The Maryland Court of Appeals has ruled that small claims collections cases, involving plaintiffs other than the original creditor (factored or assigned accounts), face more stringent standards on application for affidavit judgment than those that may be applied at trial. The Court noted that the newer procedural rules for affidavit judgments in all cases of non-original creditor plaintiffs (MD Rule 3-306) require specific attestations, based on personal knowledge, that may not be required in a small claims trial, where the rules of evidence, for the most part, do not apply.  The Court noted that the procedural rules are in place for the protection of the debtor, who will not be heard if affidavit judgment is being considered, and thus, plaintiffs in these cases must support the application with procedurally adequate documentation.  Once the case has proceeded to a small claims trial, however, those additional procedural protections are no longer necessary, as the debtor/defendant will be there to participate, or presumably will have waived that right through failure to appear.

The full opinion in Bartlett v. Portfolio Recovery Associates can be found here: http://www.mdcourts.gov/opinions/coa/2014/64a13.pdf