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$200,000 Award Against State Arising Out Of Police Beating Reinstated
Jones v. State of Maryland
This case has its genesis in an altercation between Kimberly Jones (“Ms. Jones”) and two (2) Prince George’s County deputy sheriffs during their attempt to serve an arrest warrant for an individual at Ms. Jones’ home. Ms. Jones filed a twelve count Complaint in the Circuit Court for Prince George’s County, Maryland, naming as Defendants the deputies and their employer, the State of Maryland (“the State”). Among other allegations, Ms. Jones claimed that the State was negligent in its training of the two (2) deputies in connection with the Fourth Amendment limitations on in-home execution of arrest warrants. The jury returned a verdict finding the State liable for the negligent training of the two (2) deputies, and awarded Ms. Jones $261,000.00, which the Circuit Court later reduced to $200,000.00, pursuant to the Maryland Tort Claims Act. Both parties appealed the judgment.
The State raised numerous claims of error, including, that the trial judge erred in entering judgment against the State, because, in the words of the State: (1) the State did not owe any duty to Ms. Jones, as opposed to the public generally, with respect to the training of the deputies; and (2) Ms. Jones failed to present evidence that the State owed a duty or breached a duty with respect to its training of the deputies, and failed to present that any such breach was a proximate cause of her alleged damages. In connection with its later claim, the State asserted that Ms. Jones was obligated to present expert evidence in support of her claim of negligent training.
The Court of Special Appeals reversed the judgment of the trial court, agreeing with the State that the Circuit Court should have entered judgment in the State’s favor because there was legally insufficient evidence that the State breached any duty to Ms. Jones in connection with the tort of negligent training and supervision. In light of that disposition, the Court of Special Appeals did not decide the remaining claims that the parties raised. Ms. Jones then filed a Petition for Writ of Certiorari, asking the Court of Appeals of Maryland to answer the following questions: (1) Does the Public Duty Doctrine shield the State from a claim of negligence when its police officers commit intentional torts and/or constitutional violations?; (2) Is expert testimony necessary for a Plaintiff to meet her burden of proof on a claim of negligent training or supervision of police officers?; and (3) Is evidence sufficient to prove a negligent training claim when the officer testified that their training permitted them to enter a citizen’s home without constitutionally sufficient justification to prove a claim of negligent training?
Regarding whether the Public Duty Doctrine shields the State from a claim of negligence when its police officers commit intentional torts and/or constitutional violations, the Court found that the Public Duty Doctrine shields the State and its law enforcement officers when they are engaged in their duty to protect the public. This duty alone arises, though, when law enforcement is engaged in protecting individuals from harm caused by other individuals. The doctrine is, however, inapplicable to cases such as the instant case, where the alleged harm was caused directly by the State.
As to whether expert testimony is required for a Plaintiff to meet her burden of proof on a claim of negligent training or supervision of police officers, the Court noted that generally, expert testimony is required to establish the standard for claims of professional negligence. The Court then found, however, that when the alleged standard of care is the Fourth Amendment and the alleged breach can be understood using everyday experience and common sense, no expert testimony is required. The trial court, when instructing the jury, supplies the only necessary expert clarification of the standard of care.
Finally, regarding whether the evidence that the police officers committed intentional torts and constitutional violations, coupled with testimony by the officers that their actions were in accordance with their training, and evidence that the officers entered a citizen’s home without constitutionally sufficient justification sufficient to prove a claim of negligent training, the Court relied upon the Supreme Court case Payton v. New York. In that case, the Supreme Court held that an arrest warrant authorizes law enforcement officers to enter the home of the subject of the arrest warrant, so long as the officers have reason to believe the arrestee is in his or her home. The Supreme Court, however, held in Steagald v. United States, that law enforcement officers must first obtain a search warrant before knowingly entering the home of a third-party in order to arrest a non-resident individual found inside. In the instant case, a jury could have inferred from the testimony of the Prince George’s County Sheriff Department’s deputies that the State trained law enforcement officers to execute arrest warrants in a manner inconsistent with the rules of Payton and Steagald. There was, therefore, sufficient evidence to allow the question to reach the jury of whether the State breached its duty to train officers in a manner consistent with Fourth Amendment principles.
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