White v. StateAnnotate this Case
Petitioner, a police officer, filed a complaint against respondent under the theory of respondeat superior and alleged negligent hiring/supervision and negligence in supervising 911 dispatch protocols when he suffered severe injuries from a car accident that occurred while he was pursuing a suspect from an "armed robbery." At issue was whether the Court of Special Appeals erred in concluding that a police officer injured during a high-speed pursuit was barred by the common-law firefighter's rule from recovering in a tort action alleging negligence by a police dispatcher in giving the police officer faulty information that led to the commencement of the high-speed chase. Also at issue was whether the Court of Special Appeals erred in declining to address whether a "special duty" exception to the firefighter's rule should be recognized in Maryland. The court held that the firefighter's rule barred petitioner's claim where he failed to show the court a reason, based either in law or policy, to limit application of the firefighter's rule and where adopting such a limitation on the rule ran counter to its undergirding public policy, which recognized that the very nature of the firefighter's or police officer's occupation limits the public safety officer's ability to recover in tort for work-related injuries. The court also held that petitioner's general opposition to the application of the firefighter's rule was not sufficient to allow the circuit court the opportunity to decide the issue and therefore, the court also declined to decide the issue.