[// GUIDANCE: This template is drafted for use in the Circuit Court for any county in Maryland.
• Maryland is a contributory-negligence jurisdiction—any contributory fault by the Plaintiff is a complete bar to recovery.
• For claims exceeding $75,000, Md. Rule 2-305 prohibits pleading a specific dollar amount—use “in excess of $75,000.”
• Noneconomic damages are capped by Md. Code Ann., Cts. & Jud. Proc. § 11-108; confirm the cap that applies on the date the cause of action arose and insert it where indicated.
• Maryland recognizes joint-and-several liability among joint tortfeasors pursuant to Md. Code Ann., Cts. & Jud. Proc. § 3-1401 et seq.
• Remove brackets and fill all placeholders before filing.
]

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IN THE CIRCUIT COURT FOR
[_] COUNTY, MARYLAND
========================================================
[PLAINTIFF FULL LEGAL NAME], )
Plaintiff, )
)
v. ) Case No.: ____
)
[DEFENDANT FULL LEGAL NAME], )
Defendant. )
_________)

COMPLAINT FOR PERSONAL INJURY (NEGLIGENCE)

Plaintiff, [PLAINTIFF FULL LEGAL NAME] (“Plaintiff”), by and through undersigned counsel, files this Complaint against Defendant, [DEFENDANT FULL LEGAL NAME] (“Defendant”), and alleges as follows:

I. DOCUMENT HEADER

1. Effective Date of Filing. This Complaint is filed as of [DATE OF FILING] in accordance with Maryland common and statutory tort law (“Governing Law”).

2. Parties Identification. The parties are identified in Section III below.

3. Jurisdiction & Venue. The Circuit Court for [__] County has subject-matter jurisdiction under Md. Code Ann., Cts. & Jud. Proc. § 1-501 and proper venue under Md. Code Ann., Cts. & Jud. Proc. § 6-201 because [BRIEFLY STATE VENUE FACTS].

II. DEFINITIONS [OPTIONAL]

For ease of reference, the following terms, when capitalized, have the meanings set forth below:

A. “Accident” means the incident that occurred on [DATE OF INCIDENT] at or near [LOCATION], as more fully described in Section IV.

B. “Economic Damages” means past and future medical expenses, lost wages, loss of earning capacity, and other pecuniary losses proved at trial.

C. “Noneconomic Damages” has the meaning set forth in Md. Code Ann., Cts. & Jud. Proc. § 11-108 and includes, without limitation, pain, suffering, inconvenience, physical impairment, disfigurement, loss of consortium, and other nonpecuniary losses.

III. PARTIES

4. Plaintiff. Plaintiff is an adult resident of the State of [STATE OF RESIDENCE] residing at [ADDRESS]. At all relevant times, Plaintiff was lawfully present at the Accident location.

5. Defendant. Defendant is a [CORPORATION / INDIVIDUAL] with its principal place of business / residence at [ADDRESS], and at all relevant times transacted business and/or committed tortious acts in Maryland.

6. Service. Defendant may be served through its resident agent, [NAME & ADDRESS], pursuant to Md. Rule 2-121.

IV. FACTUAL ALLEGATIONS

7. On [DATE OF INCIDENT] at approximately [TIME], Plaintiff was [DESCRIBE PLAINTIFF’S ACTIONS] at [LOCATION].

8. At the same time and place, Defendant [DESCRIBE DEFENDANT’S ACTIONS OR OMISSIONS] (“Negligent Acts”).

9. Defendant owed Plaintiff a duty to exercise reasonable care under the circumstances, including but not limited to the duties imposed by the common law of negligence and applicable statutes and regulations.

10. Defendant breached that duty by, inter alia, [LIST SPECIFIC BREACHES—e.g., failing to keep a proper lookout, operating a vehicle while distracted, violating Md. Transp. Art. § 21-901.1].

11. As a direct and proximate result of Defendant’s Negligent Acts, Plaintiff suffered serious bodily injuries, including but not limited to [LIST INJURIES], incurring Economic Damages and Noneconomic Damages.

V. COUNT I – NEGLIGENCE

12. Plaintiff realleges and incorporates by reference Paragraphs 1–11 as though fully set forth herein.

13. Duty. Defendant owed Plaintiff the legal duties described in Paragraph 9.

14. Breach. Defendant breached those duties through the Negligent Acts described in Paragraph 10.

15. Causation. Defendant’s breach was the direct, legal, and proximate cause of the injuries and damages sustained by Plaintiff.

16. Damages. Plaintiff has sustained and continues to sustain:

a. Economic Damages in an amount to be proven at trial, including medical expenses, lost wages, and diminished earning capacity; and
b. Noneconomic Damages in an amount not to exceed the statutory cap set forth in Md. Code Ann., Cts. & Jud. Proc. § 11-108, presently $[INSERT CURRENT CAP] for causes of action arising on or after [APPLICABLE DATE].

17. Joint and Several Liability. To the extent any additional tortfeasors are later joined, Defendant is jointly and severally liable under the Uniform Contribution Among Joint Tort-Feasors Act, Md. Code Ann., Cts. & Jud. Proc. § 3-1401 et seq.

18. Compliance with Conditions Precedent. All conditions precedent to the maintenance of this action have been performed, satisfied, or waived.

VI. PRAYER FOR RELIEF

WHEREFORE, Plaintiff respectfully requests that this Court:

A. Enter judgment in favor of Plaintiff and against Defendant on Count I in an amount:

1. For Economic Damages in excess of $75,000, the exact amount to be proven at trial;
2. For Noneconomic Damages up to the maximum permitted by Md. Code Ann., Cts. & Jud. Proc. § 11-108;

B. Award pre-judgment and post-judgment interest as allowed by law;

C. Award costs of this action pursuant to Md. Rule 2-603;

D. Grant such other and further relief as the Court deems just and proper.

VII. DEMAND FOR JURY TRIAL

Pursuant to Article 23 of the Maryland Declaration of Rights and Md. Rule 2-325(a), Plaintiff demands a trial by jury on all issues so triable.

VIII. GENERAL PROVISIONS

19. Amendment. Plaintiff reserves the right to amend this Complaint to conform to evidence pursuant to Md. Rule 2-341.

20. Reservation of Rights. Nothing herein shall be construed as a waiver of any right, claim, or defense available to Plaintiff under Maryland or federal law.

IX. SIGNATURE BLOCK

Respectfully submitted,

[ATTORNEY NAME] (Bar No. [__])
[LAW FIRM NAME]
[ADDRESS]
[TEL] | [EMAIL]
Counsel for Plaintiff

X. VERIFICATION [OPTIONAL – use if required by specific cause of action]

I, [PLAINTIFF NAME], being duly sworn, depose and state under the penalties of perjury that the foregoing facts are true and correct to the best of my knowledge, information, and belief.

[PLAINTIFF NAME]

Subscribed and sworn before me on this _ day of _, 20__, by [PLAINTIFF NAME].

Notary Public
My Commission Expires: _______