Cerrato v. Garner

CourtCourt of Special Appeals of Maryland
DecidedMarch 1, 2023
Docket0301/22
StatusPublished

This text of Cerrato v. Garner (Cerrato v. Garner) is published on Counsel Stack Legal Research, covering Court of Special Appeals of Maryland primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Cerrato v. Garner, (Md. Ct. App. 2023).

Opinion

Jose Ortiz Cerrato v. Toni Garner, et al., No. 301, September Term, 2022. Opinion by Albright, J.

MARYLAND SECURITY DEPOSIT ACT – DEFINITION OF A SECURITY DEPOSIT – A tenant’s voluntary, advance payment of rent meets the broad definition of a security deposit under the Act, which includes any “payment of money” that protects a landlord against certain categories of risk, such as the risk of non-payment of rent. Advance payment of rent necessarily protects the landlord against that risk. Md. Code Ann., Real Prop. § 8-203(a).

MARYLAND SECURITY DEPOSIT ACT – LIABILITY FOR EXCESSIVE SECURITY DEPOSIT – A landlord does not violate the Act by accepting a tenant’s voluntary, advance payment of rent for all but the last month of the term because liability under the Act is conditioned upon a landlord’s imposition or charging of a security deposit in excess of the equivalent of two months’ rent. By choosing this language, the Legislature limited liability under the remedial statute to cases where a landlord demands or requires a security deposit in excess of the statutory maximum and mere acceptance of advance rent does not suffice. Md. Code Ann., Real Prop. § 8-203(b). Circuit Court for Anne Arundel County Case No. C-02-CV-19-003370

REPORTED

IN THE APPELLATE COURT

OF MARYLAND*

No. 301

September Term, 2022

______________________________________

JOSE ORTIZ CERRATO

v.

TONI GARNER, ET AL.

Wells, C.J. Albright, Eyler, Deborah S., (Senior Judge, Specially Assigned)

JJ. ______________________________________ Pursuant to the Maryland Uniform Electronic Legal Materials Act (§§ 10-1601 et seq. of the State Government Article) this document is authentic. Opinion by Albright, J. 2023-03-01 12:26-05:00 ______________________________________

Filed: March 1, 2023 Gregory Hilton, Clerk

*At the November 8, 2022 general election, the voters of Maryland ratified a constitutional amendment changing the name of the Court of Special Appeals of Maryland to the Appellate Court of Maryland. The name change took effect on December 14, 2022. In July 2019, Jose Ortiz Cerrato (“Mr. Ortiz”)1, appellant, leased a residential

property from Toni and Richard Garner (“the Garners”), appellees, for one year. Before

signing the lease agreement, Mr. Ortiz and his wife, Denise Cintron (“Ms. Cintron”), who

was not on the lease and is not a party to this case, offered to pay the full 12 months’ rent

upfront, in addition to a “security deposit” equivalent to one months’ rent, in exchange for

a reduction in the monthly rent. The Garners accepted that offer.

After Mr. Ortiz and his family had lived at the property for four months, he filed

suit against the Garners in the District Court of Maryland for Anne Arundel County and

prayed a jury trial. The case was then transferred to the Circuit Court for Anne Arundel

County. Mr. Ortiz asserted multiple claims, including that the Garners had violated Md.

Code, Real Prop. § 8-203(b) (1974, 2015 Repl. Vol), prohibiting excessive security

deposits (“Count I”). On cross-motions for summary judgment, the circuit court resolved

Count I in favor of the Garners. After disposition of the remaining claims in the case,2 Mr.

Ortiz appealed, raising a single question,3 which we have rephrased as:

Did the circuit court err by ruling that a landlord does not violate Real Prop. § 8-203 by accepting a tenant’s unilateral offer to prepay rent?

1 Appellant’s counsel refers to Appellant as Mr. Ortiz, so we will as well. 2 Those claims are not before us in this appeal. 3 The question as posed by Mr. Ortiz is: “Whether the Circuit Court erred by misinterpreting Real Property § 8-203 by excluding from the statute any voluntary agreement between a tenant and landlord regarding advance payment of rent as a security deposit, and therefore applying the incorrect standard in ruling in favor of Defendants on summary judgment.” For the following reasons, we conclude that on these undisputed facts, the circuit court did

not err and affirm the judgment of the circuit court.

BACKGROUND

I. Maryland Security Deposit Act

Security deposits are governed by Real Prop. § 8-203. Subsection (a) defines a

security deposit to mean:

any payment of money, including payment of the last month’s rent in advance of the time it is due, given to a landlord by a tenant in order to protect the landlord against nonpayment of rent, damage due to breach of lease, or damage to the leased premises, common areas, major appliances, and furnishings.

Real Prop. § 8-203(a)(3).

Subsection (b)(1) limits the amount of a security deposit, providing that a “landlord

may not impose a security deposit in excess of the equivalent of two months’ rent per

dwelling unit, regardless of the number of tenants.” If a landlord “charges” more than two

months’ rent “as a security deposit, the tenant may recover up to threefold the extra amount

charged, plus reasonable attorney’s fees” in a legal action brought “at any time during the

tenancy or within two years after its termination.” Real Prop. § 8-203(b)(2)-(3).

II. The Residential Lease Agreement

The Garners reside in Alabama and own a single-family home at 4304 Rousbys Run,

West River, Maryland (“the Property”). In mid-July 2019, they listed the Property for rent

for $2,900 per month through Samson Properties, LLC (“Samson”), a real estate broker.

Damien Woodson (“Mr. Woodson”) acted as the listing agent.

2 On July 24, 2019, Mr. Ortiz and Ms. Cintron attended an open house held by Mr.

Woodson at the Property. On or about July 27, 2019, Mr. Ortiz offered to lease the Property

for one year for $2,500 per month and to pay all the rent in advance.4 Mr. Woodson

communicated that offer to the Garners, who accepted it.5

Mr. Woodson prepared a standard form “Residential Lease Agreement” (“the

Lease”) for the Property, dated July 25, 2019. The Garners executed the Lease on July 31,

2019, and Mr. Ortiz did so on August 1, 2019.6 The term of the Lease was one year, from

August 5, 2019 through August 4, 2020.

Paragraph 4 specified that rent payments were to be made in “monthly installments”

of $2,500, with rent due “in advance” on the first day of each month, beginning August 1,

2019. The total rent for the term of the Lease was $30,000. Paragraph 7 specified that the

security deposit was $2,500. Paragraph 14 included information required by statute

concerning the security deposit, including that Mr. Ortiz was obligated to deposit the

amount set out in Paragraph 7 ($2,500) with the Garners and that the Garners

acknowledged receipt of that amount. An integration clause at Paragraph 48 stated that the

4 Mr. Ortiz, who does not speak English as his first language, conveyed the offer to Ms. Cintron, who conveyed it to Mr. Woodson. 5 The Garners, through Mr. Woodson, counter offered $2,700 per month. Mr. Ortiz and Ms. Cintron did not accept that counteroffer and reiterated their initial offer. 6 The first page of the Lease names Richard Garner as the landlord but does not identify a tenant. Mr. Ortiz initialed each page of the Lease and signed on the final page as the tenant. Ms. Garner also signed the Lease and initialed each page as a landlord.

3 Lease was the “full and final agreement between the parties” and that there were “no other

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Cerrato v. Garner, Counsel Stack Legal Research, https://law.counselstack.com/opinion/cerrato-v-garner-mdctspecapp-2023.