GOSHEN RUN HOA v. CISNEROS

No. 3, Sept. Term, 2019.

223 A.3d 917 (2020)

467 Md. 74

GOSHEN RUN HOMEOWNERS ASSOCIATION, INC. v. Cumanda CISNEROS.

Court of Appeals of Maryland.

January 27, 2020.


Attorney(s) appearing for the Case

Argued by Torin K. Andrews (Andrews & Lawrence Professional Services, LLC, Ijamsville, MD) and Argued by Timothy Guy Smith (Law Offices of Timothy Guy Smith, Glenwood, MD), on brief, for Petitioner.

Argued by Martin E. Wolf ( Richard S. Gordon and Ashley A. Wetzel , Gordon, Wolf & Carney, Chtd., Towson, MD; Alexa E. Bertinelli , Civil Justice Inc., Baltimore, MD), on brief, for Respondent.

Dena Elizabeth Robinson , Murnaghan Appellate Advocacy Fellow, Public Justice Center, One North Charles Street, Suite 200, Baltimore, MD 21201, for Amici Curiae Public Justice Center, Cash Campaign of Maryland, Maryland Consumer Rights Coalition, Inc. and Public Justice in Support of Respondent.

Louise M. Carwell, Esquire , Daniel L. Rosenberg, Esquire , Anthony Hayes Davis II, Esquire , William F. Steinwedel, Esquire , (Luyao) Helen L. Zhang, Esquire , Charlotte M. Aheam, Esquire , Legal Aid Bureau, Inc., 500 East Lexington Street, Baltimore, MD 21202, for Amicus Curiae Legal Aid Bureau, Inc., (Maryland Legal Aid) in Support of Respondent.

William D. Gruhn, Esquire , Chief, Consumer Protection Division, W. Thomas Lawrie, Esquire , Assistant Attorney General, Consumer Protection Division, Office of the Attorney General, 200 Saint Paul Place, 16th Floor, Baltimore, MD 21202, for Amicus Curiae Attorney General of Maryland in Support of Respondent.

Argued before: Barbera, C.J., McDonald, Watts, Hotten, Getty, Booth, Irma S. Raker (Senior Judge, Specially Assigned), JJ.


Confessed judgments derive from the ancient legal device of a cognovit note, in which a debtor consents in advance to the holder obtaining a judgment without notice or a hearing. For centuries, the cognovit process has been the subject of much criticism. The United States Supreme Court has noted that the cognovit method has been described...

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