Maddox v. Cohn, 424 Md. 379, 36 A.3d 426 (2012)

Following mortgage foreclosure sale of residential home, mortgagor filed exception to report of sale, objecting to proposed ratification of sale on grounds that auction had been improper because trustees had required any successful purchaser to pay a $295 attorney fee for review of settlement documents, a fee not provided for in the mortgage documents or authorized by statute or court rule. The Circuit Court, Wicomico County, Kathleen L. Beckstead, J., entered order ratifying sale. Mortgagor appealed. The Court of Special Appeals, 199 Md.App. 63, 20 A.3d 153, affirmed. Mortgagor filed a petition for certiorari.   The Court of Appeals, Dale R. Cathell (Retired, specially assigned), J., held that it was an abuse of discretion for trustees to include a demand for the additional legal fees.  Judgment of Court of Special Appeals reversed; cause remanded.