HOLLANDER, Judge.
This criminal case arises from a courtroom brawl that erupted during domestic proceedings before a circuit court master. We must determine whether the authority of a domestic master to conduct and regulate court proceedings includes the power to authorize the arrest of a litigant, pending judicial review of the master’s recommendation of a finding of contempt and immediate incarceration.
Kevin Joseph Wiegmann, appellant, appeared without counsel before a circuit court master for a contempt hearing in connection with his failure to pay court-ordered child support. At the conclusion of the hearing, the master opined that appellant was in contempt and that immediate incarceration was warranted. Consequently, two sheriffs deputies who were stationed in the courtroom attempted to handcuff appellant. A scuffle ensued that culminated in criminal charges against appellant for resisting arrest and assault and battery. Thereafter, a jury in the Circuit Court for Howard County acquitted appellant of resisting arrest, but convicted him of battery. The court sentenced appellant to ninety days of incarceration, with all but ten days suspended, followed by fifteen months of probation.
Appellant timely lodged his appeal and presents three questions for our review, which we have reordered:
I. Did the trial court erroneously restrict defense counsel’s ability to present a defense?
II. Did the trial court err in its instructions to the jury?
[322] III. Was the evidence sufficient to support appellant’s conviction?
We answer the first two question in the affirmative. Accordingly, for the reasons that follow, we shall vacate appellant’s battery conviction and remand for further proceedings.
Factual Summary
The events that spawned the criminal charges occurred on September 21, 1995, when appellant appeared at a hearing before Howard County Circuit Court Master Elaine Patrick (the “master’s hearing”) with respect to his child support obligation.1 A redacted version of the transcript from the master’s hearing was admitted as an exhibit at the criminal trial.2 It indicates the following, in pertinent part:
[MASTER PATRICK]: Based on the evidence I’ve heard today, it is quite clear to me that the defendant is in contempt.
* * * *
So I am going to hold you in contempt. I’m going to sentence you to forty-five (45) days’ incarceration. I’m going to set a purge figure of Thirty-Five Hundred Dollars ($8,500.00), Mr. Wiegmann. That means, if you pay the thirty-five hundred dollars, you do not have to serve the [323] time. That’s the difference between civil and criminal contempt.
In light of your claim to live in Georgia, I am going to recommend that the incarceration he immediate from the courtroom, and that an immediate Order be entered. I’m going to enter a judgment for the arrears, which is Fourteen Thousand, Nine Hundred and Ninety-Three Dollars and Sixty-Five Cents ($14,993.65). Payments through the Department of Social Services, secured by a wage lien. Future service by first-class mail.
Mr. Wiegmann: Your Honor?
The Master: Yes, Mr. Wiegmann?
Mr. Wiegmann: Ah, I want to, like to file my exceptions now.
The Master: Mr. Wiegmann, you can file those prior to your exceptions. I’m going to recommend that an immediate order be entered, so we can—
Mr. Wiegmann: Also, a motion for stay of sentence pending the outcome of the exceptions hearing. And a request for filing fees and costs be paid by the State for my transcripts and other related fees, since I was not — , Public Defender’s — . {To the Deputy) Hold on a second. Hold on a second. Get, get away from me until I’m done.
The Master: Excuse me, Mr. Wiegmann. This is not up to you at this point.
The Deputy: Put your hands behind your back.
The Master: Cooperate with the deputies, Mr. Wiegmann.
(Emphasis added).
The State also called Master Patrick as a witness. She explained that after she announced her findings, appellant approached the bench to file handwritten exceptions and a motion to stay the sentence.3 The master planned “to pass them along to the Judge” so that the court could consider the [324] pleadings in its evaluation of her recommendation. As appellant was speaking to the Master Patrick, she observed that
the deputies were standing, and [appellant] said — he was saying stop, or back up or something. I didn’t understand that because they were just — in my recollection they were just standing there. And then I had his paper, the deputy stepped forward, and then he started saying get away from me, get away from me. I said Mr. Wiegmann, it’s not up to you at this point.
When the master saw appellant’s “arm going up,” she left the courtroom to find another deputy, out of concern that there might be an “incident.”
Master Patrick explained that she recommended immediate incarceration because she did not want appellant, who resided in Georgia, to avoid a jail sentence by flight. Her “concern” about flight was fueled by her belief that appellant had “failed to appear for a prior hearing,” he was in her court on a “cash only bond,” and appellant might not “hang around” if she gave him a surrender date.
Nevertheless, the master recognized that she had no express authority to detain appellant. Indeed, she knew that only a circuit court judge could have incarcerated Wiegmann. The master believed, however, that Maryland Rules 2-541 and S74A4 did not require her to give appellant “an opportunity to make it out the door if what I’m recommending is an immediate incarceration.” Thus, she steadfastly maintained that she was entitled to detain appellant, pending the circuit court’s consideration of her recommendation,, because a contempt order may be entered at any time and because “the proceeding isn’t actually complete until the Judge has an opportunity to rule” on the recommendation for immediate incarceration. [325] Consequently, she thought that “in that moment between making the recommendation for immediate incarceration ... and getting the file down to the Judge and making sure that the hearing proceeds on the recommendation ... in appropriate instances someone may need to be detained in order to insure the ... orderly action on the recommendation.”
The master acknowledged, however, that appellant never made any statements about fleeing. She also conceded that appellant appeared for the hearing even though, based on his own experience, “he understood that one potential outcome of a contempt finding could be incarceration.”5 Nor did the master ever ask appellant to “have a seat” and wait while she referred the matter to a judge. Moreover, in the particular segment of time that is especially relevant here — when appellant was at the bench filing exceptions — there is absolutely no indication in the record of any attempt by appellant to flee the courtroom.
During direct examination, the prosecutor asked the master what she meant when she said it “is not up to you at this point.” The master responded:
I meant that I was going — I wanted the deputies to detain [appellant] because I was going to ... try to get a hearing arranged that day on my recommendation for immediate incarceration, and I was going to have him detained while that process was going forward so we could get it resolved that day---- That’s what I meant by that, that I wanted the deputies to detain [appellant] pending disposition on my recommendation for immediate incarceration.
Master Patrick never specifically instructed the deputies to detain appellant, but she admitted that she intended “to communicate to ... [the deputies] to please escort [appellant] out the back door and hold him until [she] had an opportunity [326] to make arrangements with the Judge to hear the remainder of the proceeding.”6 The master agreed that, when the deputies sought to detain appellant, they were doing just what she wanted them to do, so that she could arrange for a judge to review her recommendations.
Although the master had not anticipated that the deputies would seek to handcuff appellant, she acknowledged that she expected appellant to comply. Moreover, the master conceded that appellant was not free to leave of his own accord. To the contrary, the master agreed that appellant’s “freedom[ ] was taken from him by State authority.” Master Patrick explained that, when she recommends immediate incarceration, “[t]hose gets [sic] done the same day [by the judge] one way or the other.”
Two sheriffs deputies, Corporal James Horan and Deputy Andre Lingham, were assigned to Master Patrick’s courtroom on the day of the incident. Corporal Horan, who testified for the State, recounted that the events in the courtroom unfolded rapidly and simultaneously.
Notwithstanding his fourteen years in the Sheriffs office, Horan testified that he did not know the legal distinction between a master and a judge, the extent of a master’s authority, or the difference between a master’s recommendation and a judge’s order. As a deputy sheriff, Horan stated that he is “the law enforcement arm of the court,” and his duties include courtroom security. He explained that “when a Judge or a Master advises that somebody is going to be taken into immediate custody from the courtroom that is directing that the subject is going to be taken into custody, to our lockup and then to the Detention Center.” Moreover, in his “mind,” the master had ordered appellant taken into custody, and the master is “the ruler of the court----” He said: “She [327] wears the black robes.... And I was directed to do something and I did it....”
Horan thought, based on the master’s initial remarks, that the deputies were supposed to take appellant into custody. When he heard Master Patrick say “immediate incarceration,” he walked to the right side of appellant and Deputy Lingham stood by appellant’s left side. Lingham took out his handcuffs, but the deputies “paused” as appellant discussed the matter with the master at the bench. Appellant then told the deputies to “[h]old on a second” and “get away from me until I’m done.” When the master said “it’s not up to you at this point,” Horan and Lingham “attempted to take [appellant] in custody.” As Lingham tried to handcuff appellant, Wiegmann “jerked and pulled away” and “clenchfed] his fist.” Because appellant raised his fist, Horan believed appellant was going to strike Lingham, and he grabbed appellant’s arm to prevent him from hitting Lingham. Appellant then struck Horan in the jaw and snapped Horan’s head back. Horan thought appellant was attempting to run out of the courtroom.
During the altercation that ensued, the deputies grabbed appellant and all three men fell to the floor “in a big pile.” Fearing that appellant might take Lingham’s weapon, Horan yelled to the master to “hit the alarm.” Horan then grabbed appellant around the neck, jaw, and face, and sprayed him with pepper mace. When other deputies arrived in the courtroom, appellant was handcuffed. As a result of the melee, Horan suffered shoulder and back injuries, for which he was placed on disability for one month and then light duty for several more months.
Malcolm Jacobson, an Assistant State’s Attorney assigned to the Child Support Enforcement Division of the State’s Attorney’s office, appeared as counsel at the contempt proceeding. He testified that he heard Master Patrick find appellant in contempt and “would recommend immediate incarceration.” According to Jacobson, when appellant handed various motions to the master, the two deputies approached appellant; while appellant was talking, one of the deputies [328] “said something about lowering his hands or putting his hands behind him.” Jacobson related that Master Patrick then
said something to the [e]ffect that this was not the right time, referring to the Motions, and the deputies continued to approach Mr. Weigmann. And Mr. Wiegmann said, wait a minute, wait a minute. The deputies were there, and Mr. Wiegmann started to scream, no, no, no, no, no, and started punching at the deputies and a scuffle ensued from there.
Jacobson did not recall that the deputies tiled to hit appellant, although “they were trying to restrain him. [Appellant] was doing all the hitting,” and was “struggling violently.”
At the end of the State’s case, the court denied appellant’s motion for judgment of acquittal. Laura Rosenthal, appellant’s girlfriend, then testified for the defense. She recounted the following:
The Master recommended that Mr. Wiegmann be incarcerated after the hearing, and Mr. Wiegmann proceeded to file exceptions and things that you would file if you were going to be incarcerated. After that — well, he wasn’t even finished. He was in the middle of handing these to the Master and the Sheriff came up behind him and went to grab him. He put his hand back, like this, and he said, I’m not done yet. And then the same Sheriff grabbed him by his arm, shoved it up behind his back and started shoving him toward the other Sheriff who grabbed him by the neck. After that I don’t exactly — everything happened so fast, I don’t know what happened. I mean, the next thing I knew four guys were on top of him.
Appellant, a construction superintendent for a builder of single family homes, testified in his own behalf. He stated that the deputies started to “manhandle” him while he was attempting to file his exceptions and, in a matter of seconds, “the thing got out of hand.” Appellant explained:
[T]he Sheriff had come up behind me and started messing with my left hand as I was trying to hand the documents to the Master at that time. And—
[329] $ $ H* $
[The deputy] was trying to place it behind my back and put what we would call in the military as an arm jack, trying to jack your arm to make you submit to what he was doing.
* * * *
I motioned to him to wait until I was done and then I would go with him, and I started to try to file the things again, and the ... Deputy ... started pushing me in the direction of the other Deputy who immediately came up and grabbed me around the neck area.
Wiegmann further stated that he pushed away one deputy who had grabbed him around the neck in a choke hold because he could not breathe. He was trying to push the deputy away “at the time that [the deputy] was struck.” According to appellant, no one ever told him he was under arrest or ordered him to submit to an arrest. Appellant also thought that, as an experienced litigant, his filing of exceptions would result in an automatic stay of any sentence.
In rebuttal, over defense objection, Corporal Horan testified that he decided to handcuff Wiegmann in the courtroom rather than wait until he had exited the courtroom, because he had been told of an incident in August 1995 when appellant was in court and fled out of the custody of the Sheriffs Department. Horan admitted, however, that he had no personal knowledge about the incident.
We shall include additional facts in our discussion of the issues.
Discussion
I.
As we noted, appellant was charged with resisting arrest and battery. Appellant’s defense rested on his claim that he was illegally arrested and, therefore, he was entitled to resist with reasonable force. In so doing, he denies that he committed a battery.
[330] It is beyond cavil that “the right to resist an unlawful, warrantless arrest remains the law of Maryland.” In re Albert S., 106 Md.App. 376, 397, 664 A.2d 476 (1995). Moreover, “an essential element of [the crime of] resisting arrest is that the arrest be lawful.” Monk v. State, 94 Md.App. 738, 742, 619 A.2d 166 (1993). Thus, when confronted with an unlawful, warrantless arrest, one may lawfully resist by resorting to reasonable force. Dennis v. State, 342 Md. 196, 212, 674 A.2d 928 (1996), aff'd after remand, 345 Md. 649, 693 A.2d 1150 (1997); Barnhard v. State, 325 Md. 602, 614, 602 A.2d 701 (1992); Rodgers v. State, 280 Md. 406, 410, 373 A.2d 944, cert. denied, 434 U.S. 928, 98 S.Ct. 412, 54 L.Ed.2d 287 (1977); Monk, 94 Md.App. at 745, 619 A.2d 166. The right to resist by the use of reasonable force is sometimes referred to as a “privilege.” In re Albert S., 106 Md.App. at 396-97, 664 A.2d 476.
Even when threatened with an illegal, warrantless arrest, however, one may not resist with excessive or unreasonable force. See Rodgers, 280 Md. at 421, 373 A.2d 944; Jenkins v. State, 232 Md. 529, 534, 194 A.2d 618 (1963). The use of excessive force may constitute a battery. See Jenkins, 232 Md. at 534, 194 A.2d 618. In addition, one has no right to use force to resist an unlawful arrest effectuated pursuant to a facially valid warrant. Rodgers, 280 Md. at 419, 373 A.2d 944. In that circumstance, the arrestee must submit and challenge the legality of the arrest in a subsequent judicial proceeding. Id.
As appellant’s defense is grounded on the claim of an unlawful arrest, we pause to consider first whether he was actually arrested. We have little trouble in concluding that he was.
It is undisputed that the deputies sought to handcuff appellant, and this act amounted to an attempt to arrest him. An arrest is defined as “the taking, seizing or detaining of the person of another, inter alia, by any act that indicates an intention to take him into custody and that subjects him to the actual control and will of the person making the arrest.” [331] Morton v. State, 284 Md. 526, 530, 397 A.2d 1385 (1979). The Court of Appeals has explained: “We have defined an arrest in general terms as the detention of a known or suspected offender for the purpose of prosecuting him for a crime. An arrest is effected (1) when the arrestee is physically restrained or (2) when the arrestee is told of the arrest and submits.” Little v. State, 300 Md. 485, 509-10, 479 A.2d 903 (1984) (citations omitted); see also Barnhard, 325 Md. at 611, 602 A.2d 701. In addition, a person is seized within the meaning of the Fourth Amendment when, “ ‘in view of all the circumstances Surrounding the incident, a reasonable person would have believed that he was not free to leave.’” Timms v. State, 83 Md.App. 12, 17, 573 A.2d 397 (quoting Michigan v. Chesternut, 486 U.S. 567, 573, 108 S.Ct. 1975, 1979, 100 L.Ed.2d 565 (1988)) (citations and internal quotations omitted), cert. denied, 320 Md. 801, 580 A.2d 219 (1990); see also In re Joshua David C., 116 Md.App. 580, 593, 698 A.2d 1155 (1997).
In reaching our conclusion that appellant was arrested, we consider it significant that the State candidly conceded at oral argument that the deputies sought to arrest appellant.7 Similarly, at trial, the prosecutor told the judge that “it was by [the master’s] Order that he was detained.... She’s the one who ordered him detained.” The prosecutor also told the trial judge that it was clear that the law enforcement officers were trying to arrest appellant, but asserted that it was not necessary for them to advise appellant of that fact. Further, the master acknowledged that appellant was deprived of his liberty. In addition, the trial court essentially found that appellant was arrested, but she determined that it was under circumstances analogous to an arrest pursuant to a warrant. That the deputies attempted to arrest appellant is also evidenced by [332] the State’s subsequent decision to charge appellant with resisting arrest.
In concluding that appellant was, indeed, arrested, we do not attach significance to the absence of a formal arrest order from the master. In this regard, we observe the State does not seek to uphold the verdict because of the lack of an order from the master directing the deputies to arrest appellant. As we noted, it concedes that the master’s conduct was tantamount to an arrest. It also acknowledges that the master’s remarks were construed by the deputies as an order to arrest. Additionally, there is no question, based on the master’s testimony, that she intended to detain appellant, with handcuffs if need be, and would actually have so ordered, had it been necessary. It was, however, unnecessary, because the deputies immediately understood the master’s remarks as an instruction to take appellant into custody.8 Thereafter, the master condoned the deputies’ actions. She told appellant to cooperate with the deputies as they sought to handcuff him and said that it was “not up to [him] at this point.” At the very least, it is clear that the deputies were doing exactly what the master intended, and the master sanctioned the deputies’ conduct.
We turn to consider the legality of the arrest.
II.
Appellant contends that his arrest was unlawful because the master lacked either express or implied authority to arrest him. He also contends that the arrest was not accomplished pursuant to a warrant, and thus he disputes the trial court’s finding that the arrest was analogous to an arrest pursuant to [333] a warrant, thereby defeating his right to resist. In addition, he claims that he did not commit a crime in the presence of the deputies, so as to entitle them to arrest him. Appellant also argued below that he never refused to submit to an arrest, because “an arrest was never communicated to him. All that was communicated to him was force.”
For its part, the State contends that the master had the right to detain appellant “to insure that her recommendation of immediate incarceration could be implemented,” and that the Maryland rules “implicitly give a master such authority.” In particular, it points to the master’s right to conduct and regulate proceedings in court and argues that this provision inherently includes the power “to briefly detain a defendant for the short time it takes for the court to issue an order in accordance with the master’s recommendation.”9 (Emphasis added). The State also posits that, even if the arrest were illegal, the situation here was analogous to the execution of a facially valid but defective warrant; just as in the case of a defective warrant, the deputies were “merely following the order of a judicial authority.” Therefore, the State suggests that appellant was not entitled to resist, just as one cannot resist an arrest pursuant to a warrant.
At trial, the State had the burden of proving that the arrest was lawful. It is undisputed that there was no warrant for [334] appellant’s arrest. Nor did appellant commit a crime in the presence of the deputies before they approached him with handcuffs. Thus, the legitimacy of the arrest necessarily depends on: (1) the authority of the master, express or implied, to order the seizure of a litigant under the circumstances attendant here or (2) the comparability of the situation here to an arrest pursuant to a facially valid but defective warrant, founded upon the deputies’ good faith belief as to the master’s authority to order appellant’s arrest. We shall consider first whether the master had the authority to arrest appellant.
A.
We recently observed that “the authority of the master[] is limited by the Maryland Rules and the statutes providing for the use of masters in domestic relations cases.” Wise-Jones v. Jones, 117 Md.App. 489, 499, 700 A.2d 852 (1997). This suggests that the master’s authority must derive either from a statute or a rule. We look to Maryland Rules 9-207 and 2-541(c), which govern the powers of a domestic master. Pursuant to Rule 9-207(a)(1), matters of contempt for noncompliance are routinely referred by the clerk to a master “as of course,” unless the circuit court directs otherwise. Rule 9-207(a)(1) specifically authorizes a master to preside at a hearing regarding contempt for noncompliance with an order relating to the payment of alimony or child support. Further, Maryland Rule 9-207(b) provides: “The master shall have the powers provided in Rule 2-541(c) and shall conduct the hearing as provided in Rule 2-541(d).” In turn, Maryland Rule 2-541(c), states, in part, that
a master has the power to regulate all proceedings in the hearing, including the powers to:
(1) Direct the issuance of a subpoena to compel the attendance of witnesses and the production of documents or other tangible things;
(2) Administer oaths to witnesses;
(3) Rule upon the admissibility of evidence;
[335] (4) Examine witnesses;
(5) Convene, continue, and adjourn the hearing, as required;
(6) Recommend contempt proceedings or other sanctions to the court; and
(7) Make findings of fact and conclusions of law.
(Emphasis added).
It is patently clear that the rules do not grant express power to a domestic master to hold a litigant against his will after a non-support hearing,10 although masters are authorized to conduct evidentiary hearings and to make findings of fact and recommendations to the circuit court. Indeed, even Master Patrick agreed that she lacked express authority to arrest appellant. The State is of the view, however, that the rules do not contain an exhaustive list of the master’s powers. In addition to the explicit powers conferred by Rule 2~541(c), the State asserts that the rule implicitly includes the power to detain, because such power is inherent in the authority conferred upon a master to “regulate all proceedings” at a hearing. It thus posits that the master had implied authority, under Maryland Rule 2-541, to detain appellant for a reasonable period, pending judicial review of the master’s recommendations. Therefore, we must determine if the phrase “regulate all proceedings,” as used in Rule 2-541(c), confers upon the master the power to hold someone in custody pending judicial review of a master’s recommendation for immediate incarceration.
As we set about to interpret the rule, we must apply the same standards of construction that apply to the interpretation of a statute. Long v. State, 343 Md. 662, 667, 684 A.2d 445 (1996); In re Victor B., 336 Md. 85, 94, 646 A.2d [336]*3361012 (1994); Davis v. Goodman, 117 Md.App. 378, 700 A.2d 798 (1997); Kerpelman v. Smith, Somerville & Case, L.L.C., 115 Md.App. 353, 357-58, 693 A.2d 357, cert. denied, 346 Md. 241, 695 A.2d 1229 (1997); Miller v. Bosley, 113 Md.App. 381, 393, 688 A.2d 45 (1997). This requires that we ascertain the Court of Appeals’s intent in promulgating the rule. Davis, 117 Md.App. at 399-400, 700 A.2d 798; Morales v. Morales, 111 Md.App. 628, 632, 683 A.2d 1124 (1996), cert. denied, 344 Md. 567, 688 A.2d 446 (1997); Stach v. Stach, 83 Md.App. 36, 40, 42, 573 A.2d 409 (1990). In order to accomplish this task, we are obligated to construe the words in the text in accordance with their ordinary and natural meaning. Long, 343 Md. at 667, 684 A.2d 445; In re Victor B., 336 Md. at 94, 646 A.2d 1012. Moreover, we must give effect to the rule as. a whole, Long, 343 Md. at 667, 684 A.2d 445; In re Victor B., 336 Md. at 94, 646 A.2d 1012, and we are not to embellish a provision so as to enlarge its meaning. See Blitz v. Beth Isaac Adas Israel Congregation, 115 Md.App. 460, 480, 694 A.2d 107, cert. granted, 347 Md. 155, 699 A.2d 1169 (1997).
If the rule is ambiguous, we may look to other sources in order to determine the Court of Appeals’s intent. Long, 343 Md. at 667, 684 A.2d 445; In re Victor B., 336 Md. at 94, 646 A.2d 1012; Leppo v. State Highway Admin., 330 Md. 416, 422, 624 A.2d 539 (1993). Even if the language of a rule is clear, we may consider extrinsic material that “ ‘fairly bears on the fundamental issue’ ” of the purpose or goal of the rule. Stach, 83 Md.App. at 42, 573 A.2d 409 (quoting Kaczorowski v. Mayor of Baltimore, 309 Md. 505, 515, 525 A.2d 628 (1987)). This is because “[o]ur mission is to give the rule a reasonable interpretation in tune with logic and common sense.” In re Victor B., 336 Md. at 94, 646 A.2d 1012. Therefore, we may consider the history of a particular rule as an aid to determining the court’s intent. Long, 343 Md. at 668, 684 A.2d 445; Stach, 83 Md.App. at 42, 573 A.2d 409.
In construing the rule here, we are mindful of the principle that the expression of one tiling is generally the exclusion of another. Long, 343 Md. at 666, 684 A.2d 445; [337] Leppo, 380 Md. at 423, 624 A.2d 539. On the other hand, the use of the word “including” suggests that the seven enumerated powers are not exclusive. “Ordinarily, the word ‘including’ means comprising by illustration and not by way of limitation.” Group Health Ass’n v. Blumenthal, 295 Md. 104, 111, 453 A.2d 1198 (1983); see also Carroll County v. Raymond, I. Richardson Found., Inc., 71 Md.App. 434, 441, 526 A.2d 81 (1987). Nevertheless, the enumerated powers in Rule 2-541(c) are procedural, not substantive. To be sure, the power to arrest is substantive in nature.
We conclude that the rule does not implicitly confer upon the master the power to detain appellant pending judicial review of a master’s recommendation. The construction of the rule urged by the State would engraft upon the rule a meaning not evident from the plain text and would be wholly inconsistent with the advisory, clerical, and ministerial functions that masters have traditionally performed. Construing the nature of the master’s power under the rule as procedural also comports with the traditional functions of the master. We turn to examine the role of a master and his or her corresponding powers.
A master is not a judicial officer, and the Maryland Constitution does not vest a master with any judicial powers. In re Anderson, 272 Md. 85, 106, 321 A.2d 516 (1974), cert. denied, 421 U.S. 1000, 95 S.Ct. 2399, 44 L.Ed.2d 667 (1975); see also Swisher v. Brady, 438 U.S. 204, 209, 98 S.Ct. 2699, 2703, 57 L.Ed.2d 705 (1978) (“masters [in Maryland] are entrusted with none of the judicial power of the State”); Lemley v. Lemley, 102 Md.App. 266, 277, 649 A.2d 1119 (1994) (“[T]he master is not a judge and is not vested with any part of the State’s judicial power.”); Sensabaugh v. Gorday, 90 Md.App. 379, 390, 600 A.2d 1204 (1992) (“Once a master has recommended a contempt proceeding it is necessary for the court to issue the show cause order because the master does not have the power to issue such orders.”). “Simply put, the Master is a ministerial and not a judicial officer.” Levitt v. [338] Levitt, 79 Md.App. 394, 399, 556 A.2d 1162, cert. denied, 316 Md. 549, 560 A.2d 1118 (1989).
In Nnoli v. Nnoli 101 Md.App. 243, 646 A.2d 1021 (1994), we observed that a master has historically been an
“adviser of the court as to matters of jurisdiction, parties, pleading, proof and in other respects where he may be of assistance to the court____ The duties of the master are of an advisory character only. He decides nothing, but merely reports to the court the result of his examination of the proceedings, with a suggestion as to the propriety of the court passing a decree.”
Id. at 261 n.5, 646 A.2d 1021 (quoting Edgar G. Miller, Jr., Equity Procedure § 556, at 654-55 (1897)). Thus, a judge “may never delegate away a part of the decision making function to a master — a non-judicial officer.” Wenger v. Wenger, 42 Md.App. 596, 602, 402 A.2d 94 (1979). Consequently, even when a judge defers to a master’s fact-finding, the judge does not defer to the master’s recommendation as to the appropriate course of action. Id. at 606, 402 A.2d 94; see also Ellis v. Ellis, 19 Md.App. 361, 365, 311 A.2d 428 (1973).
A master is, however, an officer of the court, appointed by the circuit court; that court has constitutional authority to make such appointments.11 Md. Const. art. 4, § 9 (“The Judge, or Judges of any Court, may appoint such officers for their respective Courts as may be found necessary.”); Md. Rule 2-541(a)(3) (“A master serves at the pleasure of the appointing court and is an officer of the court in which the referred matter is pending.”). Nevertheless, a master’s status [339] as an “officer of the court” does not confer judicial powers upon the master, such as the authority to hold someone in contempt, to sign a warrant, or to order a police officer to make an arrest. Indeed, “[a] master is not the trial judge. A master does not replace her or him.” Wise-Jones, 117 Md.App. at 500, 700 A.2d 852. Thus, only a judicial officer may issue a warrant. Md. Rule 4-212(d).12 Because a master is not a judicial officer, and performs only ministerial functions, a construction of the rules that recognizes an implied power to order an arrest would run afoul of constitutional precepts.
Stack supports the kind of narrow interpretation of the rule that we adopt here. In Stack, after a hearing, the master recommended, inter alia, joint temporary legal custody, with physical custody to the mother, pendente lite. The father timely filed exceptions to the master’s report and recommendations and requested a circuit court hearing. Prior to the hearing, on motion of the mother, the circuit court signed an immediate order adopting the recommendations.
This Court reversed the circuit court’s award of pendente lite custody to the mother. We observed that Maryland Rule 2~541(g), concerning entry of an order implementing recommendations by a master, “contains no explicit authority for entry by the court of an immediate order under the circumstances presently before us.” Stach, 83 Md.App. at 40, 573 A.2d 409. Of particular significance to us here, the Stack Court declined to expand the literal language of the rule, [340] which only authorized the circuit court to enter an immediate order in limited circumstances “specifically enumerated” in the rule. Id. at 42, 573 A.2d 409. As a pendente lite award of custody was not so enumerated, we refused to uphold the chancellor’s action in signing an immediate order implementing all of the master’s recommendations, without first holding a hearing. Id. at 43, 573 A.2d 409. In .reaching that conclusion, we were also persuaded by the “legislative history” that the rule did not confer by implication the power in issue. We thus invoked the principle that “the [Maryland] Rules are not guides to the practice of law but precise rubrics established to promote the orderly and efficient administration of justice.” Id. at 41, 573 A.2d 409.
In much the same way as the Stack Court, we shall strictly interpret Rule 2-541(c). Because the rule does not provide express authority to the master to arrest a litigant pending judicial review of the master’s recommendations, we decline to expand the rule to authorize such power by implication.13
Because the Stack Court decided the appeal in favor of appellant based upon principles of statutory construction, it did not resolve appellant’s contentions that the circuit court’s entry of the order was an unconstitutional delegation of authority to the master, which denied appellant due process of law. The Stack decision, however, “alerted the Court of Appeals to the ‘constitutional infirmities that may lurk beneath the surface of Rule 2-541.’ ” Morales, 111 Md.App. at 631, 683 A.2d 1124 (quoting Reporter’s Note to Rule S74A, 18 Md. Reg. 679 (March 22, 1991)). As a result, the Court of Appeals revisited former Rule S74A to provide “a delicate balance between the need for expediency in domestic cases and the rights of domestic litigants to receive due process of law.” Morales, 111 Md.App. at 631, 683 A.2d 1124. The revisions included a streamlined process in which the master [341] is required to file written recommendations within three days of the hearing. Upon receipt of notice of the recommendation, either orally at the hearing or in writing, but whichever is earlier, the parties must file exceptions within five days. Id. at 632-33, 683 A.2d 1124; see also Miller, 113 Md.App. at 391-93, 688 A.2d 45.
Under Maryland Rule 9 — 207(f)(1)? a circuit court generally may not enter an order based upon a master’s recommendations until either the time for filing exceptions has expired or, if exceptions have been filed, until the court has ruled on the exceptions. There are two limitations, however. Maryland Rule 9 — 207(f)(2) provides that, in pendente lite matters, if the master finds that “extraordinary circumstances” exist, the court may direct the entry of an immediate order after reviewing the file or exhibits. Such an order “remains subject to a later determination by the court on exceptions.” Id. The second exception concerns contempt, authorizing the court to hold a hearing and enter an order of contempt “at any time.” Md. Rule 9-207(f)(3). This provision does not have the limitation that it is subject to later rulings on exceptions. Nevertheless, Master Patrick’s recommendations of contempt and immediate incarceration clearly were not self-executing. Rather, they were subject to review and implementation by a judge of the circuit court. Domingues v. Johnson, 323 Md. 486, 491-92, 593 A.2d 1133 (1991); In re Darryl D., 308 Md. 475, 477 n.2, 520 A.2d 712 (1987); see also Md. Rule 9-207; cf. Caldor, Inc. v. Bowden, 330 Md. 632, 658, 625 A.2d 959 (1993) (construing Md. Rule 911 with respect to juvenile masters).
The broad construction of the rule urged upon us by the State is also contrary to the history of the rule. Our review of the minutes from the Court of Appeals Standing Committee on Rules of .Practice and Procedure indicates that the Committee was concerned about an unconstitutional delegation of judicial power to domestic masters. At its meeting on April 22, 1977, the Committee discussed Rule 596, the predecessor to Rule 2-541. It considered Judge William McCullough’s [342] letter to the Reporter dated March 10, 1977, suggesting “the amendment and enlargement of section g.l (Time of Entry of Order — Immediate Order) to permit entry of immediate orders in other than pendente lite cases, including contempt.” Minutes from the Court of Appeals Standing Committee on Rules of Practice and Procedure 3-4 (April 22, 1977). The proposed section g.l provided:
g. Time of Entry of Order.
1. Immediate. Order.
Subject to the later determination of the court on any exceptions, an order implementing the recommendation of a Master
(i) shall be entered immediately in accordance with a recommendation that alimony or child support be awarded, pendente lite, accounting from the date recommended by the Master; and
(ii) may be entered immediately, effective as of the date of the order, in accordance with a recommendation that visitation of minor children be awarded pendente lite, or that an existing decree or order be modified as to child visitation.
The minutes also reflect the following debate concerning Judge McCullough’s suggestion:
■ Mr. [now Judge] Rodowsky stated that he believed Judge McCullough’s ... point was well taken, with respect to immediate orders, and that' he proposed inclusion in the second line of subsection g. l(ii) following “order,”, the words “upon a master’s determination of contempt,”.
Mr. Myerberg stated that such an amendment would raise a serious constitutional question, and that he believed it unconstitutional for a master to hold a party in contempt. Masters in Baltimore City have no such power.
Mr. Owens and Judge McAuliffe agreed that in Montgomery County masters have no power to hold a party in contempt.
[343] Mr. Myerberg asked how a master could hold a party in contempt of an immediate order, if the party had ten days within which to except to the master’s report?
* * * *
Mr. Myerberg stated that masters should have no jurisdiction in either custody or contempt matters, that these issues were too important to allow masters to determine them. The Chairman concurred that masters should not handle contempt matters.
Judge Ross stated that in Baltimore City, Lucy Garvey had been handling contempt matters for years, and that it works well. He acknowledged, however, that although the master determines prima facie that a party is in contempt, a judge actually signs the order.
Judge McAuliffe thereupon moved the deletion of subsection c. 4,