Prince George's Cnty. v. Watts

Summary

The Supreme Court of Maryland held that the Local Government Tort Claims Act damages cap does not apply generally to state statutory claims sounding in tort, but attaches to a specific statutory tort claim where the governing scheme shows no legislative determination about local government liability. Applying that rule, the Court held the cap does not reach Joseph Watts's MFEPA disability discrimination and retaliation claims, which are governed by MFEPA's own employer-size-based damages caps, but does reach his parallel claim under State Gov't § 20-1202 enforcing Prince George's County Code § 2-222. The Court affirmed in part and reversed in part the Appellate Court's judgment and remanded for entry of judgment in the higher of the MFEPA-capped or LGTCA-capped amounts. Judge Watts concurred in the MFEPA result but dissented as to § 20-1202, would have held the LGTCA cap inapplicable to both statutes, and would have affirmed the Appellate Court in full.