Maryland Telemarketing and Robocall Laws: Statutes, Rules, and How They Differ from the TCPA

Overview

Maryland regulates telemarketing through four statutes, three in the Commercial Law Article and one in the Public Utilities Article. The most significant recent development is the Stop the Spam Calls Act of 2023, codified as Title 14, Subtitle 45 of the Commercial Law Article (Md. Code Ann., Com. Law §§ 14-4501 to 14-4503). Enacted by Chapters 413 and 414 of 2023 (Senate Bill 90 and its cross-file, House Bill 37) and effective January 1, 2024, it requires prior express written consent for telephone solicitations made with "an automated system for the selection or dialing of telephone numbers" or a recorded message, prohibits solicitation calls between 8 p.m. and 8 a.m., caps solicitations at three per 24 hours on the same subject, and imposes caller ID and voice-alteration rules. Chapter 214 of 2024 (House Bill 1228), effective April 25, 2024 as an emergency measure, added an express private right of action for the greater of $500 or actual damages, trebled for willful or knowing violations, and barred most contractual waivers.

The Maryland Telephone Consumer Protection Act (the "MTCPA"), Com. Law §§ 14-3201 and 14-3202, takes a different approach: it makes any violation of the federal Telephone Consumer Protection Act (TCPA) and the FCC's implementing rules, or of the federal Telemarketing Sales Rule (TSR), a violation of Maryland law, and it gives affected individuals $500 per violation plus reasonable attorney's fees. The Maryland Telephone Solicitations Act (the "MTSA"), Com. Law §§ 14-2201 to 14-2205, makes contracts formed through merchant-initiated telephone sales unenforceable unless reduced to a signed writing. The Public Utilities Article restricts automated prerecorded solicitation calls (Pub. Util. § 8-204) and caller ID blocking (Pub. Util. § 8-205), with criminal fines.

Violations of all three Commercial Law subtitles are unfair, abusive, or deceptive trade practices under the Maryland Consumer Protection Act (Com. Law § 13-301(14)(xiv), (xx), and (xli)), enforced by the Consumer Protection Division of the Office of the Attorney General. The Maryland Public Service Commission also enforces the MTSA against the retail energy suppliers it licenses.

Headline difference from federal law: Maryland pairs a Florida- and Oklahoma-style "mini-TCPA" (8 a.m. to 8 p.m. calling window, three-call daily cap, consent for automated systems without the Duguid number-generator limitation) with a statute that federalizes every TCPA and TSR rule into state law with a $500-per-violation remedy and fee shifting, and which on its face has no counterpart to the federal requirement of more than one call in 12 months for do-not-call claims.

Key statutes and regulations

We located no Maryland statute creating a separate state do-not-call registry or a general telemarketer registration or bonding requirement, and the Attorney General's consumer guide directs residents to the National Do Not Call Registry. The MTCPA instead incorporates the federal registry rules in 47 C.F.R. § 64.1200(c) and the TSR.

Detailed provisions

1. Stop the Spam Calls Act (Com. Law §§ 14-4501 to 14-4503)

What is a "telephone solicitation." Subtitle 45 does not define the term itself. Section 14-4501(f) provides that "'Telephone solicitation' has the meaning stated in § 8-205 of the Public Utilities Article." That definition, Pub. Util. § 8-205(a), is broad:

(a) (1) In this section, "telephone solicitation" means an organized activity, program, or campaign to communicate by telephone with residents of Maryland in order to:

(i) sell, lease, or rent goods or services;

(ii) attempt to sell, lease, or rent goods or services;

(iii) offer or attempt to offer a gift or prize;

(iv) conduct or attempt to conduct a poll; or

(v) request or attempt to request survey information, if the results of the survey will be used directly to solicit persons to purchase, lease, or rent goods or services.

(2) "Telephone solicitation" includes the act of managing, directing, or supervising an individual engaged in telephone solicitation under paragraph (1) of this subsection.

Three features stand out. The definition requires "an organized activity, program, or campaign," so one-off calls are outside it. It reaches polls and lead-generation surveys, not only sales calls. And it covers those who manage, direct, or supervise callers, which supports liability for sellers and call center supervisors, not only the individual dialer.

Called party. Section 14-4501(b) provides: "'Called party' means a person who is a regular user of a telephone number that receives a telephone solicitation."

Prior express written consent. Section 14-4501(d) defines the consent required for automated and recorded solicitations. The written agreement must bear the called party's signature and must:

(2) Clearly authorizes the person making or allowing the placement of a telephone solicitation by telephone call, text message, or voicemail to deliver or cause to be delivered to the called party:

(i) A telephone solicitation using an automated system for the selection or dialing of telephone numbers;

(ii) The playing of a recorded or artificial voice message when a connection is completed to a number called; or

(iii) The transmission of a prerecorded voicemail; and

It must also include the authorized telephone number and a clear and conspicuous disclosure that the called party:

2. The called party is not required to directly or indirectly:

A. Sign the written agreement; or

B. Agree to enter into the agreement as a condition of purchasing any property, goods, or services.

Section 14-4501(e) provides that "'Signature' includes an electronic or digital signature to the extent that the form of signature is recognized as a valid signature under applicable federal law or State contract law."

The consent requirement. Section 14-4502(a)(3) provides:

(3) Without the prior express written consent of the called party, a person may not make or cause to be made a telephone solicitation that involves:

(i) An automated system for the selection or dialing of telephone numbers; or

(ii) The playing of a recorded message when a connection is completed to the number called.

As in Oklahoma and Florida, the phrase "automated system for the selection or dialing of telephone numbers" is not defined and does not contain the "random or sequential number generator" element of the federal automatic telephone dialing system (ATDS) definition, 47 U.S.C. § 227(a)(1), as construed in Facebook, Inc. v. Duguid, 592 U.S. 395 (2021). The disjunctive "selection or dialing" supports an argument that list-based automated dialing platforms are covered. No Maryland appellate court has construed the phrase. The requirement applies to any telephone number, not only cellular numbers, and the definition of consent expressly contemplates "text message" and "voicemail" delivery.

Exemptions apply only to the consent requirement. Section 14-4502(a)(1) begins, "This subsection does not apply to:" and then lists the exemptions. Because the exemptions are confined to subsection (a), they excuse only the consent requirement. They do not excuse the caller ID rules in subsection (b) or the calling-hour, frequency and voice-alteration rules in subsection (c). The exempt categories are:

(i) A telephone solicitation that is an isolated transaction and not performed in the course of a pattern of repeated transactions of a similar nature;

(ii) Subject to paragraph (2) of this subsection, a noncommercial telephone solicitation for religious, charitable, political, or educational purposes;

(iii) A business-to-business sale where the telephone solicitor has been lawfully operating continuously for at least 3 years under the same business name;

(iv) A person who solicits contracts for the maintenance or repair of goods previously purchased from the person making the solicitation or on whose behalf the solicitation is made;

(v) A single telephone solicitation made to a customer or client in response to an inquiry or request from the customer or client;

(vi) A communication between a business and a customer that have an existing business contract or relationship with each other if:

1. The communication is initially intended for informational purposes only; and

2. Based on further inquiry from the customer, the communication becomes a telephone solicitation; or

(vii) A noncommercial telephone solicitation for the purpose of public opinion research.

The noncommercial exemption in item (ii) is available only if the caller is soliciting for a nonprofit that is registered with the Secretary of State under Title 6 of the Business Regulation Article and exempt under § 501(c)(3), (4), or (6) of the Internal Revenue Code (§ 14-4502(a)(2)). Item (vii) was added by Chapter 214 of 2024.

The established customer exemption is narrow. Item (vi) does not exempt marketing calls to existing customers generally; it covers only a communication that begins as informational and becomes a solicitation "[b]ased on further inquiry from the customer." Item (v) permits only "[a] single telephone solicitation" in response to a customer's inquiry. There is no general established business relationship exemption comparable to 47 C.F.R. § 64.1200(f)(5).

Caller ID. Section 14-4502(b)(1) provides:

(b) (1) A person who makes or causes to be made a telephone solicitation may not:

(i) Fail to transmit or cause not to be transmitted:

1. The originating telephone number; and

2. When made available by the caller's carrier, the name of the caller to any caller identification service in use by a called party;

(ii) Intentionally act to prevent the transmission of the telephone solicitor's name or telephone number to the called party when the equipment or service used by the telephone solicitor is capable of creating and transmitting the telephone solicitor's name and telephone number; or

(iii) In order to conceal the true identity of the caller, use technology that deliberately displays a different caller identification number than the number the call is originating from.

Under § 14-4502(b)(2), it is not a violation to substitute the name and customer service number of "the seller or other entity for whom the telephone solicitation is placed." Unlike Oklahoma, Maryland does not add an express requirement that the displayed number be answered or connect back to the seller.

Calling hours, frequency and voice alteration. Section 14-4502(c) provides:

(c) A person may not make or cause to be made a telephone solicitation, including a call made through automated dialing or a recorded message:

(1) To a called party during the hours between 8 p.m. and 8 a.m. in the called party's time zone;

(2) More than three times to the same called party during a 24-hour period on the same subject matter or issue, regardless of the telephone numbers used to make the call; or

(3) By intentionally altering the voice of the caller in an attempt to disguise or conceal the identity of the caller in order to:

(i) Defraud, confuse, or financially or otherwise injure the called party; or

(ii) Obtain personal information from the called party that may be used in a fraudulent or unlawful manner.

These restrictions apply to live calls as well as automated calls, and they apply regardless of consent, because subsection (c) has no consent or exemption carve-out. A caller with valid written consent still may not call at 8:15 p.m. or make a fourth solicitation in a day on the same subject.

Remedies, presumption and anti-waiver. Section 14-4503, as amended in 2024, provides:

(2) (i) A called party who is aggrieved by a person who violates this subtitle may bring an action in accordance with § 13-408 of this article to enjoin further violations and to recover damages up to $500 or actual damages, whichever is greater.

(ii) If the court finds the defendant willfully or knowingly violated this subtitle, the court may award damages up to three times the amount of damages under subparagraph (i) of this paragraph.

On its face, the phrase "damages up to $500" appears to give the court discretion to award less than $500, unlike the fixed $500 in the MTCPA and in 47 U.S.C. § 227(b)(3). A violation is also an unfair, abusive, or deceptive trade practice subject to Title 13 enforcement (§ 14-4503(a)(1)). The remaining subsections provide:

(b) There is a rebuttable presumption that a telephone solicitation made to any area code in the State is made to a resident or a person who is reasonably presumed to reside or have a place of business in the State at the time the call is made.

(d) Except as provided in § 14-4502(a)(3) of this subtitle, the requirements and remedies provided under this subtitle may not be waived by an agreement, unless the agreement is part of a settlement of a legal dispute or action.

The anti-waiver clause bears directly on consumer terms that purport to waive statutory damages or consent to unlimited calling. Subsection (c) preserves the Public Utilities Article provisions (§§ 8-204, 8-205 and Title 13) for calls subject to Subtitle 45.

2. Maryland Telephone Consumer Protection Act (Com. Law §§ 14-3201, 14-3202)

Section 14-3201 provides in full:

A person may not violate:

(1) The Telemarketing and Consumer Fraud and Abuse Prevention Act, 15 U.S.C. §§ 6101 through 6108, as implemented by the Federal Trade Commission in the Telemarketing Sales Rule (16 C.F.R. Part 310); or

(2) The Telephone Consumer Protection Act, 47 U.S.C. § 227, as implemented by the Federal Communications Commission in the Restrictions on Telemarketing and Telephone Solicitations Rule (47 C.F.R. Part 64, Subpart L).

Section 14-3202 supplies the remedy:

(b) In addition to the remedies provided in § 13-408 of this article, an individual who is affected by a violation of this subtitle may bring an action against a person that violates this subtitle to recover:

(1) Reasonable attorney's fees; and

(2) Damages in the amount of the greater of:

(i) $500 for each violation; or

(ii) Actual damages sustained as a result of the violation.

(c) For purposes of this section, each prohibited telephone solicitation and each prohibited practice during a telephone solicitation is a separate violation.

The MTCPA's practical significance is that it adds remedies the federal statute lacks. It provides attorney's fees, which the TCPA does not. It does not contain the TCPA's requirement in 47 U.S.C. § 227(c)(5) that the plaintiff have received "more than one telephone call within any 12-month period" before suing over do-not-call violations. It makes TSR violations, which carry no federal private right of action for most consumers, privately actionable under state law. And subsection (c) treats "each prohibited practice during a telephone solicitation" as a separate violation, which can multiply damages where a single call violates several rules. The MTCPA has no treble damages provision.

The MTCPA's reach is limited by federal law in one respect. In Worsham v. Ehrlich (discussed below), the Court of Special Appeals held that the MTCPA cannot supply a private right of action for violations of the TCPA's technical and procedural standards for prerecorded messages under 47 U.S.C. § 227(d), because § 227(e) does not permit states to impose more restrictive requirements on those standards. Federal courts have also required MTCPA plaintiffs to plead the same elements as the underlying TCPA claim (see Drake v. Synchrony Bank, below).

3. Maryland Telephone Solicitations Act (Com. Law §§ 14-2201 to 14-2205)

Definition. Section 14-2201(f) provides:

(f) "Telephone solicitation" means the attempt by a merchant to sell or lease consumer goods, services, or realty to a consumer located in this State that is:

(1) Made entirely by telephone; and

(2) Initiated by the merchant.

"Consumer services" excludes "financial services or securities sales" (§ 14-2201(c)(2)(i)), subject to an exception for certain pay-per-call credit services solicitations.

Written contract requirement. Section 14-2203 provides:

(a) A contract made pursuant to a telephone solicitation is not valid and enforceable against a consumer unless made in compliance with this subtitle.

The contract must be "reduced to writing and signed by the consumer" (§ 14-2203(b)(1)), must match the description used in the solicitation, must state the seller's name, address and telephone number, the total price and a detailed description, may not exclude oral or written representations made in connection with the sale, and:

(5) Shall contain, in at least 12 point type, immediately preceding the signature, the following statement:

"You are not obligated to pay any money unless you sign this contract and return it to the seller."; and

Section 14-2204 provides: "A merchant engaging in a telephone solicitation may not make or submit any charge to the consumer's credit account until after the merchant receives from the consumer a copy of the contract which complies with this subtitle."

Exemptions. Section 14-2202(a) exempts transactions made after prior negotiations during a visit to the merchant's fixed retail location; transactions where the caller or its business "[h]as made a previous sale to the consumer" or "[h]as a preexisting business relationship with the consumer"; transactions covered by the door-to-door sales subtitle; sales with a 7-day full refund right processed within 30 days; purchases made after the consumer examined an advertisement, catalogue or other mailing that contains the merchant's name, address and telephone number, a description of the goods or services, and any limitations of the offer; and sales by bona fide charitable organizations.

Enforcement. Under § 14-2205, a violation is an unfair or deceptive trade practice under Title 13, Subtitle 3 and, for credit services solicitations, a violation of the Maryland Credit Services Businesses Act. The MTSA is the Maryland telemarketing statute that the Supreme Court of Maryland has construed most fully (In re Smart Energy Holdings, below), and its remedy, unenforceability of the contract, can produce restitution of everything paid.

4. Automated prerecorded calls and caller ID blocking (Pub. Util. §§ 8-204, 8-205)

Section 8-204(b) provides:

(b) A person may not use an automated dialing, push-button, or tone-activated address signaling system with a prerecorded message to:

(1) solicit persons to purchase, lease, or rent goods or services;

(2) offer a gift or prize;

(3) conduct a poll; or

(4) request survey information if the results will be used directly to solicit persons to purchase, lease, or rent goods or services.

The section does not apply to government emergency calls or to "a person who has a preexisting business relationship with, or the consent of, the person called" (§ 8-204(a)(2)). The prerecorded message machine must disconnect "within 5 seconds after the termination of the call by either the person calling or the person called" (§ 8-204(c)). A violation of subsection (b) or (c) is a misdemeanor punishable by a fine "not exceeding $1,000 for the first offense" and "not exceeding $5,000 for each subsequent offense" (§ 8-204(d)).

Section 8-205(c) provides that, where the caller's service or equipment allows it to choose whether to display its number, a person engaged in telephone solicitation may not:

(1) intentionally use any device or method to block the transmission of the person's telephone number to a recipient; or

(2) take any other action to prevent or control the transmission of the person's telephone number to a recipient.

A violation is a misdemeanor with the same $1,000 and $5,000 fine structure (§ 8-205(d)).

5. Consumer Protection Act enforcement and penalties

Private action. Section 13-408(a) permits "any person" to sue "to recover for injury or loss sustained by him as the result of a practice prohibited by this title," and § 13-408(b) allows a prevailing plaintiff who is awarded damages to seek reasonable attorney's fees. Subtitle 45 actions are brought "in accordance with § 13-408" (§ 14-4503(a)(2)(i)).

Civil penalties. Section 13-410 provides:

(a) A merchant who engages in a violation of this title is subject to a fine not exceeding $10,000 for each violation.

(b) A merchant who has been found to have engaged in a violation of this title and who subsequently repeats the same violation is subject to a fine not exceeding $25,000 for each subsequent violation.

Criminal penalties. Under § 13-411(a), a violation of Title 13 is a misdemeanor punishable, "unless another criminal penalty is specifically provided elsewhere," by "a fine not exceeding $1,000 or imprisonment not exceeding one year or both, in addition to any civil penalties."

Limitations period. None of the telemarketing subtitles states its own limitations period. The general Maryland civil limitations period should be confirmed for each claim; this page does not take a position on it.

How Maryland law differs from federal law

Where Maryland is stricter. Maryland's 8 p.m. cutoff, its three-call daily cap, and its consent requirement for automated systems without the Duguid limitation exceed federal law, and the hour and frequency rules apply even to consented calls. The MTCPA's fee shifting, its single-call standing, and its per-practice violation count make federal-rule violations more expensive in Maryland than under federal law alone. The MTSA's signed-contract requirement for merchant-initiated telephone sales, as construed in Smart Energy Holdings to include calls made by consumers in response to merchant mailers, has no federal counterpart.

Where Maryland is looser. Subtitle 45's damages are "up to $500" rather than a fixed amount, and its exemptions for isolated transactions and established business-to-business sellers remove some calls from the consent requirement entirely. The MTCPA cannot be used to enforce the § 227(d) prerecorded-message identification rules.

Where Maryland tracks federal law. The MTCPA incorporates the federal standards without changing them, so its substantive rules move with the TCPA, FCC rules and TSR. Subtitle 45's definition of prior express written consent follows the structure of 47 C.F.R. § 64.1200(f)(9).

Notable enforcement and case law

In the Matter of Smart Energy Holdings, LLC, No. 1, September Term, 2023, 311 A.3d 919 (Md. Feb. 22, 2024). In re Smart Energy Holdings (Md. 2024) The Supreme Court of Maryland affirmed the judgment of the Appellate Court of Maryland upholding a Public Service Commission order against a retail electricity supplier that mailed postcards inviting consumers to call and then enrolled callers by telephone without a signed written contract. The court held "that the MTSA applies to sales made over the telephone where a consumer places a telephone call to a merchant in response to a merchant's marketing materials, unless the transaction falls within one of the statutory exemptions outlined in CL § 14-2202." It reasoned that the definition in § 14-2201(f) "explicitly separates the requirement relating to the 'making' of a sales attempt from the requirement relating to the 'initiation' of a sales attempt." The court also held that the Commission has authority to enforce the MTSA against suppliers it regulates. In a later federal challenge to the resulting refund order and civil penalty, the Fourth Circuit affirmed dismissal in an unpublished opinion, SmartEnergy Holdings, LLC v. Hoover, No. 25-1936 (4th Cir. May 28, 2026), noting the Commission's findings that approximately 32,000 customer contracts were invalid.

Worsham v. Ehrlich, No. 1442, September Term, 2007, 957 A.2d 161 (Md. Ct. Spec. App. Sept. 15, 2008). Worsham v. Ehrlich (Md. Ct. Spec. App. 2008) The plaintiff sued under the MTCPA over prerecorded political calls that did not state the caller's telephone number. The court held that "[t]here is no private right of action under 47 U.S.C. section 227 (d), and states may not create a private right of action under that subsection." It explained that "[t]he plain language of § 227 (e) provides that the States may create their own more restrictive standards than the federal TCPA, except with regard to subsection (d)."

Worsham v. Accounts Receivable Management, Inc., No. 11-2390 (4th Cir. Nov. 14, 2012) (unpublished). Worsham v. Accounts Receivable Management (4th Cir. 2012) Deferring to Worsham v. Ehrlich, the Fourth Circuit affirmed summary judgment against an MTCPA claim based on 47 C.F.R. § 64.1200(b), stating that it saw "no reason to reject the determination of the state's intermediate appellate court that this cause of action does not exist under state law."

Drake v. Synchrony Bank, No. 1:19-cv-02134-CCB (D. Md. Oct. 11, 2023). Drake v. Synchrony Bank (D. Md. 2023) The court treated TCPA and MTCPA claims together, holding that "to state a claim for recovery under the TCPA and MTCPA, the plaintiff must allege that the defendant: (1) called his cellular phone; (2) using an automatic telephone dialing system or an artificial or prerecorded voice; (3) without his prior express consent (or any of the other exceptions)." The MTCPA claim survived on the plaintiff's prerecorded-voice theory after he withdrew his autodialer allegations.

No reported decision construing the Stop the Spam Calls Act (Com. Law §§ 14-4501 to 14-4503) was located.

Recent amendments

• Chapters 413 and 414 of 2023 (Senate Bill 90 and House Bill 37, cross-filed bills), the Stop the Spam Calls Act of 2023, effective January 1, 2024: added Com. Law Title 14, Subtitle 45 ("Telephone Solicitations"), §§ 14-4501 to 14-4503, and added Subtitle 45 to the list of unfair, abusive, or deceptive trade practices in § 13-301(14). As enacted, § 14-4503 routed enforcement through Title 13 and did not contain the stand-alone $500 statutory damages provision.
• Chapter 214 of 2024 (House Bill 1228), emergency measure effective April 25, 2024: added the public opinion research exemption (§ 14-4502(a)(1)(vii)); added the called-party private action for up to $500 or actual damages, trebled for willful or knowing violations (§ 14-4503(a)(2)); added the anti-waiver clause (§ 14-4503(d)); and added § 14-4503(e), which allows agreements to establish more extensive requirements or remedies.
• No 2025 or 2026 amendment to Subtitle 45 was identified in the official statute text as of the fetch date.

Practical compliance checklist

• Treat every outbound sales, prize, poll or lead-generation survey campaign to Maryland area codes as a "telephone solicitation" under Pub. Util. § 8-205, including the conduct of managers and supervisors.
• Obtain signed (electronic acceptable) prior express written consent that names the number and uses Maryland's technology description before any solicitation call, text or ringless voicemail placed with automated selection or dialing or a recorded or artificial voice.
• Block all solicitation calls and texts between 8 p.m. and 8 a.m. in the called party's time zone, regardless of consent.
• Enforce a cap of three solicitations per called party per 24 hours on the same subject, counted across all numbers, vendors and channels.
• Transmit the originating number and available caller name, or the seller's name and customer service number; never block or spoof caller ID and never alter a caller's voice to conceal identity.
• Comply fully with the TCPA, FCC rules and TSR, including national registry scrubbing and internal do-not-call procedures, because each violation is independently actionable in Maryland at $500 plus attorney's fees.
• For merchant-initiated telephone sales of consumer goods or services, including sales closed when a consumer calls in response to a mailer, deliver a written contract with the 12-point statement and do not charge the consumer's account until the signed contract is returned, unless a § 14-2202 exemption clearly applies.
• Do not rely on consumer terms that purport to waive Subtitle 45 requirements or remedies; they are unenforceable outside a settlement.
• Ensure prerecorded-message equipment disconnects within 5 seconds, and limit prerecorded solicitations to consenting persons or those with a preexisting business relationship.

References

• Md. Code Ann., Com. Law § 14-4501, https://mgaleg.maryland.gov/mgawebsite/Laws/StatuteText?article=gcl&section=14-4501&enactments=false
• Md. Code Ann., Com. Law § 14-4502, https://mgaleg.maryland.gov/mgawebsite/Laws/StatuteText?article=gcl&section=14-4502&enactments=false
• Md. Code Ann., Com. Law § 14-4503, https://mgaleg.maryland.gov/mgawebsite/Laws/StatuteText?article=gcl&section=14-4503&enactments=false
• Md. Code Ann., Com. Law § 14-3201, https://mgaleg.maryland.gov/mgawebsite/Laws/StatuteText?article=gcl&section=14-3201&enactments=false
• Md. Code Ann., Com. Law § 14-3202, https://mgaleg.maryland.gov/mgawebsite/Laws/StatuteText?article=gcl&section=14-3202&enactments=false
• Md. Code Ann., Com. Law §§ 14-2201 to 14-2205, https://mgaleg.maryland.gov/mgawebsite/Laws/StatuteText?article=gcl&section=14-2201&enactments=false
• Md. Code Ann., Com. Law § 13-301, https://mgaleg.maryland.gov/mgawebsite/Laws/StatuteText?article=gcl&section=13-301&enactments=false
• Md. Code Ann., Com. Law § 13-408, https://mgaleg.maryland.gov/mgawebsite/Laws/StatuteText?article=gcl&section=13-408&enactments=false
• Md. Code Ann., Com. Law § 13-410, https://mgaleg.maryland.gov/mgawebsite/Laws/StatuteText?article=gcl&section=13-410&enactments=false
• Md. Code Ann., Com. Law § 13-411, https://mgaleg.maryland.gov/mgawebsite/Laws/StatuteText?article=gcl&section=13-411&enactments=false
• Md. Code Ann., Pub. Util. § 8-204, https://mgaleg.maryland.gov/mgawebsite/Laws/StatuteText?article=gpu&section=8-204&enactments=false
• Md. Code Ann., Pub. Util. § 8-205, https://mgaleg.maryland.gov/mgawebsite/Laws/StatuteText?article=gpu&section=8-205&enactments=false
• 2023 Md. Laws Ch. 413 (S.B. 90), https://mgaleg.maryland.gov/2023RS/Chapters_noln/CH_413_sb0090e.pdf
• 2023 Md. Laws Ch. 414 (H.B. 37), https://mgaleg.maryland.gov/2023RS/Chapters_noln/CH_414_hb0037t.pdf
• 2024 Md. Laws Ch. 214 (H.B. 1228), https://mgaleg.maryland.gov/2024RS/Chapters_noln/CH_214_hb1228t.pdf
• In the Matter of Smart Energy Holdings, LLC, No. 1, Sept. Term 2023 (Md. Feb. 22, 2024), https://www.mdcourts.gov/data/opinions/coa/2024/1a23.pdf
• Worsham v. Ehrlich, No. 1442, Sept. Term 2007 (Md. Ct. Spec. App. Sept. 15, 2008), https://www.mdcourts.gov/data/opinions/cosa/2008/1442s07.pdf
• Worsham v. Accounts Receivable Management, Inc., No. 11-2390 (4th Cir. Nov. 14, 2012), https://www.govinfo.gov/content/pkg/USCOURTS-ca4-11-02390/pdf/USCOURTS-ca4-11-02390-0.pdf
• Drake v. Synchrony Bank, No. 1:19-cv-02134 (D. Md. Oct. 11, 2023), https://www.govinfo.gov/content/pkg/USCOURTS-mdd-1_19-cv-02134/pdf/USCOURTS-mdd-1_19-cv-02134-1.pdf
• SmartEnergy Holdings, LLC v. Hoover, No. 25-1936 (4th Cir. May 28, 2026), https://www.govinfo.gov/content/pkg/USCOURTS-ca4-25-01936/pdf/USCOURTS-ca4-25-01936-0.pdf
• Office of the Attorney General of Maryland, How to Stop Telemarketing Calls and Junk Mail, https://oag.maryland.gov/our-office/Documents/How%20to%20Stop%20Telemarketing%20and%20Junk%20Mail.pdf
• 47 U.S.C. § 227, https://www.law.cornell.edu/uscode/text/47/227
• 47 C.F.R. § 64.1200, https://www.law.cornell.edu/cfr/text/47/64.1200
• 16 C.F.R. § 310.4, https://www.law.cornell.edu/cfr/text/16/310.4

This page summarizes state law for general informational purposes and is not legal advice. Statutes change; confirm current text with the official source before relying on it.