Summary
The United States District Court for the District of Maryland granted motions to dismiss filed by the Baltimore City Police Department, the Mayor and City Council of Baltimore, and the State of Maryland. The court held that the City was not liable for the alleged conduct of a Baltimore City police officer, sovereign immunity barred the claims against the Police Department, and the State retained immunity from the state-law claims. The dismissal was without prejudice as to those defendants; claims against Officer Morales-Mendez remained pending.
Topics
Practice areas
Questions Presented
- Whether the Mayor and City Council of Baltimore could be held liable under Maryland law for the alleged conduct of a Baltimore City Police Department officer.
- Whether the Baltimore City Police Department was protected by sovereign immunity from Wilson's state constitutional and common-law claims.
- Whether the State of Maryland was protected by sovereign immunity from Wilson's state-law claims arising from the conduct of Baltimore City police personnel.
- Whether Wilson could assert new Section 1983 and indemnification theories against the institutional defendants through briefing when those theories were not pleaded in the complaint.
Holdings
- The Mayor and City Council of Baltimore cannot be held liable on Wilson's state-law claims based on respondeat superior for the conduct of a Baltimore City Police Department officer because the Baltimore City Police Department is an agency of the State, not the City.
- The Baltimore City Police Department is protected by common-law sovereign immunity as a state agency from Wilson's state constitutional and common-law claims.
- The State of Maryland retains sovereign immunity from Wilson's state-law claims because the Maryland Tort Claims Act's waiver does not apply to the alleged conduct of Baltimore City Police Department personnel.
- Wilson could not amend his complaint through opposition briefs to add Section 1983 or indemnification theories that were not pleaded against the institutional defendants.
Key quotations
“Put simply, Wilson “cannot bring state-law claims against the City based on the actions of [Officer Morales-Mendez].”” (II.B.1)
“Under longstanding caselaw, the Baltimore City Police Department “exists as an agency of the State, and therefore enjoys the common law sovereign immunity from tort liability.”” (II.B.2)
“The doctrine of state sovereign immunity is “firmly embedded in the law of Maryland.”” (II.B.3)
Factual background
On April 17, 2022, DeShawn Wilson was seriously injured in a vehicle collision in Baltimore City and was hospitalized in a coma for three days. Baltimore City Police Officer Kenneth Morales-Mendez investigated the collision and reported that a firefighter had observed a handgun in Wilson's vehicle; an application for charges led to a warrant for knowingly transporting a firearm while Wilson was still hospitalized. Wilson alleged that he never possessed or knew of the firearm and that inconsistencies existed between the officer's account and body-worn-camera footage. The firearm charges were later dropped, after which Wilson sued the State, Baltimore City, the Baltimore City Police Department, and the officer for malicious prosecution, due process violations, Section 1983 violations, and negligence.
Procedural history
Wilson filed the complaint in the Circuit Court for Baltimore City on July 25, 2025. The Mayor and City Council of Baltimore and the Baltimore City Police Department removed the action to the United States District Court for the District of Maryland on September 8, 2025, based on federal-question jurisdiction. The three institutional defendants moved to dismiss; Officer Morales-Mendez filed an answer. The court granted the motions to dismiss filed by the State, the Mayor and City Council, and the Baltimore City Police Department, while the action continued against Morales-Mendez.