Prince George's County v. Columcille Building Corp., 98 A.3d 1043

On Dec. 29–30, 2007, two Prince George’s County police officers (Sgt. Sanders and Cpl. Tims), assigned as off-duty security for an event at the Columcille Building, shot Donte Guzman in the building’s parking lot.
Guzman sued the officers, Prince George’s County, Columcille Building Corporation, and others, alleging common law torts and constitutional violations and asserting respondeat superior liability against the County and Columcille.
At trial (Aug.–Sept. 2012), Oxon Hill’s motion for judgment was granted by consent; Columcille’s initial motion was denied but its renewed motion at the end of all evidence was granted and a judgment for Columcille was entered on Nov. 7, 2012.
The jury returned verdicts against the County and the officers; after post-verdict motions the judgment against the County was reduced to $200,000 (entered Dec. 21, 2012).
The County appealed on Jan. 22, 2013, but its notice did not reference the Nov. 7 judgment in favor of Columcille; Guzman had earlier appealed and dismissed his appeal as to Columcille and later told this Court he would not pursue claims against Columcille if remanded.
The Court of Special Appeals concluded that, because Guzman will not litigate his claims against Columcille and the County cannot obtain contribution or assert a cross-claim now, there is no effective relief available — rendering the County’s appeal moot.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the trial court erred by granting Columcille’s renewed motion for judgment on the ground no employer-employee relationship existed between Columcille and the officers	Guzman argued Columcille was not the officers’ employer and thus not vicariously liable	County sought review of Columcille’s judgment, contending the court erred in ruling no employment relationship existed	Appeal dismissed as moot; court did not reach merits because Guzman will not pursue claims against Columcille and County cannot obtain effective relief
Whether the County can obtain contribution from Columcille post-trial without a cross-claim	Guzman implied the County preserved no objection and thus Columcille’s judgment should stand	County argued it could seek relief and contribution against Columcille	County cannot obtain contribution because Columcille was judicially determined not to be a joint tort-feasor and County has not paid the judgment; contribution unavailable

Attorney Gen. v. Anne Arundel Cnty. Sch. Bus Contractors Ass’n, 286 Md. 324 (general principle that courts avoid moot questions)
Suter v. Stuckey, 402 Md. 211 (definition of mootness and lack of effective remedy)
Hayman v. St. Martin’s Evangelical Lutheran Church, 227 Md. 338 (mootness doctrine principles)
Lerman v. Heeman, 347 Md. 439 (post-trial contribution allowed even without cross-claim when jury found parties joint tort-feasors)
Max’s of Camden Yards v. A.C. Beverage, 172 Md. App. 139 (Rule 2-614 contribution practice and tort-feasor status determination)
Montgomery Cnty. v. Valk Mfg. Co., 317 Md. 185 (contribution right inchoate until payment of common liability)