The Maryland Court of Appeals issued a significant ruling regarding the Local Government Tort Claims Act (LGTCA) in the case of Prince George's County v. Joseph Watts, No. 56, September Term, 2025. The court's decision clarifies how the LGTCA interacts with claims made under the Maryland Fair Employment Practices Act (MFEPA) and other state statutes. This ruling impacts local government liability in cases of employment discrimination and retaliation.
Joseph Watts, a former correctional officer for Prince George's County, sued the county after he was terminated from his position following a disability. He alleged that the county discriminated against him based on his disability and retaliated against him for raising concerns about discrimination. A jury initially awarded Watts $1.7 million in damages, but the trial court later reduced this amount to $400,000, citing the LGTCA's damages cap. Watts appealed, leading to the court's recent ruling.
The LGTCA limits the amount of damages that can be awarded against local governments for the tortious acts or omissions of their employees. However, the court found that claims under the MFEPA are not subject to this cap. The court ruled that MFEPA is a comprehensive law that allows claims against local governments and sets its own damages limits. In contrast, the court determined that claims under § 20-1202 of the State Government Article, which addresses violations of the Prince George's County Code, are subject to the LGTCA cap.
In its ruling, the court stated, "We agree with the Appellate Court that MFEPA claims are not subject to the LGTCA damages cap. MFEPA is a comprehensive statutory scheme, and it expressly contemplates claims against local governments and requires that they be treated the same as claims against other defendants." The opinion was authored by Chief Judge Fader, with Justices Watts, Booth, Biran, Gould, Eaves, and Getty concurring.
This ruling has significant implications for employees of local governments in Maryland. It clarifies that while claims of disability discrimination and retaliation under MFEPA can lead to higher damages without the limitations of the LGTCA, claims based on local county codes may still fall under the LGTCA's caps. This distinction is critical for individuals pursuing legal action against local governments for discrimination, as it affects the potential recovery amounts.
Moving forward, this ruling may influence how local governments handle employment discrimination claims and could lead to changes in how they approach liability and damages in such cases. The decision underscores the importance of understanding the specific legal frameworks governing employment discrimination and local government liability.
As for what’s next, the ruling can be appealed to the U.S. Supreme Court, but it is unclear if that will happen. There are no related cases currently pending that directly address this issue, but the implications of this ruling may prompt further legal challenges in the future.