Beall v. Holloway-JohnsonAnnotate this Case
Respondent, on her own behalf and as the personal representative of the estate of her deceased son, brought a wrongful death suit against Petitioner, a Baltimore City police officer, alleging negligence and gross negligence, among other causes of action. Petitioner sought both compensatory and punitive damages. The circuit court granted Petitioner’s motion for judgment in part, allowing only the question of whether Respondent was negligent and what amount of compensatory damages should be awarded. The jury returned a verdict for compensatory damages for Respondent, which amount was reduced by the trial judge to comply with the damages cap of the Local Government Tort Claims Act (LGTCA). The court of special appeals reversed and remanded for a new trial, concluding that there was sufficient evidence for each of Petitioner’s claims to have been submitted to the jury, that Petitioner’s claims could qualify as predicates for punitive damages, and that the LGTCA cap applied. The Court of Appeals affirmed in part and reversed in part, holding (1) there was sufficient evidence as to the counts for which the trial court gave judgment in favor of Respondent and on the LGTCA question; but (2) Respondent was not entitled to punitive damages, and therefore, a new trial was not warranted.