The Supreme Court of Maryland dismissed an appeal in *Wilson v. Tanglewood Venture, LP* after determining that no live controversy remained between the parties, leaving unresolved a key question about tenant rights when landlords operate without required licenses.
The case, decided during the September Term 2025 with Justice Gould writing the opinion, centered on whether courts may require tenants to pay rent into escrow when rental properties lack licenses required by local law under Maryland's rent escrow statute.
The legal dispute arose when tenants invoked Maryland's rent escrow statute (MD. CODE ANN., REAL PROP. § 8-211 (2023)) against Tanglewood Venture, LP. The rent escrow law allows tenants to pay rent to the court rather than directly to landlords when certain conditions exist, protecting tenants from potential exploitation while ensuring landlords receive payment for legitimate rental obligations.
By the time the appeal reached Maryland's highest court, however, the circumstances that gave rise to the litigation had fundamentally changed. The tenants had relinquished possession of their rental units, effectively ending their landlord-tenant relationship with Tanglewood Venture. Additionally, the landlord had obtained the required license for the property and disclaimed any intent to collect rent attributable to the period when the property operated without proper licensing.
These developments led the Supreme Court of Maryland to apply the mootness doctrine, which prevents courts from deciding cases where no live controversy exists between the parties. The court found that with the tenants no longer in possession and the landlord properly licensed, there was no ongoing dispute requiring judicial resolution.
Crucially, the court determined that dismissing the appeal would not create collateral consequences for the tenants. The record showed that dismissal would not expose the tenants to liability for unpaid rent or other adverse consequences, as no judgment had been entered against them by either the district court or circuit court level.
The tenants had attempted to invoke two exceptions to the mootness doctrine that might have allowed the court to reach the substantive legal question despite the changed circumstances.
First, they argued the "capable of repetition, yet evading review" exception should apply. This exception allows courts to decide moot cases when the same parties are likely to face similar disputes in the future, and those disputes would likely become moot before appellate review could be completed. The Supreme Court of Maryland rejected this argument, holding that the exception did not apply because there was no live controversy and because rent escrow complaints would not typically evade appellate review.
Second, the tenants invoked the public interest exception, which permits courts to decide moot cases when the underlying legal questions are of significant public importance and likely to recur. The court also rejected this argument, noting that during the pendency of the litigation, the Maryland General Assembly had substantially revised the rent escrow statute and altered landlord-tenant law in related respects.
These statutory changes proved fatal to the public interest exception argument. The court determined that the legislative modifications rendered the case "an unsuitable vehicle for applying the public interest exception to the mootness doctrine." Essentially, the court concluded that any ruling on the original legal question would address outdated law rather than current statutory provisions.
The case originated in the Circuit Court for Prince George's County under Case No. C-16-CV-24-002586, and oral arguments were held on Oct. 3, 2025.
The dismissal leaves unresolved the important question of whether tenants can be required to pay rent into escrow for unlicensed rental properties. This issue affects tenant rights across Maryland, where many local jurisdictions require rental licenses as a condition of operating rental properties.
The rent escrow statute serves as a critical tenant protection, allowing renters to withhold rent payments to landlords while still making payments to the court system when properties fail to meet certain standards. The unresolved question of how this protection applies to unlicensed properties could impact future landlord-tenant disputes.
While the Supreme Court of Maryland declined to address the substantive legal issue in this case, the question may arise again in future litigation involving current landlord-tenant relationships where the factual circumstances would not trigger mootness concerns.
The decision demonstrates how procedural doctrines like mootness can prevent courts from addressing important legal questions, particularly in landlord-tenant law where circumstances frequently change during the course of litigation. Tenants often move out, landlords may remedy violations, or legislative changes may alter the legal landscape before appeals can be resolved.
For Maryland tenants and landlords, the case highlights the importance of understanding both substantive rental law and the procedural requirements that can affect how disputes are resolved in court.