[// GUIDANCE: This template is drafted to comply with the Maryland District Court “small claims” procedures (Courts & Jud. Proc. § 4-405 et seq. and Md. Rules, Title 3). Customize bracketed fields and remove guidance notes before filing. Because small-claims proceedings are intended to be simple and informal, this pleading is intentionally concise while still preserving every material defense and optional counterclaim rights. ]
I. DOCUMENT HEADER
IN THE DISTRICT COURT OF MARYLAND FOR [COUNTY]
| Case No. | [CASE NUMBER] |
| Claim Amount | $[AMOUNT] (exclusive of interest, costs, and fees) |
| Plaintiff | [PLAINTIFF LEGAL NAME] |
| Defendant | [DEFENDANT LEGAL NAME] |
DEFENDANT’S ANSWER, AFFIRMATIVE DEFENSES, AND (IF ANY) COUNTERCLAIM
Filed: [MM/DD/YYYY]
II. RECITALS & APPEARANCE
-
Defendant [DEFENDANT NAME] (“Defendant”) respectfully appears, pursuant to the Maryland Rules of Procedure governing small-claims actions, and submits this Answer to the Complaint (the “Complaint”) filed by [PLAINTIFF NAME] (“Plaintiff”).
-
This Answer is timely because it is filed within [15] days of service of the Complaint, in accordance with the Maryland District Court deadline for a Notice of Intention to Defend in small-claims matters.
[// GUIDANCE: 15 days if served within Maryland; 60 days if served outside Maryland.]
III. GENERAL DENIAL
Except as expressly admitted herein, Defendant denies each and every allegation, legal conclusion, and prayer for relief set forth in the Complaint and demands strict proof thereof at trial.
IV. SPECIFIC RESPONSES TO COMPLAINT PARAGRAPHS
| Complaint ¶ | Defendant’s Response |
|---|---|
| 1. | [ADMIT / DENY / LACK KNOWLEDGE] |
| 2. | [ADMIT / DENY / LACK KNOWLEDGE] |
| 3. | … |
| N. | … |
[// GUIDANCE: Insert additional rows as required. “Lack knowledge” functions as a denial under Md. Rules.]
V. AFFIRMATIVE DEFENSES
Without conceding any burden of proof, and reserving the right to amend, Defendant asserts the following defenses, each of which is pled in the alternative:
- Failure to State a Claim – The Complaint fails to state facts upon which relief can be granted.
- Statute of Limitations – The claim (or portions thereof) is barred by the applicable limitations period.
- Payment / Accord and Satisfaction – Any alleged obligation has been paid, settled, or otherwise discharged.
- Lack of Privity – No contractual or legal relationship exists between Plaintiff and Defendant giving rise to liability.
- Set-off / Recoupment – Amounts sought are subject to reduction or elimination due to Plaintiff’s own indebtedness or wrongful conduct.
- Estoppel & Waiver – Plaintiff’s actions and/or omissions preclude the asserted claims.
- Failure of Consideration – Any alleged contract lacks valid consideration.
- Illegality / Unenforceability – The underlying agreement, if any, is void or unenforceable.
- Comparative / Contributory Negligence – Plaintiff’s own negligence caused or contributed to the alleged loss.
- Reservation of Additional Defenses – Defendant reserves the right to raise additional defenses as discovery and investigation proceed.
VI. COUNTERCLAIM (OPTIONAL)
[// GUIDANCE: Counterclaims must not exceed the $5,000 jurisdictional cap to remain in small-claims. Delete this section if no counterclaim is asserted.]
-
Parties & Jurisdiction
a. Counter-Plaintiff: [DEFENDANT NAME] (in Counterclaim capacity, “Counter-Plaintiff”).
b. Counter-Defendant: [PLAINTIFF NAME] (“Counter-Defendant”).
c. This Counterclaim arises out of the same transaction or occurrence alleged in the Complaint and falls within the monetary jurisdiction of this Court. -
Factual Allegations
2.1. On or about [DATE], Counter-Defendant … [describe facts giving rise to claim].
2.2. As a direct result, Counter-Plaintiff sustained damages of $[AMOUNT] plus costs and interest. -
Cause(s) of Action
Count I – [e.g., Breach of Contract / Unjust Enrichment]
[State elements concisely.] -
Prayer for Counter-Relief
WHEREFORE, Counter-Plaintiff demands judgment against Counter-Defendant in the amount of $[AMOUNT], together with pre- and post-judgment interest, costs, and any other relief deemed just.
VII. PRAYER FOR RELIEF ON COMPLAINT
WHEREFORE, Defendant respectfully requests that the Court:
a. Enter judgment in favor of Defendant and against Plaintiff;
b. Dismiss the Complaint with prejudice;
c. Award Defendant costs and any other relief the Court deems just and proper.
VIII. VERIFICATION (Self-Represented Litigant Only)
I, [DEFENDANT NAME], solemnly affirm under the penalties of perjury that the statements contained in this Answer are true to the best of my knowledge, information, and belief.
Date: ___ _____
[DEFENDANT NAME], Pro Se
[// GUIDANCE: If represented by counsel, omit the verification and insert counsel’s signature block below.]
IX. SIGNATURE BLOCK
Respectfully submitted,
[ATTORNEY NAME] (Bar No. __)
[LAW FIRM NAME]
[ADDRESS]
[TELEPHONE] | [EMAIL]
Counsel for Defendant
X. CERTIFICATE OF SERVICE
I hereby certify that on this ___ day of ____, 20__, a copy of the foregoing Answer, Affirmative Defenses, and Counterclaim was mailed first-class, postage prepaid, or electronically served in accordance with Maryland rules, to:
[PLAINTIFF / PLAINTIFF’S COUNSEL]
[MAILING ADDRESS / EMAIL]
[ATTORNEY OR DEFENDANT SIGNATURE]