Prince George's County v. Longtin, 19 A.3d 859

Longtin was arrested Oct. 5, 1999 for the murder of his wife, interrogated for ~36 hours, and held for ~8 months; exculpatory DNA results were discovered during detention but not disclosed to him; a serial rapist’s DNA matched another suspect, after which Longtin was released.
During detention, police obtained and withheld exculpatory and other evidence, and Longtin’s trial included claims of pattern or practice against the department for unconstitutional interrogation practices.
Longtin pursued a 13-count civil action in 2006 alleging constitutional violations, false arrest/imprisonment, malicious prosecution, IIED, invasion of privacy/false light, and a pattern-or-practice claim; jury awarded about $5.2 million compensatory and >$1 million punitive damages.
The circuit court denied portions of summary judgment; the Court of Special Appeals affirmed; this Court granted certiorari to address LGTCA notice, damages caps, pattern-or-practice viability, and admission of exculpatory evidence, ultimately affirming the lower courts.
The Court held that (i) LGTCA notice accrued at release for false arrest/imprisonment, rendering Longtin’s notice timely; (ii) retroactive application of the LGTCA damages cap violates vested rights; (iii) Maryland recognizes a pattern-or-practice claim under Article 24; and (iv) evidentiary preservation issues related to DNA evidence were not dispositive.

Issue	Plaintiff's Argument	Defendant's Argument	Held
LGTCA notice accrual for false arrest/imprisonment	Longtin’s notice timing should be tied to release from prison	Notice began at arrest date, precluding most claims	Notice timely; accrual tied to release (February 2000) per false arrest/imprisonment rule.
Whether LGTCA damages cap applies to constitutional torts	Cap would unduly limit compensatory recovery for constitutional torts	Cap applies to all local-government liability, including constitutional harms	Retroactive cap violates vested rights; cap does not apply to this jury award.
Whether Maryland recognizes a pattern-or-practice claim under Article 24	Pattern-or-practice liability exists under Maryland Constitution for unconstitutional policy	Monell-type claim not needed or incompatible with state law	Pattern-or-practice claim recognized and supported by evidence.
Admission of exculpatory DNA results and subsequent conviction evidence	Exculpatory DNA and later conviction evidence were relevant to constitutional claims	Not preserved/apportioned properly and should be limited	Preservation issues unresolved or non-dispositive; not grounds to overturn judgment.

Heron v. Strader, 361 Md. 258, 761 A.2d 56 (2000) (accrual of LGTCA notice for false arrest/imprisonment by date of injury)
Wallace v. Kato, 549 U.S. 384, 127 S. Ct. 1091 (2007) (discusses accrual concepts for false imprisonment)
Monell v. Dep't of Soc. Servs., 436 U.S. 658, 98 S. Ct. 2018 (1978) (municipal liability for unconstitutional policies)
DiPino v. Davis, 354 Md. 18, 729 A.2d 354 (1999) ( Maryland recognizes respondeat superior for constitutional torts)
Dua v. Comcast Cable of Md., Inc., 370 Md. 604, 805 A.2d 1061 (2002) (retroactive limits on accrued causes of action; vested rights)
Housing Auth. v. Bennett, 359 Md. 356, 754 A.2d 367 (2000) (constitutionality and scope of LGTCA damages cap)