Dep’t of State Police v. Dashiell
Annotate this CaseRespondent filed a complaint against a sergeant of the Maryland State Police that was “sustained.” Respondent subsequently sought records of the internal investigation conducted by the State Police in response to her complaint, but the State Police denied the request. Respondent subsequently filed a complaint for declaratory and injunctive relief under the Maryland Public Information Act. The circuit court granted summary judgment for the State Police, concluding that the records were mandatorily exempt from disclosure as “personnel records.” The Court of Special Appeals vacated the judgment, concluding that the circuit court erred in failing to require the State Police to create an index of the withheld documents and, in addition, by not conducting an in camera review of the documents to determine whether the documents could be redacted. The Court of Appeals vacated the judgment of the Court of Special Appeals and remanded to the circuit court for the entry of a declaratory judgment, holding that the internal affairs records of an investigation into the conduct of a specifically identified state trooper is a “personnel record” under the Act, and, in this case, not capable sufficiently of redaction were disclosure necessary.
Some case metadata and case summaries were written with the help of AI, which can produce inaccuracies. You should read the full case before relying on it for legal research purposes.
This site is protected by reCAPTCHA and the Google Privacy Policy and Terms of Service apply.