City of Brunswick v. Christopher Handler

Summary

The Appellate Court of Maryland held that the Maryland Police Accountability Act requires each law enforcement agency to establish a trial board process for all matters for which a police officer is subject to discipline. The court concluded that this requirement applies to internal disciplinary matters, including letters of reprimand that do not involve a member of the public, and affirmed the writ of mandamus issued by the Circuit Court for Frederick County.

Holdings

1. Public Safety § 3-106(a)(1) unambiguously requires every law enforcement agency to establish a trial board process for all matters for which a police officer is subject to discipline, including internal disciplinary matters that do not involve a member of the public.
2. Because Handler was subject to discipline for both letters of reprimand, appellants' denial of his request for trial board process violated Public Safety § 3-106(a)(1), and the circuit court properly granted a writ of mandamus.

Questions Presented

1. Whether Maryland Public Safety § 3-106(a)(1), which requires each law enforcement agency to establish a trial board process to adjudicate all matters for which a police officer is subject to discipline, applies to disciplinary matters that do not involve a member of the public.
2. Whether the Circuit Court for Frederick County properly granted Handler's petition for a writ of mandamus after appellants denied his request for a trial board hearing.

Disposition

affirmed