Board of Liquor License Commissioners for Baltimore City v. KouglAnnotate this Case
The Board of Liquor License Commissioners for Baltimore City (the Liquor Board) found that Steven Kougl and his company, Kougl, Inc., violated three Rules and Regulations for the Board of Liquor License Commissioners for Baltimore City when Kougl’s employee solicited prostitution and exposed her breasts. The Liquor Board imposed a thirty-day suspension of Kougl’s liquor license. The circuit court affirmed. The court of special appeals reversed, concluding (1) the Rules require actual or constructive knowledge on the part of the licensee, and (2) therefore, Kougl did not violate the Rules at issue because his employee acted improperly without his knowledge. The Court of Appeals reversed, holding (1) the Rules impose strict liability on licensees for offending conduct that occurs on their premises, and (2) therefore, the Liquor Board was not required to show that Kougl knew or should have known about his employee’s actions to find that he violated the Rules.