Robinson v. Baltimore Police Department, 33 A.3d 972

LEOBR § 3-106(a) requires charges within 1 year after the act giving rise to the charges comes to attention.
Houssain accused Petitioner of prostitution; she identified him as 'Steve' Robinson in Feb 2007; IID confirmed identity as Gregory Robinson.
Investigation showed the misconduct occurred in Baltimore County; criminal proceedings were unfounded, but IID continued the administrative investigation.
IID charged Petitioner on June 26, 2008 with six violations, including a false statements charge based on July 11 and August 1, 2007 interviews.
Petitioner argued the limitations clock started Feb 22, 2007 for all charges related to the underlying incident; BPD policy allegedly treated false statements as an extension of underlying charges.
Circuit Court granted summary judgment for the BPD on the false statement charge; Court of Special Appeals affirmed; petition for certiorari granted to address whether the same one-year date applies to false statements.

Issue	Plaintiff's Argument	Defendant's Argument	Held
When does § 3-106(a) accrue for a false-statement charge?	Robinson argues accrual is Feb 22, 2007 (underlying incident).	BPD argues accrual is the date of the false statements (July 11, 2007), within one year.	Accrual starts at the false statement, July 11, 2007.

State v. Johnson, 415 Md. 413 (2010) (ascertaining legislative intent and plain meaning of statutes)
Baltimore Police Dep't v. Etting, 326 Md. 132 (1992) (limits of LEOBR § 3-106 as a statute of limitations)
Pollock v. Patuxent Inst. Bd. of Review, 374 Md. 463 (2003) (Accardi-related administrative procedure considerations)
Ikossi-Anastasiou v. Bd. of Supervisors of La. State Univ., 579 F.3d 546 (5th Cir. 2009) (retaliation/discrimination analogy for accrual timing)
Accardi v. Shaughnessy, 347 U.S. 260 (1954) (agency procedures must be followed where appropriate)