Baltimore XV Props. v. Newsteps' Choice N.

Summary

The Supreme Court of Maryland held that a judgment-debtor’s payment of the judgment after a sheriff’s sale does not invalidate or vacate the sale before ratification. The payment is not an irregularity in the sale cognizable under the post-sale exceptions procedure because it concerns the judgment rather than the manner in which the sale was conducted. The purchaser acquired an inchoate equitable interest and therefore was entitled to proceed through ratification, although the judgment-debtor could still raise genuine sale-related exceptions on remand.