year statute of limitations. Md. Code Ann., Cts. & Jud. Proc. § 5-101. Maryland courts have adopted the “discovery rule,” which provides that time does not begin accruing until “the potential plaintiff either discovers his or her injury, or should have discovered it through the exercise of due diligence.”

Section 5-101 requires a civil action to be filed within three years after it accrues unless another Maryland provision provides a different limitations period.

U.S. Bank National Association v. Mitchell · filed 2023-03-09

Under Maryland law, “[a] civil action at law shall be filed within three years from the date it accrues unless another provision of the [Maryland] Code provides a different period of time within which an action shall be commenced.” ... And so, the Court agrees with Ms. Mitchell that USB’s claims for claims for reformation, declaratory judgment, declaration of equitable lien, equitable subrogation, and unjust enrichment accrued no later than, on September 25, 2015, when Ms. Mitchell filed her motion to dismiss the Order to Docket proceedings.

Section 5-101 provides a three-year statute of limitations for Maryland breach-of-contract claims.

Fowose v. Bank of America · filed 2024-06-12

Maryland law generally applies a three-year statute of limitations for breach of contract claims. Md. Code Ann., Cts. & Jud. Proc. § 5-101; see also Dual Inc. v. Lockheed Martin Corp., 857 A.2d 1095, 1099 n.2 (Md. 2004) (applying three-year statute of limitations).

Section 5-101 generally requires a civil action to be filed within three years after accrual unless another provision establishes a different limitations period.

Trattner v. National Western Life Insurance Company · filed 2024-06-28

Under Maryland law, a “civil action at law shall be filed within three years from the date accrues unless another provision . . . provides a different period of time within which an action shall be commenced.” Md. Code Ann., Cts. & Jud. Proc. § 5-101 (West 2020). That limitations period applies to breach of contract actions. ... The Motion to Dismiss will therefore be denied as to the statute of limitations argument.

Section 5-101 sets a three-year limitations period for civil actions, and applicable state tolling principles can extend that period.

Milligan v. May · filed 2024-09-26

In Maryland, the statute of limitations for bringing a civil action, including an action for fraudulent conveyance or unjust enrichment, is three years. See Md. Code Ann., Cts. & Jud. Proc. § 5-101. When a Court applies a state statute of limitations, it also applies state tolling principles.

Section 5-101 subjects Maryland civil claims, including MWPCL claims, to a three-year statute of limitations.

Herbert Core Drill, LLC v. Brothers Mechanical, Inc. · filed 2024-12-03

Claims under the MWPCL and the DCWPL are each subject to a three-year statute of limitations. Md. Code Ann., Cts & Jud. Proc, § 5-101); D.C. Code § 32-1308(c)(1)). ... Therefore, it “is clear from the face of the complaint” that Mr. Hector’s claims for wages before January 17, 2021, are time-barred. ... Those claims are dismissed.

Section 5-101 provides a three-year limitations period, and claims filed more than six years after accrual are barred even if relation back is asserted.

Mbanusi v. Liberty Mutual Insurance Company · filed 2025-05-06

See Md. Code Ann., Cts. & Jud. Proc. § 5-101 (three-year statute of limitations). ... This case is more like English Boiler than Grattan or Florida Steel Corp. ... The new claims do not relate back to the original claims. Because the proposed claims were filed more than six years after they accrued, they are barred by the statute of limitations. ... Moreover, even if the claims related back, they would not have been timely when the original complaint was filed in September 13, 2022. ... Therefore, they would be barred by the statute of limitations even if they related back. Mbanui’s motion for leave to amend is denied.

Section 5-101 requires a civil action at law to be filed within three years after the date it accrues.

Newcomb v. Warden of Kent Co. Det. Center · filed 2025-05-08

In Maryland, the applicable statute of limitations is three years from the date of the occurrence. See Md. Code Ann., Cts. & Jud. Proc. § 5-101 (providing that “[a] civil action at law shall be filed within three years from the date it accrues”).

Section 5-101's general three-year limitations period requires a malicious-prosecution claim to be filed within three years after it accrues.

Reichert v. Hornbeck · filed 2025-07-23

Under Maryland law, a malicious prosecution claim accrues from the date that the criminal proceeding terminates in a plaintiff’s favor. Heron v. Strader, 761 Md. A.2d 56, 59 (Md. 2000). This is the case because “the tort of malicious prosecution includes not only the initiation of criminal proceedings against the plaintiff, but also the termination of those proceedings in the defendant’s favor as a necessary element of the cause of action.” Id. A plaintiff therefore lacks facts to support all the elements for a malicious prosecution claim until the criminal case terminates. Id. In the instant matter, it is undisputed that the relevant criminal proceedings terminated in Plaintiff’s favor on or after August 5, 2021. (ECF No. 57-1 at 23). Thus, Plaintiff’s malicious prosecution claim was required to be filed by August 5, 2024 in order to be timely filed pursuant to Maryland’s general three (3)-year statute of limitations. Md. Code Ann., Cts. & Jud. Proc. § 5-101.

Section 5-101 supplies a three-year limitations period for claims under 42 U.S.C. § 1983 and Article 24 of the Maryland Declaration of Rights.

Mark Vogel Acquisitions, LLC v. Prince George's County MD · filed 2025-08-14

It is also well-established that claims brought pursuant to Sections 1983 and Article 24 of the Maryland Declaration of Rights are subject to a three-year statute of limitations. See Owens, 767 F.3d at 388; see also Md. Code Ann., Cts. & Jud. Proc. § 5-101. ... The Plaintiffs commenced this matter on October 16, 2024, which is well-within the three-year state of limitations period for some of the alleged discriminatory conduct in this case. ECF No. 1.

Section 5-101 generally requires a civil action to be filed within three years after it accrues unless another limitations period applies.

Olanipekun v. Housing Authority of Baltimore City · filed 2025-08-27

Under Maryland law, “[a] civil action at law shall be filed within three years from the date it accrues,” unless another limitations period is specifically provided. Md. Code Ann., Cts. & Jud. Proc. § 5-101. ... As such, any cause of action against HABC must have been filed within at least three years of Plaintiff's departure in 2016. Since Plaintiff waited until the end of 2024 to file suit, Plaintiff's additional (non-discrimination) claims are time-barred and are similarly dismissed.

Section 5-101 generally requires civil actions to be filed within three years, and a claim may be dismissed as time-barred when that bar is clear from the complaint.

Parks v. Jhonson · filed 2025-09-22

The county defendants also assert that any constitutional claims arising out of Parks’s placement on suicide watch before July 29, 2021 must be dismissed for failure to state a claim because they are barred by the three-year statute of limitations. See Wallace v. Kato, 549 U.S. 384, 387 (2007) (explaining that the statute of limitations for § 1983 actions “is that which the State provides for personal injury torts”); Md. Code Ann., Cts. & Jud. Proc. § 5-101 (in general, statute of limitations for civil actions is three years). A claim may be dismissed under Rule 12(b)(6) if it clearly appears on the face of the complaint that the claim is barred by the statute of limitations. ... If it is obvious from the face of the complaint that Parks’s claims against Warden Colbourne arising from his 2020–2021 placements on suicide watch accrued before July 22, 2021, the Court may dismiss the claims as time-barred. It is not so obvious. ... Without any allegations about when Parks learnedthat the Warden became aware of his injuries, the Court cannot conclude from the allegations in the complaint that Parks’s claims against the Warden are barred by the statute of limitations.

Section 5-101 generally requires Maryland civil actions to be filed within three years.

Moore · filed 2025-10-31

Under Maryland law, the statute of limitations for civil actions is generally three years. See Md. Code Ann., Cts. & Jud. Proc. § 5- 101; see also Owens, 767 F.3d at 388 (applying Maryland’s “three-year limitations period” for a personal-injury action to a § 1983 suit). Moore alleges that the incident involving Wilcox occurred in 2021 and claims that the incident involved alleged conduct that would put Moore on immediate notice that he was hurt and that Wilcox was the one who inflicted the injury. ECF 1, at 1. Moore did not, however, file this suit until April 21, 2025, well beyond the three-year statute of limitations that would apply even if the Court considered the event to have occurred on the last day of 2021. Dismissal is therefore appropriate on that ground as well.

Section 5-101 generally requires a civil action to be filed within three years after the claim accrues.

Bhutta · filed 2025-12-18

Maryland’s statute of limitations for fraud or misrepresentation claims is three years. See Md. Code Ann., Cts. & Jud. Proc. § 5-101; James v. Weisheit, 367 A.2d 482, 484-85 (Md. 1977).

Section 5-101 generally requires a civil action to be filed within three years after the claim accrues.

Warn · filed 2026-01-30

Sears also contends that subject matter jurisdiction fails because of “the statute of limitations,” and raises arguments regarding the merits of Warn’s amended complaint. ECF 78, at 3. Although a statute of limitations argument is not relevant to an analysis of diversity of citizenship, the Court will nonetheless address it here. As noted by Warn, the Maryland law applicable to the claims here provides for a statute of limitations of three years. ECF 88, at 2 (citing Md. Code Ann., Cts. & Jud. Proc. § 5-101), Warn contends that the contracts atissue are “dated July 22, 2022, and May 14, 2023,” id., while Sears counters that the agreement was dated “August 2021,” ECF 78, at 2. Either way, the allegations in the complaint fall well within the three-year statute of limitations period, as the complaint was filed on September 11, 2023. See ECF | (initial complaint), Dismissal of the complaint for statute of limitations reasons is not | warranted.

Section 5-101 provides a three-year statute of limitations for negligence claims.

Richburg · filed 2026-03-27

As to the negligence claim (Count 1), the statute of limitations is three years. Md. Code Ann., Cts. & Jud. Proc. § 5-101. Therefore, only alleged breaches that occurred after April 2, 2021 are timely.

Section 5-101 provides a three-year statute of limitations for Maryland personal-injury claims, measured from the date of occurrence.

Falkenstein v. Rahman · filed 2020-03-03

In Maryland, the applicable statute of limitations is three years from the date of the occurrence. See Md. Code Ann., Cts & Jud. Proc. § 5-101.

Section 5-101 bars a claim filed more than three years after it accrued.

Halle Development, Inc. v. Anne Arundel County · filed 2005-02-04

Halle’s cause of action premised on the denial of fee credits thus accrued at that time, and is now barred by Maryland’s three-year statute of limitations.

Section 5-101 provides a three-year limitations period for Maryland civil actions, including the period borrowed for § 1983 claims arising in Maryland.

Potts v. DiPaola · filed 2022-03-02

In Maryland, the applicable statute of limitations is three years from the date of the occurrence. See Md. Code Ann., Cts & Jud. Proc. § 5-101.

Section 5-101 generally requires a civil action to be filed within three years after accrual, with accrual triggered when the claimant knew or reasonably should have known of the wrong; knowledge of the underlying facts, rather than the immediate ability to press a viable claim, starts the period.

Turner v. JP Morgan Chase Bank, N.A. · filed 2013-10-18

“A civil action at law shall be filed within three years from the date it accrues unless another provision of the Code provides a different period of time within which an action shall be commenced.” Id. Maryland follows the discovery rule, which provides that a “cause of action accrues when the claimant in fact knew or reasonably should have known of the wrong.” ... Maryland adheres strictly to this facts-based approach for determining when a claim accrues and consistently maintains that a party’s knowledge of facts, not the party’s unfettered ability to immediately press a viable claim, is the only trigger. ... Accordingly, we reject the Turners’ contention that a favorable decision of the Maryland Special Court of Appeals began the running of the limitations period on their wrongful eviction claim. See Ali v. CIT Tech. Fin. Servs., Inc., 6 A.3d 890, 894-95 (Md. 2010) (explaining that tolling is method by which Maryland legislature has created flexibility in § 5-101’s limitations period).

Section 5-101 requires a civil action to be filed within three years after accrual, and Maryland uses the discovery rule to determine when an action accrues.

Shirley Johnson, Personal Representative of the Estate of Elbert Davis, Sr. v. Baltimore City Police Department · filed 2020-04-07

Maryland law on this point is largely identical, and therefore instructive. It provides that any civil action must be filed “within three years from the date it accrues.” Md. Code Ann., Cts. & Jud. Proc. § 5-101. Because section 5-101 leaves the word “accrues” undefined, Maryland courts use the discovery rule to determine accrual.

Section 5-101 generally requires a civil action at law to be filed within three years after accrual, with accrual determined under Maryland’s discovery rule by when the claimant knew or reasonably should have known of the wrong.

The Chesapeake Bay Foundation v. Weyerhaeuser Company · filed 2014-07-31

Maryland’s statute of limitations provides that “[a] civil action at law shall be filed within three years from the date it accrues unless another provision of the Code provides a different period of time within which an action shall be commenced.” ... Maryland follows the discovery rule, which provides that “the cause of action accrues when the claimant in fact knew or reasonably should have known of the wrong.” ... Viewing the evidence in the light most favorable to the plaintiffs, a genuine dispute exists as to whether knowledge of the water infiltration problem would have put a reasonable person on notice that the Parallams were susceptible to premature deterioration and that their PolyClear 2000 treatment would not preserve them.

Section 5-101 provides a three-year limitations period subject to the discovery rule, which begins when the plaintiff knew or reasonably should have known of the wrong; dismissal is inappropriate when accrual cannot be determined from the pleading.

Ten-X, Inc. v. Pasha Realty Holdings, LLC · filed 2022-04-28

Under Maryland law, the three-year statute of limitations, which the parties agree applies to the counterclaims, is subject to the discovery rule, which starts the clock on the date the plaintiff “knew or reasonably should have known of the wrong.” ... The Court cannot discern from the face of the third amended countercomplaint when Pasha “knew or reasonably should have known of the operative facts giving rise to” its injuries. ... With this question unanswered, and with the defendants failing to respond to Pasha’s contention that the claims accrued in March 2021, the Court cannot determine whether Pasha’s counterclaims against the individual defendants are time- barred. Accordingly, the motion to dismiss is denied.

Section 5-101 requires civil actions to be filed within three years after accrual, and Maryland's discovery rule generally treats a claim as accruing when the claimant has sufficient knowledge to be on inquiry notice.

Shirley Johnson, Personal Representative of the Estate of Elbert Davis, Sr. v. Baltimore City Police Department · filed 2022-06-21

Maryland law on this point is largely identical, and therefore instructive. It provides that any civil action must be filed “within three years from the date it accrues.” Md. Code Ann., Cts. & Jud. Proc. § 5-101. Because section 5-101 leaves the word “accrues” undefined, Maryland courts use the discovery rule to determine accrual. Frederick Road Ltd. P’ship v. Brown & Sturm, 360 Md. 76, 95 (2000) (citing Hahn v. Claybrook, 130 Md. 179, 186-87 (1917)); see also Poffenberger v. Risser, 290 Md. 631, 636 (1981) (expanding the discovery rule’s application to all civil actions). Under the discovery rule, a cause of action accrues “when a claimant gains knowledge sufficient to put him or her on inquiry notice.” Lumsden v. Design Tech Builders, Inc., 358 Md. 435, 447 (2000). A plaintiff is on “inquiry notice” if he “has ‘knowledge of circumstances which would cause a reasonable person in the position of the plaintiff[] to undertake an investigation which, if pursued with reasonable diligence, would have led to knowledge of the alleged [tort].’” Estate of Adams v. Continental Ins. Co., 233 Md. App. 1, 25 (2017) (quoting Lumsden, 358 Md. at 446). The question of when a plaintiff had inquiry notice of his claim is typically one of fact for the jury, O’Hara v. Kovens, 305 Md. 280, 294-95 (1986), since it oftentimes “requires the balancing of factual issues and the assessment of the credibility of believability of the evidence[.]” Frederick Road, 360 Md. at 96. ... Accordingly, Defendants have not met their burden to show that Plaintiffs’ § 1983 claims accrued in the immediate aftermath of the April, 2010 incident, and their motion for summary judgment is denied insofar as it argues that Plaintiffs’ § 1983 claims are time-barred.

Section 5-101 generally requires a civil action to be filed within three years after accrual, but Maryland’s discovery rule tolls the limitations period until the plaintiff discovers or should have discovered the injury through due diligence, and the continuation-of-events principle may further toll it during a fiduciary relationship absent facts prompting reasonable investigation.

Whiteford Taylor and Preston, L.L.P v. SENS, Inc. · filed 2022-07-29

It is well-established under Maryland law that “[a] civil action at law shall be filed within three years from the date it accrues unless another provision of the [Maryland] Code provides a different period of time within which an action shall be commenced.” Md. Code Ann., Cts. & Jud. Proc. § 5-101. Maryland law also recognizes that the discovery rule can toll “the accrual of the limitations period until the time the plaintiff discovers, or through the exercise of due diligence, should have discovered, the injury.” Frederick Rd. Ltd. P’ship v. Brown & Sturm, 756 A.2d 963, 973 (Md. 2000). And so, the limitations period for a civil action begins to run when the plaintiff knows of circumstances which would cause a reasonable person in the plaintiff’s position to investigate with reasonable diligence and such investigation would have led to the discovery of the alleged tort. Pennwalt Corp. v. Nasios, 550 A.2d 1155, 1163 (Md. 1988).

Section 5-101 generally gives civil actions a three-year limitations period; accrual under Maryland’s discovery rule awaits when the plaintiff knows or reasonably should know of the wrong, and disputed accrual facts may preclude summary judgment.

McMillan-McCartney v. McMillan, Jr. · filed 2022-09-30

Defendant also argues that any claims of waste are barred by the applicable three-year statute of limitations. See Md. Code Ann., Cts. & Jud. Proc. § 5-101. The discovery rule, which applies generally in all civil actions, provides that a cause of action accrues when a plaintiff in fact knows or reasonably should know of the wrong. ... Since a factual determination is needed to determine the date of accrual, and genuine disputes remain as to the facts relevant to when Plaintiff knew or should have known about the damage on the Homestead Property, summary judgment is not appropriate.

Section 5-101 requires a civil action to be filed within three years after accrual; for breach of contract, accrual generally occurs at breach but may be postponed by Maryland’s discovery rule.

Goodman v. Praxair, Inc. · filed 2007-07-25

The parties agree that Maryland’s statute of limitations applies, providing, “A civil action at law shall be filed within three years from the date it accrues.” ... In Maryland, a cause of action for breach of contract generally accrues when the contract is breached. ... Although the statute of limitations for breach of contract generally commences on the date of breach, for that is when the cause of action “accrues,” that date may be extended in Maryland by the “discovery rule,” which provides that the limitations period does not begin until the plaintiff learned or should have learned of the breach. ... Accordingly, we conclude that the face of the complaint does not allege facts sufficiently clear to conclude that the statute of limitations had run, and the district court therefore erred in dismissing the complaint on that basis under Rule 12(b)(6).

Section 5-101 gives plaintiffs three years to file a personal-injury action, supplying the limitations period borrowed for § 1983 claims.

Owens v. Baltimore City State's Attorneys Office · filed 2014-09-24

Maryland law affords plaintiffs three years to file a personal-injury action. See Md.Code Ann., Cts. & Jud. Proc. § 5-101. Hence, a three-year limitations period applies to Owens’s claims.

Section 5-101 gives personal injury claims a three-year limitations period measured from the date of occurrence.

Sims v. Maryland Department of Safety and Correctional Services · filed 2020-09-28

Additionally, any allegations relating to conduct in 2015 fall outside of the three-year statute of limitations. ... Md. Code Ann., Cts. & Jud. Proc. § 5-101 (providing the statute of limitations for ... personal injury claims is three years from the date of the occurrence). Accordingly, Sims’ claims against Barnes will be dismissed.

Section 5-101 provides a three-year limitations period for personal-injury claims, measured from the date of the occurrence.

Tang v. Schmoke · filed 2022-06-10

Maryland’s statute of limitations for personal injury claims is three years from the date of the occurrence. Id.; see also Md. Code Ann., Cts. & Jud. Proc. § 5-101.

Section 5-101 supplies a three-year limitations period for personal-injury claims, running from the date of the occurrence.

Tang v. Schmoke · filed 2022-07-25

Maryland’s statute of limitations for personal injury claims is three years from the date of the occurrence. Id.; see also Md. Code Ann., Cts. & Jud. Proc. § 5-101.

Section 5-101 requires personal injury actions at law in Maryland to be filed within three years from the date of occurrence, and that period governs the personal-injury limitations period applied to § 1983 claims.

Collington v. Calvert County · filed 2023-01-31

Since there is “no federal statute of limitations for § 1983 claims, the state limitations period which governs personal injury actions is applied.” Wilkins v. Montgomery, 751 F.3d 214, 223 (4th Cir. 2014). Maryland requires that a personal injury action at law be filed within three years from the date of occurrence. Md. Code Ann., Cts. & Jud. Proc. § 5-101. ... Therefore, the three-year statute of limitations for his claims has expired, and Plaintiff will only be permitted to add the two new Defendants if his amended complaint relates back to the date of the original filing.

Section 5-101 provides a three-year statute of limitations for personal-injury claims.

Cary v. Washington Metropolitan Area Transit Authority · filed 2024-02-08

The District of Columbia and Maryland have a three- year statute of limitations period for personal injury claims. D.C. Code Ann. § 12-301(a)(8); Md. Code Ann., Cts. & Jud. Proc. § 5-101. Virginia’s statute of limitations period for such claims is two years. Va. Code Ann. § 8.01-243(A). Cary did not file this action until October 2023. ECF 1- 1. Accordingly, the relevant statutes of limitations have lapsed and it is too late for him to bring this suit.

Section 5-101 imposes a three-year limitations period on general civil actions.

Martin v. Montgomery County Police · filed 2015-12-17

Martin’s claims, whether brought under state law or 42 U.S.C. § 1983 (2012), were subject to, at longest, a three-year statute of limitations. See Md. Code Ann., Cts. & Jud. Proc. § 5-101 (2013) (general civil statute of limitations); Md. Code Ann., Cts. & Jud. Proc. § 5-105 (2013) (actions for assault and defamation); Owens v. Balt. City State’s Attorneys Office, 767 F.3d 379, 388 (4th Cir. 2014) (§ 1983 claims), cert. denied, 135 S. Ct. 1893 (2015).

Section 5-101 provides a three-year limitations period for civil actions, measured from the date of occurrence.

Certeza v. Krishnaswamy · filed 2019-09-09

In Maryland the general statute of limitations for civil actions is three years from the date of the occurrence. See Md. Code Ann., Cts. & Jud. Proc. § 5-101 (West 2013). ... Thus, under any application of the statute of limitations, any claims arising on or after June 13, 2015 would not be time-barred. ... As of June 13, 2015, when the request for authorization for surgery had not yet been submitted, there is no basis to claim that Certeza’s claim of deliberate indifference to his medical needs had already accrued. Thus, the Court cannot conclude that Certeza’s deliberate indifference claim falls outside the limitations period.

Section 5-101 requires a civil action to be filed within three years after accrual unless another Maryland statute provides a different limitations period.

Bird v. Ocwen Federal Bank, FSB · filed 2019-09-30

Under Maryland law, a civil action must be filed “within three years from the date it accrues unless another provision of the [Maryland] Code provides a different period of time within which an action shall be commenced.” Md. Code Ann., Cts. & Jud. Proc. § 5-101 (West 2019). As Bird has cited no other Code provisions that would extend the statute of limitations on his state claims, the Court concludes that the statute of limitations for those claims is, at most, three years. ... Here, as discussed above, Ocwen assigned the Deed to JP Morgan Chase on November 15, 2000 and, on December 20, 2000, Ocwen executed the Lost Note Affidavit to Homecomings. Bird was aware of these facts through the course of the prior litigation and therefore his claims against Ocwen accrued more than a decade ago, well more than three years ago. As a result, they are now barred by each claim’s statute of limitations.

Section 5-101 provides a general three-year statute of limitations under Maryland law.

Boyd v. SFS Communications, LLC · filed 2021-04-15

As a general proposition, the statute of limitations under Maryland law is three years.

Section 5-101 generally imposes a three-year limitations period on civil claims, including breach-of-contract claims; a qualifying acknowledgment of a contract debt can reset that period, but the opinion does not extend that doctrine to a statutory wage claim.

India Globalization Capital, Inc. v. Apogee Financial Investments, Inc. · filed 2022-03-04

The statute of limitations in New York for breach of contract is six years, see N.Y.C.P.L.R. § 213(2), whereas the statute of limitations in Maryland for breach of contract is three years, see Md. Code Ann., Cts. & Jud. Proc. § 5-101. ... Accordingly, accepting the well-pled allegations in the Amended Counterclaim as true, the December 2018 acknowledgement reset the statute of limitations, moving its expiration to December 2021, well after this claim was filed.

Section 5-101 generally requires Maryland civil claims to be filed within three years after accrual, and an insurance coverage claim accrues when the insurer notifies the insured of an allegedly wrongful denial of coverage.

Betskoff v. Standard Guaranty Insurance Company · filed 2023-07-06

These state law claims are subject to Maryland’s general statute of limitations. See Md. Code Ann., Cts. & Jud. Proc. § 5-101 ... It is well-established that a civil action in Maryland must be filed within three years of the date when the cause of action accrues. Id. And so, in an insurance coverage case, such as this action, Maryland’s three-year statute of limitations begins to run when an insurer notifies the insured of an allegedly wrongful denial of coverage. ... Given this, the latest date on which Plaintiff’s claims in this action could have accrued is May 19, 2017, when Standard denied his most recent insurance claim. And so, to be timely, Plaintiff’s claims based upon the alleged wrongful denial of his insurance claims must have been filed no later than May 19, 2020.

Section 5-101 generally requires a civil action at law to be filed within three years after it accrues unless another statute provides a different limitations period.

Vass v. Nathan · filed 2024-06-18

Regarding Plaintiff’s remaining claims of contempt and abuse of power, the Court reiterates that it is unclear based on Plaintiff’s Amended Complaint and opposition whether these are recognizable causes of action. Regardless, Maryland’s general statute of limitations is three years. See Md. Code Ann., Cts. & Jud. Proc. § 5-101 (“A civil action at law shall be filed within three years from the date it accrues unless another provision of the Code provides a different period of time within with an action shall be commenced.”). All factual allegations in Plaintiff’s Amended Complaint—including those regarding his passport denial—likewise occurred more than three years prior to Plaintiff filing this lawsuit and those claims are therefore untimely and subject to dismissal.

Section 5-101 treats a statute of limitations as governing when a plaintiff may bring a civil action; it does not create a standalone claim.

Hall v. JP Morgan Chase Bank, NA · filed 2020-03-25

A statute of limitations governs when a plaintiff can bring a civil action; it is not itself a type of claim a plaintiff can bring against a defendant.

Section 5-101's three-year limitations period applies to civil actions at law, but not to equitable foreclosure actions.

Ahmed v. NewRez LLC · filed 2020-04-17

Maryland’s general three-year statute of limitations for civil actions applies only to actions at law and thus does not apply to foreclosure actions, which are actions in equity.

Section 5-101's three-year limitations period applies only to actions at law and does not apply to equitable foreclosure actions.

Mobashera B Ahmed · filed 2020-04-17

Maryland’s general three-year statute of limitations for civil actions applies only to actions at law and thus does not apply to foreclosure actions, which are actions in equity. See Md. Code Ann., Cts. & Jud. Proc. § 5-101 (“A civil action at law shall be filed within three years from the date it accrues . . . .”); Hill v. Cross Country Settlements, LLC, 936 A.2d 343, 360 (Md. 2007) (stating that “[m]ortgage foreclosure is an equitable remedy in Maryland”); Brooks, 2019 WL 418412 at *6.

Section 5-101 requires a breach-of-contract action to be filed within three years after it accrues, and the claim accrues only once the contractual obligation and breach exist; where payment is conditioned on consummation of a sale, accrual occurs when the sale is consummated.

Parkway 1046, LLC v. U. S. Home Corporation · filed 2020-06-03

In Maryland, an action for breach of contract must “be filed within three years from the date it accrues.” Md. Code Ann., Cts. & Jud. Proc. § 5-101; see Kumar v. Dhanda, 43 A.3d 1029, 1033–34 (Md. 2012). ... The plain language of the contract supports the district court’s finding that there was no breach—and thus Parkway’s claim did not accrue—until 2017. ... Thus, the Development Contract required U.S. Home to pay Parkway the Reimbursement “at the time of” the “consummation of the purchase and sale,” which occurred on April 21, 2017. J.A. 11, 279. There was no contractual obligation, and no breach, until that time.

Section 5-101 requires a breach-of-contract action to be filed within three years after the claim accrues, with accrual running from the alleged breach.

Robinson v. Pennsylvania National Mutual Casualty Insurance Company · filed 2021-12-16

Under Maryland law, a breach of contract action must be filed within three years of the date that the claim accrues. See Md. Code Ann., Cts. & Jud. Proc. § 5-101. The Fourth Circuit has recognized that this statute of limitations period begins to run from the date of the alleged breach. See Curry v. Trustmark Ins. Co., 600 F. App’x 887, 882 (4th Cir. 2015) (citing Jones v. Hyatt Ins. Agency, Inc., 741 A.2d 1099, 1104 (Md. 1999)).

Section 5-101’s three-year period for a breach-of-contract claim begins when a reasonable person could discover the breach, even if the full extent of damages is not yet known.

Kodor Associates Ltd. Partnership v. Rose · filed 2007-03-20

As the district court found, the extent of the damages sustained by the Koppels, which did not occur until after Rose delivered the incomplete drawings on March 20, 2003, was not the lynchpin for the accrual of the Koppels’ cause of action.3 Rather, it was the point at which a reasonable person could have discovered that a breach had occurred. See Lumsden v. Design Tech Builders, Inc., 749 A.2d 796, 804 (Md. 2000). As the district court held, this point was no later than March 6, 2003, the date the Koppels terminated their contract with Rose, and prior to which they had sustained ongoing damages related to the construction delays caused by Rose’s failure to perform under the contract. Hence, the Koppels’ action for breach of contract, having been filed more than three years after March 6, 2003, was untimely.

Section 5-101’s three-year period for a breach-of-contract claim begins when the alleged continuing-coverage obligation is breached by termination.

The Lebbin-Spector Family Trust by and Through Its Trustees Roger M. Lebbin and Carole Sue Lebbin v. Transamerica Life Insurance Company · filed 2021-08-02

Because the obligations in this case are alleged to be continued coverage, the Plaintiffs’ breach of contract claim is tied to the dates of termination, which were July 9, 2017, and December 20, 2017, respectively. The Plaintiffs filed their complaint in July 2017, within the statute of limitations.

Section 5-101 requires a negligence action to be filed within three years after the claim accrues.

Booker v. The National Fallen Firefighters Foundation · filed 2021-02-11

In Maryland, a negligence action must be filed within three years from the date it accrues. Md. Code Ann., Cts. & Jud. Proc. § 5-101. Booker alleges in the original and in the amended complaint that he was injured on October 9, 2016. (ECF 4 ¶¶ 7, 14; ECF 41-2 ¶¶ 8, 16). Accordingly, his claim accrued at that time. The three-year statute of limitations therefore had expired by the time Booker sought to amend his complaint in October 2020.

Section 5-101 imposes a three-year limitations period that begins when the claimant knew or reasonably should have known of the wrong.

Hardwire, LLC v. Freyssinet International et CIE · filed 2023-02-08

Hardwire’s state law breach of contract claim is subject to Maryland’s three-year limitations period because it is shorter than New York’s six-year statute of limitations. Md. Code Ann., Cts. & Jud. Proc. § 5-101; N.Y. C.P.L.R. § 214(4). Under the Maryland rule, the statute of limitations period runs from when Hardwire “knew or reasonably should have known of the wrong.” Am. Gen. Assur. Co. v. Pappano, 822 A.2d 1212, 1219 (Md. 2003). Defendants rely solely on the familiar argument that Hardwire should have known of Defendants’ alleged misappropriation by February 2015, when they learned that Defendants had won the Kosciuszko Bridge contract. But this argument has already been addressed and rejected. The Court therefore declines to find that Hardwire’s breach claim is untimely as a matter of law.

Section 5-101’s three-year limitations period begins when the plaintiff discovers, or through due diligence should have discovered, the injury.

North Avenue Capital, LLC v. United States of America · filed 2023-04-10

Similarly, this Court concludes that Legalist’s claims are not subject to dismissal pursuant to Maryland’s three-year statute of limitations. See Md. Code Ann., Cts. & Jud. Proc. § 5-101. ... But Maryland applies the “injury discovery rule,” which dictates that the limitations period begins to run from “the time the plaintiff discovers, or through the exercise of due diligence, should have discovered, the injury.” ... Accordingly, the counterclaims are not subject to dismissal on limitations grounds, though they are dismissed for the reasons described above.

Section 5-101 provides a three-year limitations period for Maryland state-law claims, with accrual governed by the injury-discovery rule when the plaintiff discovers or should have discovered the injury through due diligence.

Layani v. Ouazana · filed 2024-12-12

RICO has a four-year statute of limitations, see Agency Holding Corp. v. Malley Duff & Assoc., Inc., 483 U.S. 143, 156–57 (1987), and Plaintiffs’ state-law claims have a three-year limitations period, see Md. Code Ann., Cts. & Jud. Proc. § 5-101. Both the Fourth Circuit (when deciding RICO claims) and Maryland courts apply the “injury discovery rule,” which dictates that the limitations period begins to run from “the time the plaintiff discovers, or through the exercise of due diligence, should have discovered, the injury.” Frederick Rd. L.P. v. Brown & Sturm, 360 Md. 76, 95–96 (2000); see also Potomac Elec. Power Co. v. Elec. Motor & Supply, Inc., 262 F.3d 260, 266 (4th Cir. 2001). A party is on “inquiry notice,” meaning it should have discovered the injury, when it has “knowledge of circumstances which ought to have put a person of ordinary prudence on inquiry … with notice of all facts which such an investigation would in all probability have disclosed if it had been properly pursued.” Windesheim v. Larocca, 443 Md. 312, 327 (2015) (citation omitted); see also Caviness v. DeRand Res. Corp., 983 F.2d 1295, 1303 (4th Cir. 1993).

Section 5-101 generally imposes a three-year limitations period for civil claims, subject to Maryland’s discovery-rule exception when notice of an injury’s nature and cause was not reasonably obtainable.

McGinn v. Broadmead, Inc. · filed 2026-02-18

Generally, Maryland applies a three-year limitations period for civil claims. See Md. Code Ann., Cts. & Jud. Proc. § 5-101 (West 2025). But the discovery rule provides an exception. It protects plaintiffs “where it was not reasonably possible to have obtained notice of the nature and cause of an injury,” and it tolls the limitations period “until the time the plaintiff discovers, or through the exercise of diligence, should have discovered, the injury.” ... But McGinn doesn’t satisfy the conditions to invoke the discovery rule. ... Because McGinn’s alleged gluten exposure occurred in February 2018, the three-year limitations period ran in February 2021. She didn’t file suit until September 2023, so her breach of contract and negligence claims arising from that incident are barred by the statute of limitations.

Section 5-101 imposes a three-year limitations period that begins under Maryland’s discovery rule when the plaintiff knows or reasonably should have known of the wrong.

Tobacco Technology, Inc. v. Taiga International N.V. · filed 2010-07-20

We now turn to the final issue, whether the district court erred in finding the balance of TTI’s tort-based claims barred by the applicable three-year statute of limitations, Md. Code Ann., Cts & Jud. Proc. § 5-101. ... Under Maryland’s “discovery rule,” a statute of limitations begins to run when the plaintiff “kn[ows] or reasonably should have known of the wrong.” ... However, under the “adverse interest exception” to this rule, a principal may “avoid imputation when the agent’s interests are sufficiently adverse” to its own. ... As a result, TTI cannot show that Whitehead acted with “complete adversity” to its own interests, and so is “chargeable with [Whitehead’s] knowledge.” ... TTI’s tort claims are therefore time-barred.

Section 5-101 generally requires a civil action to be filed within three years after accrual, but a continuing harm delays accrual until the harm abates.

Shabazz v. Dept of Pub. Safety & Corr. Servs. · filed 2024-04-18

Appellees are mistaken. Indeed, a civil action ordinarily must be filed within three years from the date it accrues, see Md. Code Ann., Cts. & Jud. Proc. § 5-101, and an action is generally considered to have “accrued” when the wrong is discovered, which, in this case, would have occurred when Shabazz was first required to register. Supik v. Bodie, Nagle, Dolina, Smith & Hobbs, P.A., 152 Md. App. 698, 716-17 (2003). But, when a plaintiff suffers a “continuing harm,” that is, when a defendant is accused of committing an ongoing tort, “every repetition of the wrong creates further liability and creates a new cause of action, and a new statute of limitations begins to run after each wrong perpetuated.” Litz v. Maryland Dep’t of Env’t, 434 Md. 623, 646 (2013) (quotation marks and citation omitted). “Therefore, violations that are continuing in nature are not barred by the statute of limitations merely because one or more of them occurred earlier in time.” Id. (quotation marks and citation omitted). Here, the “harm” was Shabazz’s placement on the sex-offender registry, which began in December 2010. That harm did not abate until, at the earliest, August 24, 2016, when the Department informed Shabazz that he was no longer required to register. Thus, under the continuing harm doctrine, the statute of limitations did not begin to run until August 24, 2016, despite the fact that the harm was discovered well before that date. And, because Shabazz filed the instant complaint on July 18, 2019, his claim was not barred by the three-year statute of limitations.

Section 5-101 generally requires a civil action at law to be filed within three years after accrual, but continuing contractual breaches can cause accrual to occur continuously for damages within the limitations period.

CONTOUR DATA SOLUTIONS LLC v. GRIDFORCE ENERGY MANAGEMENT LLC · filed 2024-08-28

The Maryland Code provides that “[a] civil action at law shall be filed within three years from the date it accrues unless another provision of the Code provides a different period of time within which an action shall be commenced.” ... “[W]here a contract provides for continuing performance over a period of time, each successive breach of that obligation begins the running of the statute of limitations anew, with the result being that accrual occurs continuously and a plaintiff may assert claims for damages occurring within the statutory period of limitations.” ... Although Contour may have learned about an initial material breach in 2016, Gridforce alleges successive breaches under the continuously governing MMSA. ... Therefore, the statute of limitations does not bar Gridforce’s counterclaim.

Section 5-101 requires a civil action at law to be filed within three years after accrual; for these contract claims, accrual occurred when the subcontractor reasonably should have known the contractor would not pay for the requested work.

Hess Construction v. Francis O'Day Co. · filed 2025-02-28

The correct accrual date for claims relating to each PCO is the first date on which F.O. Day “reasonably should have known” that Hess had determined not to pay F.O. Day for all or part of the work requested in that PCO. Est. of Adams, 233 Md. App. at 25 (quoting Poffenberger, 290 Md. at 636); see also Patriot Constr., LLC, 257 Md. App. at 265-66. In the instant case, Hess failed to demonstrate that F.O. Day’s claims accrued prior to May 2017. Accordingly, we hold that F.O. Day’s breach of contract claims relating to PCO 11 and PCO 34 are not barred by the applicable statute of limitations, CJP § 5-101.

Section 5-101 imposes a three-year limitations period for battery claims, measured under Maryland’s discovery rule from when the claimant knew or reasonably should have known of the wrong.

Brown · filed 2026-02-19

On the issue of when a claim accrues for purposes of the statute of limitations, Maryland law applies the discovery rule, under which a limitations period begins to run when “the claimant in fact knew or reasonably should have known of the wrong.” ... Where all of the incidents of physical contact alleged by Caroline Brown occurred prior to April 25, 2022, any claims of battery arising from those incidents are time-barred. ... Where she has not done so, the Court finds that the Amended Complaint does not sufficiently allege a battery claim based on an incident occurring within the limitations period.

Section 5-101 imposes a three-year limitations period on breach-of-contract claims, with accrual governed by Maryland’s discovery rule.

Mbanusi · filed 2026-03-27

Under Maryland law, the statute of limitations for breach of contract claims is three years. Md. Code Ann., Cts. & Jud. Proc. § 5-101. A statute of limitations begins to run when “all of the elements of a cause of action have occurred so that it is complete.” Caruso Builder Belle Oak, LLC v. Sullivan, 330 A.3d 666, 676 (Md. 2025) (quoting Shailendra Kumar, P.A. v. Dhanda, 43 A.3d 1029, 1034 (Md. 2012)) (emphasis removed). But, under the discovery rule, “even if all the elements for a cause of action have been met,” the claim does not accrue until the plaintiff “‘knew or reasonably should have known of the wrong.’” Id. (quoting Cain v. Midland Funding, LLC, 256 A.3d 765, 783 (Md. 2021)). In other words, “the cause of action accrues when the wrong is discovered or when with due diligence it should have been discovered.” Poffenberger v. Risser, 431 A.2d 677, 679 (Md. 1981); see Caruso, 330 A.3d at 676 (discussing rule from Poffenberger). ... Thus, a party asserting a breach of contract claim must file suit within three years of when they knew or should have known the facts giving rise to the alleged breach. See id. ... Thus, as of July 2019, Mbanusi knew the facts underpinning her breach of contract claim. Mbanusi had until July 2022 to bring the claim, but she did not file suit until September 13, 2022. By then, the statute of limitations had expired two months earlier.

Section 5-101's general three-year limitations period applies to civil fraud and conspiracy claims connected to health care when they are not traditional medical-malpractice claims.

Brunenkant v. Suburban Hospital, Incorporated · filed 2026-05-21

Against this backdrop of Maryland legal principles, we are of opinion that the claims alleged by Brunenkant in his fraud and conspiracy complaint fall well within the ambit of section 5-101, and not section 5-109.