Ireton v. Chambers, 143 A.3d 215

Lore L. Chambers, former assistant city administrator of Salisbury, sued Mayor James P. Ireton, Jr. for assault after she was fired; jury found assault but no actual malice.
CJP § 5-507(a)(1) provides municipal officials immunity "from any civil liability" when acting in a discretionary capacity, without malice, and within scope of employment.
The jury answered: assault = Yes; malice = No; they did not reach damages.
The circuit court clerk initially docketed a judgment for Chambers against Ireton for $0.00; the court then revised, re-revised, and ultimately restored the zero-dollar judgment after multiple post-judgment motions.
Ireton appealed, arguing that statutory immunity from "civil liability" required the court to enter judgment in his favor (not a zero-dollar judgment against him).
The Court of Special Appeals reviewed the statutory interpretation de novo and held the zero-dollar judgment improper; it reversed and directed entry of judgment for Ireton.

Issue	Chambers' Argument	Ireton's Argument	Held
Whether CJP § 5-507(a)(1) immunizes an official from entry of any civil judgment (including $0) or only from an award of damages	§5-507 bars an award of damages; a zero-dollar judgment is permissible because it imposes no damages	Immunity from "civil liability" bars any civil judgment against the official, even if nominal ($0)	Immunity from "civil liability" means immunity from entry of a civil judgment; court must enter judgment for the official when jury finds no malice

Walter v. Gunter, 367 Md. 386 (discussing de novo review for statutory interpretation)
Gluckstern v. Sutton, 319 Md. 634 (treatment of revisory motions and finality)
Yarema v. Exxon Corp., 305 Md. 219 (finality principles for revised judgments)
Thacker v. City of Hyattsville, 135 Md. App. 268 (plaintiff must produce evidence of malice to overcome official immunity)
Thomas v. City of Annapolis, 113 Md. App. 440 (same: plaintiff bears burden to permit inference of malice)