Robinson v. Baltimore Police Dep't
Annotate this CaseOn February 22, 2007, a prostitute alleged that she had sexual intercourse with Petitioner, an officer with the Baltimore Police Department (BDP). On June 26, 2008, the BDP administratively charged Petitioner with six violations of BDP general orders arising out of his alleged sexual misconduct and his alleged false statements to investigators with the BDP's internal investigation division on July 11, 2007 and August 1, 2007. On July 11, 2008, the BPD terminated Petitioner. Petitioner appealed, contending that the administrative charges were barred by the one-year statute of limitations set forth in section 3-106 of the Law Enforcement Officers' Bill of Rights. The circuit court granted the BPD's cross-motion for summary judgment as it related to the false statement charge, ruling that it was filed within the one-year limitations window. The court of special appeals affirmed. The Court of Appeals affirmed, holding that the limitations period begins when the officer makes the false statement, not when the earlier misconduct that underlies the investigation was alleged to have occurred.
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