Edwards Systems Technology v. Corbin, 379 Md. 278

Summary

The Maryland Court of Appeals considered whether Maryland Code, Article 49B, § 42, together with Prince George's County anti-discrimination ordinances, violated Article XI-A of the Maryland Constitution. The court held that the state statute was not an unconstitutional local law because it applied to three counties and created a judicial cause of action, and it construed the county ordinance to cover only discrimination occurring in Prince George's County by an employer with a significant presence there. The court affirmed the judgment of the Court of Special Appeals.

Holdings

1. Article 49B, § 42 did not violate Article XI-A because it was enacted by the General Assembly, applied to three counties rather than a single county, and created a new judicial cause of action that was not a prohibited local law.
2. The county ordinances could prohibit discrimination occurring within the county and define the elements of a discrimination claim, while Article 49B, § 42 supplied the civil cause of action and remedies.
3. Prince George's County Code § 2-222 was construed to cover only discrimination occurring in Prince George's County by an employer with a significant presence there.
4. The General Assembly's incorporation of substantive standards from county anti-discrimination ordinances into the state-created cause of action was not an unconstitutional delegation of legislative authority.

Questions Presented

1. Whether Maryland Code, Article 49B, § 42, authorizing civil actions for discrimination prohibited by the codes of Montgomery, Prince George's, and Howard Counties, violated Article XI-A of the Maryland Constitution.
2. Whether the combined operation of Article 49B, § 42, and Prince George's County Code §§ 2-186(a)(3) and 2-222 constituted an unconstitutional delegation of legislative authority or an invalid local law.
3. Whether Prince George's County's employment-discrimination ordinances were valid under Article XI-A and were preempted by Maryland public general laws.

Disposition

affirmed