Bartlett v. Portfolio Recovery Associates, LLC, 91 A.3d 1127

Debt buyers filed small claim actions in District Court seeking judgments on affidavit under Md. Rule 3-306 and small claim Rule 3-701; defendant timely defended in Bartlett and Townsend.
Rule 3-306 was amended in 2011 to add a heightened Assigned Consumer Debt Checklist (d) requiring certain documents satisfying the business records exception for judgments on affidavit.
Small claims are informal and the Rules of Evidence do not apply at trial, though competency of witnesses remains; contested small claims proceed to a merits trial under Rule 3-701 with informal procedures.
The Court consolidated Bartlett and Townsend to decide whether debt buyers may rely on hearsay/business-record evidence in contested small claims, and how Rule 3-306(d) interacts with trial practice.
The Circuit Court judgments in Bartlett and Townsend were affirmed, with the Court holding that evidence weighing and reliability may be considered in the informal small-claims context, not strictly limited to business-record admissibility.
The dissent would require cross-examination and reject automatic reliability given the debt-buyer context and bank-record provenance.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Does 3-306(d) require business-record proof in contested small claims?	Bartlett—debt buyer must meet business-record standards.	Bartlett—contested trial allows relaxed standards; crossing not required.	In affidavit stage, yes; in contested trials, evidence is weighed informally; no strict business-record bar.
Were the trial courts' evidentiary rulings abuse of discretion?	Bartlett and Townsend—records sufficient under 3-306(d).	Records unreliable or improperly authenticated.	No abuse; court properly weighed reliability and probative value in informal small-claims context.
Did the trial courts err in applying 3-701/Rules of Evidence in contested small claims?	Debt buyers prevail via merits trial with admissible evidence.	Evidence should be constrained by Rules of Evidence even in small claims.	No error; small-claims trials are informal and do not apply Title 5 Rules of Evidence, except competency.

Goodman v. Commercial Credit Corp., 364 Md. 483 (Md. 2001) (discussion of 3-306 and proof in debt-buyer context)
Chapman v. State, 331 Md. 448 (Md. 1993) (bank records' reliability in criminal context; trustworthiness via cross-examination)
Md. Dept. of Human Resources v. Bo Peep Day Nursery, 317 Md. 573 (Md. 1989) (due process and hearsay in administrative contexts; cross-examination valued)
North v. North, 102 Md. App. 1 (Md. 1994) (abuse of discretion standard; deferential review for weighings)