The Maryland Court of Appeals recently ruled on a significant case involving the Maryland Department of Health and several defendants found incompetent to stand trial. The court's decision affects how the Department must handle the admission of these individuals to designated healthcare facilities. This ruling is crucial as it clarifies the responsibilities of the Department regarding timely admissions and the sanctions that can be imposed for non-compliance.
The case, known as Maryland Department of Health v. Thompson, was filed on August 25, 2026, under docket number 376pet/25. It involved multiple defendants, including Rachel D. Thompson, Stashauna Daree M. Whitaker, William Antoine Lunn, Devonte J. Scott, Cortni Alston, and Michael Maggio. All the defendants were found incompetent to stand trial and were awaiting transfer to healthcare facilities after being detained at the Baltimore County Detention Center (BCDC).
The dispute arose after the Department of Health failed to admit these defendants to designated facilities within the required ten-day period following their court commitment orders. This delay led the defendants to seek sanctions against the Department, arguing that it had not complied with the law. The case highlights the tension between the Department's operational procedures and the legal requirements for handling defendants deemed incompetent.
Initially, the District Court held a consolidated hearing on the defendants' motions for sanctions on August 5, 2025. The court ruled that the Department should reimburse BCDC $141 for each day it failed to meet the ten-day deadline. This sanction was retroactive to the eleventh business day after the commitment orders and would continue until each defendant was admitted to a healthcare facility.
The Department appealed this decision to the Circuit Court for Baltimore County. On November 10, 2025, the circuit court imposed additional non-monetary sanctions on the Department. These included prohibiting the Department from relying on clinical acuity screening surveys and requiring it to admit defendants in the order of their commitment.
The Department then appealed to the Appellate Court of Maryland, which transferred the case to the Court of Appeals. The court held the petitions pending until it decided a related case, Maryland Department of Health v. Boulden, which was issued on July 15, 2026. This decision clarified the authority of courts to impose sanctions on the Department for failing to comply with the ten-day requirement.
In its ruling, the Court of Appeals stated that the Department is required to admit defendants found incompetent to stand trial and dangerous as soon as possible, but no later than ten business days after receiving the commitment order. The court emphasized that if the Department fails to meet this deadline, the court may impose sanctions to compel compliance, including reimbursement for detention costs.
The court ruled, "If the court can reasonably conclude, based on the evidence before it, that the Department has not taken available steps to admit the particular defendant before the court as soon as possible, the court may impose a sanction that is designed to coerce the Department to do so."
However, the Court of Appeals found that the sanctions imposed by the circuit court did not comply with the Boulden ruling. The court noted that the circuit court's requirements did not focus on the individual defendants and that there was no statutory basis for the Department to prioritize acuity in the manner ordered by the circuit court.
The Court of Appeals granted the petitions for writ of certiorari, vacated the circuit court's judgment, and remanded the cases for reconsideration in light of the Boulden decision. This means that the lower court must reevaluate its sanctions against the Department based on the new legal standards established by the Court of Appeals.
The impact of this ruling is significant for the Maryland Department of Health and the defendants involved. It reinforces the requirement that the Department must act promptly to admit defendants found incompetent to stand trial. The ruling also clarifies the limitations of the circuit court's authority to impose sanctions, ensuring that future sanctions align with the specific needs of each defendant.
Going forward, this decision may set a precedent for how similar cases are handled in Maryland. It emphasizes the importance of timely admissions and the legal consequences for failing to comply with established deadlines. The ruling could lead to more scrutiny of the Department's practices and may prompt changes to ensure compliance with the law.
As for what’s next, the circuit court must now reconsider the sanctions imposed on the Department in light of the Court of Appeals' ruling. It remains to be seen whether the Department will appeal this decision further or if there are related cases pending that could influence future rulings.