Christopher Handler, a corporal with the Brunswick Police Department in Maryland, received two letters of reprimand in August 2023: one for a speeding complaint and another for alleged unprofessional conduct toward a supervisor. Neither incident involved misconduct toward a member of the public. Handler requested a trial board hearing under the Maryland Police Accountability Act of 2021, which governs police discipline, but the City and its police chief denied the request. Handler filed a mandamus action in circuit court, which ordered the City to provide the hearing, and the City appealed.
The Appellate Court of Maryland affirmed, holding that the 2021 law requires a trial board process for all disciplinary matters. The Court focused on Public Safety § 3-106(a)(1), enacted as part of the Maryland Police Accountability Act of 2021, which provides that agencies must establish a process “to adjudicate all matters for which a police officer is subject to discipline.” The Court explained that this language is unambiguous and contains no limitation to misconduct involving members of the public. Accepting the City’s interpretation would require the Court to “add words to the statute that are not there,” which it declined to do.
The Court framed its analysis against the backdrop of the prior Law Enforcement Officers’ Bill of Rights (LEOBR), which the 2021 legislation repealed. The LEOBR provided procedural protections in disciplinary cases but was more limited in scope, generally tied to more serious or punitive actions. By contrast, the 2021 Act created a broader disciplinary framework, including a statewide matrix and a trial board process that applies more expansively.
The City argued that, despite the broader statutory language, the new law should be read narrowly in light of its origins in police reform efforts focused on public accountability and civilian complaints. The Court rejected that approach. It emphasized that whatever the motivations behind the 2021 reforms, the enacted statutory text controls. If the legislature chose to expand procedural protections beyond those available under the LEOBR, courts must apply that choice as written.
The Court also pointed to subsequent amendments confirming that expansion. A 2022 amendment clarified that the trial board process applies to “all internal and external matters” that may result in discipline, reinforcing that the statute reaches internal discipline as well as public-facing misconduct.
Because Handler was plainly subject to discipline when he received the reprimands, the Court held that he was entitled to a trial board hearing under the 2021 Act. It therefore affirmed the circuit court’s order granting mandamus relief and requiring the City to provide that process.
City of Brunswick v. Handler, 2026 WL 575004 (Md. Ct. Spec. App. Mar. 2, 2026).