White v. State, 19 A.3d 369

On Oct. 24, 2002, White, a Thurmont police officer, pursued suspects after a dispatcher reported an armed robbery.
The dispatch described a red Nissan fleeing toward Route 15; White’s pursuit covered rural two-lane roads with no shoulder.
White lost control on Yellow Springs Road, crashed into a culvert, and was severely injured, impairing his recall of events.
White sued Henrickson and the State, alleging negligent dispatch, negligent hiring/supervision, and respondeat superior liability.
The circuit court dismissed on qualified immunity for Henrickson; later, it granted judgment for State based on the firefighter’s rule and contributory negligence; the Court of Special Appeals affirmed.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Does the firefighter's rule bar White's tort claims against the State for a negligent dispatch?	White argues dispatch negligence created the risk of pursuit and is not within anticipated risks.	State contends injury arose from pursuing a suspect in a high-speed chase, an inherent risk; rule bars claim.	Yes; firefighter's rule bars.
Should there be a special duty exception to the firefighter's rule in this case?	Special duty exception should apply to public safety officers suing government employees.	No special-duty exception should be recognized; rule governs the relation to the hazard created by the negligence.	Not addressed; not adopted.
Is the firefighter's rule applicable to claims between public safety officers (officer vs. state dispatcher)?	Rule should not bar suits between fellow public safety officers or state employees.	Rule applies to injuries arising from hazards inherent to police work, regardless of opponent.	Rule applies; bars suit.

Flowers v. Rock Creek Terrace, 308 Md. 432 (Md. 1987) (public policy underpins firefighter's rule; limits recovery for injuries tied to the need for emergency response)
Sherman v. Suburban Trust Co., 282 Md. 238 (Md. 1978) (injury from expected risk during response may be barred; duty of care limited during initial risk period)
Tucker v. Shoemake, 354 Md. 413 (Md. 1999) (rejects transactional approach; injuries not tied to the required presence may fall outside rule)
Hart v. Swaroop, Inc., 385 Md. 514 (Md. 2005) (injuries during rescue may be barred if within anticipated occupational risk and related to the hazard)
Steinwedel v. Hilbert, 149 Md. 121 (Md. 1925) (early foundation linking premises liability to firefighter's rule)