Police officer sought judicial review of decision of city police department trial board, determining that officer had violated department rules. The Circuit Court reversed and remanded. Department appealed. The Court of Special Appeals reversed and remanded. Officer sought certiorari review.
The Court of Appeals held that:
- Brady protections, requiring State disclosure of exculpatory evidence to the defense in criminal cases, do not extend to the administrative processes of the Law Enforcement Officers’ Bill of Rights (LEOBR), and
- LEOBR does not require disclosure of information regarding pending investigations unrelated to the officer and his or her specific charges.
LEOBR does not require state and federal agencies to provide information regarding pending investigations unrelated to the officer and his or her specific charges in officer disciplinary proceedings. The Legislature only intended to disclose information related to the officer and the charges specified, rather than the disclosure of information regarding an alleged extraneous investigation of a witness, which did not relate to the officer and his or her specific charges involved in the hearing.