Sale, Conveyance, Or Delivery of Property; Payment of Money

• Jurisdiction: Maryland

E. [§ 51] Sale, Conveyance, or Delivery of Property; Payment of Money

An order for the sale, conveyance, or delivery of real or personal property or the payment of money, or the refusal to rescind or discharge such an order, unless the delivery or payment is directed to be made to a receiver appointed by the court. Cts. & Jud. Proc. II § 12-303(3)(v).

For examples of orders "for the sale, conveyance, or delivery of real or personal property," see Granados v. Nadel, 220 Md. App. 482, 497 (2014); Barnes v. Barnes, 181 Md. App. 390, 407 (2008); 8621 Ltd. P'ship v. LDG, Inc., 169 Md. App. 214, 224 n.3 (2006); and Norkunas v. Cochran, 168 Md. App. 192, 197 n.1 (2006). An order that merely authorizes the sale of a property but that does not terminate the court's involvement in the sale of the property is not necessarily appealable under this provision. See Balt. Home Alliance, LLC v. Geesing, 218 Md. App. 375, 383 n.5 (2014).

The term "an order for ... the payment of money" may seem relatively straightforward on first reading, but the meaning of the term in the context of this statute is narrow and elusive. In Della Ratta v. Dixon, 47 Md. App. 270, 286 (1980), the Court of Special Appeals held that an order granting partial summary judgment and awarding money damages was not appealable...