Ellsworth v. Baltimore Police Dep’t
Annotate this CasePetitioner, a homicide detective with the Baltimore City Police Department, was involved in an incident with the Baltimore City Police, which resulted in Petitioner being charged with seven violations of four administrative rules. A hearing board found Petitioner guilty of two of the charges. Petitioner sought judicial review, alleging that his hearing was unfair because the Department failed to disclose certain exculpatory evidence in violation of section 3-104(n)(ii) of the Law Enforcement Officers’ Bill of Rights (“LEOBR”). The circuit court reversed the Police Commissioner’s final order imposing the hearing board’s recommended sanction because the Department failed to disclose the information. The intermediate appellate court reversed, determining that because the information would not have tended to exonerate Petitioner of the administrative charges, it did not fall within the definition of “exculpatory.” The Court of Appeals affirmed, holding that the Legislature did not intend to import Brady v. Maryland and its progeny into the administrative LEOBR process by including the term “exculpatory” in section 3-104(n).
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