Hallam v. New Life Evang. Baptist Church

Summary

The Supreme Court of Maryland held that a borrower who knows or reasonably should know of a defense to a lienholder’s right to foreclose must raise it before the foreclosure sale under Maryland Rule 14-211, including defenses based on fraud, invalidity, or satisfaction of the debt. The borrower may not revive such a defense through post-sale exceptions, regardless of who purchased the property. Although failure to satisfy stay conditions did not itself waive the defenses, the respondents forfeited the opportunity for a merits ruling by failing to pursue available procedures before the rescheduled sale. The court reversed the intermediate appellate judgment and remanded for consideration of the unresolved sale-price issue.