333 A.3d 610
Md. Ct. Spec. App.2025Background
- Michael Young, an inmate at the Maryland Correctional Training Center, was attacked on December 25, 2017, first in his cell by one group of inmates with weapons, then in the recreation hall by a second group without weapons.
- Young had previously warned Warden Dovey in writing that he feared for his safety after a prior attack, but no investigation or meaningful response occurred.
- Young sued the State of Maryland, the Maryland Department of Public Safety and Correctional Services (DPSCS), Sergeant Wright (the officer on duty during the attack), and Warden Dovey, asserting constitutional and negligence claims.
- The jury found both officers negligent but not constitutionally liable, and found the State liable under a "pattern or practice" (Longtin) claim, awarding Young a total of $4,000,000 in damages.
- The State moved post-trial to reduce damages and for judgment notwithstanding the verdict; these motions were denied and the State appealed.
- The appellate court reversed the Longtin judgment against the State for insufficient evidence but upheld the negligence verdicts and ruled the damages cap under the Maryland Tort Claims Act (MTCA) applied separately to each distinct attack, totaling $800,000.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether a Longtin pattern/practice claim lies against the State | It applies; not limited to local governments | Should only apply to local gov't, not State | It may be brought against the State under Maryland law |
| Sufficiency of evidence for Longtin claim | State maintained unconstitutional pattern/policy leading to injury | No evidence of State pattern/policy directly causing injury | Insufficient evidence to support a State pattern/practice claim in this instance |
| Negligence by Sergeant Wright and Warden Dovey | Duty to protect was breached and harm was foreseeable | Harm not foreseeable; no breach; verdict unsupported | Sufficient evidence; verdicts against them for negligence upheld |
| Application of MTCA damages cap | Two attacks are two incidents; cap applies to each | Only one “incident/occurrence”; single $400,000 cap | Two distinct incidents; cap is $400,000 per, for a total cap of $800,000 |
Key Cases Cited
- Prince George’s County v. Longtin, 419 Md. 450 (2011) (Pattern or practice claims for unconstitutional conduct can be brought against local governments; now extended to State).
- DiPino v. Davis, 354 Md. 18 (1999) (Respondeat superior and liability for constitutional torts of employees applies to municipal entities under Maryland law).
- Cooper v. Rodriguez, 443 Md. 680 (2015) (Addressing negligence and duty of care by correctional officers to inmates).
- Steamfitters Local Union No. 602 v. Erie Ins. Exch., 469 Md. 704 (2020) (Elements required to prove negligence under Maryland law).
- Pittway Corp. v. Collins, 409 Md. 218 (2009) (Causation standards for tort/negligence claims in Maryland).