Jones v. State, 38 A.3d 333

Petitioner Kimberly Jones alleges negligent training and supervision by the State in relation to deputies Falby and Henderson who forcibly entered her home during a warrant service.
A 12-count complaint was filed; trial proceeded on counts I–X, with a verdict for the deputies on most counts and a $5,000 battery award for Petitioner; later counts XI–XII were tried separately for negligent retention/training/supervision.
The jury found the State liable for negligent training/supervision and the circuit court reduced damages under the Maryland Tort Claims Act to $200,000.
The Court of Special Appeals reversed, holding there was legally insufficient evidence the State breached any duty in training the deputies.
Maryland Supreme Court granted certiorari to decide: public duty doctrine applicability, necessity of expert testimony, and sufficiency of evidence on negligent training.
The Court ultimately holds that the public duty doctrine does not bar the claim, expert testimony is not required to establish the standard of care here, and there is enough evidence to support negligent training based on Payton/Steagald Fourth Amendment principles.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Does the public duty doctrine bar negligent training claims against the State when police officers entrench in-home entry via arrest warrants?	Jones argues public duty doctrine does not shield the State because the claim is about training, not protection from private harm.	State contends the doctrine bars liability absent a special duty to the individual.	Public duty doctrine does not bar negligent training claims against the State.
Is expert testimony necessary to prove negligent training or supervision of police officers?	Jones contends expert proof is not required; Fourth Amendment standard can be explained to the jury.	State argues expert testimony is needed to establish standard of care in police training.	Expert testimony is not required; the Fourth Amendment standard can be understood through jury instructions.
Was there sufficient evidence that the State negligently trained Deputies Falby and Henderson in accordance with Fourth Amendment rules on in-home arrest warrants?	Jones presented deputies’ testimony showing training allowed entry based on warrant address and belief the arrestee was inside, conflicting with Payton/Steagald standards.	State contends the training conformed to Fourth Amendment standards and did not breach duty.	There is sufficient evidence to support a jury finding of negligent training.

Horridge v. St. Mary’s County Dep’t of Soc. Servs., 854 A.2d 1232 (Md. 2004) (establishes negligent selection/retention duty to public; four-part элементов)
Evans v. Morsell, 395 A.2d 480 (Md. 1978) (extends duty to the public for selection/retention of employees in contact with the public)
Ashburn v. Anne Arundel County, 510 A.2d 1078 (Md. 1986) (public duty doctrine shields police for failure to protect from private harm; special relationship limits)
Payton v. New York, 445 U.S. 573 (U.S. 1980) (arrest warrant on arrestee permits entry if arrestee inside; core Fourth Amendment rule)
Steagald v. United States, 451 U.S. 204 (U.S. 1981) (entry into third-party home requires different warrant basis; not a general apply to arrest warrants)