City of Brunswick, et al. v. Christoper Handler, No. 1437, September Term, 2024. Opinion by Kenny, J. Filed March 2, 2026.
MUNICIPAL, COUNTY AND LOCAL GOVERNMENT
The Maryland Police Accountability Act (MPAA) provision governing trial board process for disciplinary actions applies to “all matters for which a police officer is subject to discipline[,]” and is not limited to matters involving a member of the public. Circuit Court for Frederick County Case No.: C-10-CV-24-000331 REPORTED
IN THE APPELLATE COURT
OF MARYLAND
No. 1437
September Term, 2024
CITY OF BRUNSWICK, ET AL.
v.
CHRISTOPHER HANDLER
Wells, C.J., Leahy, Kenney, James A., III. (Senior Judge, Specially Assigned),
JJ.
Opinion by Kenney, J. ______________________________________
Filed: March 2, 2026
Pursuant to the Maryland Uniform Electronic Legal Materials Act (§§ 10-1601 et seq. of the State Government Article) this document is authentic.
2026.03.02 15:26:30 -05'00' Gregory Hilton, Clerk After Christopher Handler, appellee, received two letters of reprimand from his
employer, the Brunswick Police Department, he requested a trial board hearing. When that
request was denied, he filed a petition for writ of mandamus in the Circuit Court for
Frederick County against appellants, the City of Brunswick and its chief of police, Kevin
Grunwell. After a hearing, the circuit court determined that appellants failed to comply
with the hearing requirement set forth in Md. Code Ann., Public Safety (“Public Safety”)
§ 3-106(a)(1). In their timely-noted appeal, appellants ask the following question:
Did the Circuit Court err by entering an order granting a writ of mandamus and finding that [t]he City of Brunswick and Kevin Grunwell failed to comply with the trial board hearing requirement for disciplinary procedures set forth in the Maryland Police Accountability Act of 2021?
For reasons we shall discuss, we answer that question in the negative and affirm the
judgment of the circuit court.
BACKGROUND
The facts before us in this appeal are straightforward and undisputed. Mr. Handler
is a corporal with the Brunswick Police Department in Frederick County, Maryland. On
August 24, 2023, he received two letters of reprimand from appellants – one relating to a
speeding complaint, and the other relating to an allegation of unprofessional conduct
towards a supervisor. Neither letter of reprimand related to conduct involving a member of
the public. 1 Mr. Handler requested a trial board hearing under Public Safety § 3-106(a)(1), 0F
1 The record reflects that the speeding complaint was made by a private citizen who happened to be a federal police officer. The private citizen “advised that he did not wish to make a formal complaint but felt the need to contact the department” after observing Mr. Handler speeding. Because neither party disputes that the speeding complaint did not (continued…) which appellants denied. Mr. Handler filed a petition for writ of mandamus seeking to
compel appellants to provide that process. After a hearing, the circuit court found that
appellants failed to comply with Public Safety § 3-106(a)(1) in denying Mr. Handler’s
request and granted Mr. Handler’s petition for writ of mandamus. Appellants noted the
instant appeal.
STANDARD OF REVIEW
Generally, we review an action that has been tried without a jury “on both the law
and the evidence[,]” and we do not “set aside the judgment of the trial court on the evidence
unless clearly erroneous[.]” Md. Rule 8-131(c). The deference shown to the trial court’s
“factual findings under the clearly erroneous standard does not, of course, apply to legal
conclusions.” Nesbit v. Gov’t Emps. Ins. Co., 382 Md. 65, 72 (2004). When, as here, the
ruling on appeal “‘involves an interpretation and application of Maryland statutory and
case law, [we] must determine whether the [circuit] court’s conclusions are legally correct
under a de novo standard of review.’” Id. (quoting Walter v. Gunter, 367 Md. 386, 392
(2002)); see also Wiggins v. Griner, 155 Md. App. 530, 533 (2004). Because the parties
stipulated to the facts before the circuit court and do not challenge the court’s factual
findings, our task is to determine whether the court’s ruling was “legally correct[.]” Nesbit,
382 Md. at 72 (cleaned up).
“involv[e]” a member of the public, we will assume for the purposes of this opinion that it did not. 2 DISCUSSION
Contentions
Appellants assert that “[a]t the heart of the instant appeal are the parties’ competing
interpretations” of Public Safety § 3-106. They contend that, “when viewed in the statutory
scheme of the Act[, Public Safety § 3-106] pertains to misconduct involving a member of
the public and a police officer,” and because neither letter of reprimand involves a member
of the public, the denial of Mr. Handler’s request for a trial board process was proper.
Mr. Handler contends that “there is only one reasonable interpretation” of Public
Safety § 3-106(a)(1), which states that “every law enforcement agency in the state is
required to establish a trial board process to adjudicate all matters for which a police officer
is subject to discipline.” In support of that contention, he states that there is “no
differentiation in § 3-106(a)(1) between allegations of police misconduct involving a
member of the public and allegations of police misconduct that do not involve a member
of the public[,]” and therefore, the circuit court properly determined that Public Safety § 3-
106(a)(1) applies to “all matters for which a police officer is subject to discipline.”
Analysis
I. Relevant Provisions of the MPAA
Sections 3-101 to 3-113 of the Public Safety Article were enacted in 2021 with the
passage of the Maryland Police Accountability Act (“MPAA”). 2 In pertinent part, the 1F
2 Five bills were enacted as part of the Maryland Police Accountability Act of 2021: Senate Bill 178, Senate Bill 71, Senate Bill 600, House Bill 670, and Senate Bill 786. See Maryland General Assembly, https://perma.cc/B5C8-F3HT (last accessed January 15, (continued…) 3 MPAA provides that “[t]he Maryland Police Training and Standards Commission shall
develop and adopt, by regulation, a model uniform disciplinary matrix for use by each law
enforcement agency in the State” and that “[e]ach law enforcement agency shall adopt the
uniform State disciplinary matrix for all matters that may result in discipline of a police
officer.” Public Safety § 3-105(a)-(b). The Maryland Statewide Model Disciplinary
Matrix (the “Matrix”) provides that the Matrix is the “required framework through which
all matters of discipline will be imposed as a result of a sustained disposition from an
administrative investigation into an officer’s misconduct.”
Police misconduct is defined by the MPAA as “a pattern, a practice, or conduct by
a police officer or law enforcement agency that includes: (1) depriving persons of rights
protected by the constitution or laws of the State or the United States; (2) a violation of a
criminal statute; and (3) a violation of law enforcement agency standards and policies.”
Public Safety § 3-101(g). The Matrix provides examples of misconduct, ranging from less
2026). Senate Bill 178 set forth additional requirements for the application and execution of no-knock search warrants. Final Bill Text, S.B. 178, 2021 Leg., 442 Sess. (Md. 2021). Senate Bill 71 required the implementation and the use of body-worn cameras when officers engage with civilians and set out procedures for monitoring and addressing issues regarding uses of force by officers. Final Bill Text, S.B. 71, 2021 Leg., 442d Sess. (Md. 2021). Senate Bill 600 established an independent investigative unit in the Office of the Attorney General to investigate “police-involved death[s] of . . . civilians.” Final Bill Text, S.B. 600, 2021 Leg., 442d Sess. (Md. 2021). In addition, Senate Bill 600 prohibited police departments from acquiring “weaponized . . . vehicle[s,] . . . destructive device[s,] firearm silencer[s,] or . . . grenade launcher[s]” from military equipment surplus programs. Id. House Bill 670 repealed the Law Enforcement Officers’ Bill of Rights and required each county in Maryland to establish a police accountability board. Final Bill Text, H.B. 670, 2021 Leg., 442d Sess. (Md. 2021). Control of the Baltimore City Police Department was returned to the City of Baltimore under Senate Bill 786. Final Bill Text, S.B. 786, 2021 Leg., 442d Sess. (Md. 2021).
4 serious violations such as “improper attire and grooming” and being “[l]ate for duty
assignment[,]” to the most severe violations, including “[t]ampering or manufacturing of
evidence” or “[i]ntentional malicious and unjustified use of force resulting in serious bodily
injury or death[.]”
Further, the MPAA authorizes the Maryland Police Training and Standards
Commission to adopt implementing regulations. Public Safety § 3-114. The regulations
implemented pursuant to the MPAA appear in two Code of Maryland Regulations
(“COMAR”) chapters: COMAR 12.04.09, which focuses on general disciplinary
processes, and COMAR 12.04.10, which establishes the Matrix. Among other things,
COMAR 12.04.10.04 provides various disciplinary ranges, including letters of reprimand.
COMAR 12.04.10.04B(1)(b). The Matrix provides that letters of reprimand shall “detail[]
the officer’s wrongful actions and state[] their actions have been deemed inappropriate or
unacceptable.”
The specific provision at issue in the matter before us, Public Safety § 3-106(a)(1),
states that: “[E]ach law enforcement agency shall establish a trial board process in
accordance with this section to adjudicate all matters for which a police officer is subject
to discipline.” Public Safety § 3-106(a)(1). 3 A trial board decision may be appealed to the 2F
circuit court within thirty days; otherwise, the trial board decision is final. Public Safety §
3 An exception, which is not directly relevant to the matter before us, is set forth in Public Safety § 3-106(a)(1). See Public Safety § 3-106(a)(2) (“A small law enforcement agency may use the trial board process of another law enforcement agency by mutual agreement.”). 5 3-106(k)-(l). With certain exceptions, “[p]roceedings of a trial board shall be open to the
public[.]” Public Safety § 3-106(e).
II. Statutory Interpretation
As the Supreme Court of Maryland has stated, “statutory interpretation begins, and
usually ends, with the statutory text itself[.]” Price v. State, 378 Md. 378, 387 (2003).
Indeed, “before judges may look to other sources for interpretation, first there must exist
an ambiguity within the statute, i.e., two or more reasonable alternative interpretations of
the statute.” Id. Therefore, we look first to the statute’s plain language to decide “what
parts, if any, are ‘ambiguous or not clearly consistent with the statute’s apparent purpose.’”
Blood v. Stoneridge at Fountain Green Homeowners Ass’n, Inc., 242 Md. App. 417, 427
(2019) (quoting Hailes v. State, 442 Md. 488, 495 (2015)). Where the statutory language
“is free from such ambiguity, [we] will neither look beyond the words of the statute itself
to determine legislative intent nor add to or delete words from the statute[.]” Price, 378
Md. at 387-88. In other words, when “the meaning of the language is clear and
unambiguous,” we presume the General Assembly “meant what it said.” Willis v.
Montgomery Cnty., 415 Md. 523, 536 (2010).
As noted above, the statutory provision at issue in this appeal, Public Safety § 3-
106(a)(1), clearly states that “each law enforcement agency shall establish a trial board
process in accordance with this section to adjudicate all matters for which a police officer
is subject to discipline.” In short, we are not persuaded that there is more than one
reasonable interpretation of the statutory text. The provision unequivocally requires every
law enforcement agency to establish a trial board process “to adjudicate all matters for
6 which a police officer is subject to discipline.” Id. (emphasis added). Neither Public Safety
§ 3-106(a)(1), nor any other provision within the MPAA, suggests any limitations or
exclusions on the types of matters to be adjudicated by the trial board process. See Public
Safety § 3-101 et seq. We are persuaded that the General Assembly’s unconditional use of
“all matters” includes those matters now at issue before us.
Notably, appellants neither point to an ambiguity within the language of the statute
itself, nor do they advance a reasonable alternative interpretation of that language. Instead,
they urge that we look to various sources outside of the statute to conclude that “[Mr.]
Handler was not entitled to a trial board process” because the letters of reprimand “did not
involve complaints of police misconduct involving a member of the public and a police
officer[.]” In support of their position, appellants assert that Public Safety § 3-106 “should
not be read and considered in a vacuum[.]” We agree that the plain language of a statute is
not to be “interpreted in isolation.” Kushell v. Dep’t of Nat. Res., 385 Md. 563, 577 (2005).
But what appellants fail to acknowledge is that, in the absence of an ambiguity within the
statute, the search for “‘legislative intent ends[,]’” and a ‘“resort to the various, and
sometimes inconsistent, external rules of construction”’ is not necessary. Id. (quoting
Arundel Corp. v. Marie, 383 Md. 489, 502 (2004)).
That said, however, our conclusion is consistent with Public Safety § 3-101(g)(3),
which defines police misconduct broadly to include “violation[s] of law enforcement
agency standards and policies[,]” and Public Safety § 3-105, which provides the authority
for the Matrix, which is the “framework through which all matters of discipline will be
imposed[,]” including such matters relating to attire, grooming, and tardiness. In other
7 words, Public Safety § 3-106(a)(1) need not be read in a vacuum to conclude that it applies
to all levels of misconduct, and not only misconduct involving a member of the public.
Indeed, accepting appellants’ argument that Public Safety § 3-106(a)(1) applies only
to police misconduct involving a member of the public would require us to “add words to
the statute that are not there.” Baires v. State, 249 Md. App. 62, 80 (2021). We would
decline to do that even if we had “determined that an omission from a statute was
inadvertent[.]” Rosemann v. Salsbury, Clements, Bekman, Marder & Adkins, LLC, 412 Md.
308, 327 (2010) (“Even where we have determined that an omission from a statute was
inadvertent, we have declined to supply words to reach a desired result.”); see also
Birmingham v. Bd. of Pub. Works, 249 Md. 443, 449 (1968) (“Nor have we the power to
correct an omission in the language of a statute, even although the omission was the
obvious result of inadvertence.”). We do not find, and we decline to add, language limiting
the requirements of Public Safety § 3-106(a)(1) only to matters involving a member of the
public.
Appellants argue that interpreting Public Safety § 3-106(a)(1) as we have will result
in a “significant expansion of police officer disciplinary rights” in that a trial board will be
mandated “for every single type of discipline a law enforcement officer might receive
during that law enforcement officer’s tenure[.]” That might be true but it does not alter the
fact that, when a statute is unambiguous, it is presumed that the General Assembly meant
what it said. Willis, 415 Md. at 536. Public Safety § 3-106(a)(1) clearly states that the trial
boards shall “adjudicate all matters for which a police officer is subject to discipline.”
Although the resulting responsibilities imposed upon law enforcement agencies may be
8 significant, it is not our role “to supply words [into a statute] to reach a desired result.”
Rosemann, 412 Md. at 327. If the alleged result was in error or simply an oversight, it may
be corrected by the General Assembly.
There being no dispute that Mr. Handler was “subject to discipline” for both letters
of reprimand, we hold, under the plain and unambiguous language of Public Safety § 3-
106(a)(1), that appellants’ denial of his request for trial board process was error. In absence
of any ambiguity in the statute, there is no need to look beyond the language of the statutory
text to interpret its meaning, but we will do so to confirm our conclusion. See In re Abhishek
I., 255 Md. App. 464, 475 (2022) (noting that, even where a statute is unambiguous, “we
may look to legislative history to confirm our conclusion regarding the intent of a statute”);
accord Blackstone v. Sharma, 461 Md. 87, 113 (2018) (concluding that, “[e]ven in
instances ‘when the language is unambiguous, it is useful to review legislative history of
the statute to confirm that interpretation and to eliminate another version of legislative
intent alleged to be latent in the language’” (quoting State v. Roshchin, 446 Md. 128, 140
(2016))).
III. Legislative History of the MPAA
Appellants contend that “[t]he language of § 3-106 of the [MPAA] is ambiguous
when considered with the [MPAA’s] purpose and the provisions of the former [Law
Enforcement Officer’s Bill of Rights.]” They urge our consideration of “the legislative
history and the implementing COMAR Regulations adopted in furtherance of the
[MPAA]” in interpreting the statutory language. Mr. Handler disagrees that Public Safety
§ 3-106(a)(1) is ambiguous, but nonetheless contends that legislative history, including a
9 2022 amendment to the MPAA, reflects an intention to “increase[] the applicability of the
trial board process to all internal and external matters that lead to discipline, rather than
limiting the applicability of that process[.]”
The Law Enforcement Officer’s Bill of Rights (“LEOBR”), the predecessor to the
MPAA, was enacted in 1974 “‘to guarantee that certain procedural safeguards be offered
to police officers during any investigation and subsequent hearing which could lead to
disciplinary action, demotion, or dismissal.’” Blondell v. Baltimore City Police Dep’t, 341
Md. 680, 691 (1996) (quoting Abbott v. Admin. Hearing Bd., 33 Md. App. 681, 682
(1976)); see also Manger v. Fraternal Ord. of Police, Montgomery Cnty. Lodge 35, Inc.,
239 Md. App. 282, 294 (2018) (“The broad purpose of the LEOBR is to provide law
enforcement officers with heightened procedural rights and protections when they are
under internal investigation.”).
As noted, the LEOBR was repealed when the MPAA became effective in 2022,
following police reform efforts after the death of George Floyd and others at the hands of
police. 2021 H.B. 670, Speaker Jones 2/9/21; see also 110 Md. Op. Atty. Gen. 3 at *17
(2025) (“The original impetus behind the General Assembly’s 2021 police reform efforts
was the murder of George Floyd and similar incidents where members of the public were
injured or killed by police officers.”). For that reason, House Bill 670, which primarily
focused on the relationship between law enforcement and the public, sought to bring
greater transparency and more accountability to policing in Maryland. 2021 H.B. 670,
Speaker Jones 2/9/21; 110 Md. Op. Atty. Gen. 3. Among other things, House Bill 670
created a police accountability board, defined police misconduct and called for the creation
10 of a trial board process and the Matrix. 2021 H.B. 670 at 28-40. In 2021, with the passage
of several bills, including House Bill 670, the MPAA was enacted. 2021 Md. Laws, ch. 59.
Before becoming effective in July of 2022, however, several provisions of §§ 3-101
to 3-113 of the Public Safety Article were revised by Senate Bill 763. 2022 Md. Laws, ch.
141; 2022 S.B. 763. Among Senate Bill 763’s stated purposes was to “specify[] that the
purpose of a certain trial board process is to adjudicate all internal and external matters for
which a police officer is subject to discipline[.]” 2022 S.B. 763 at 2 (emphasis added). To
that end, Senate Bill 763 added the word “all” before “matters for which a police officer is
subject to discipline” by Public Safety § 3-106(a)(1), 2022 S.B. 763 at 20 (emphasis
added), and revised Public Safety § 3-105(b) to clarify that the disciplinary matrix
contemplated would be “for all matters that may result in discipline of a police officer.” Id.
(emphasis added). Each of these amendments indicate the intent to broaden, not limit, the
reach of the MPAA, including the provision at issue before us.
In their reply brief, appellants contend that legislative history detailed in a 2025
Maryland Office of Attorney General opinion (“OAG opinion”) indicates that the MPAA
“is subject to more than one reasonable interpretation.” See 110 Md. Op. Atty. Gen. 3.
Appellants assert that:
[T]he OAG Opinion makes clear that “[t]he [MPAA] as a whole is concerned predominantly with misconduct involving members of the public,” id. at *16, the legislative intent focused on addressing incidents where “members of the public were injured or killed by police officers,’ id. at *17, and the enactment of the [MPAA] was motivated by the desire of the Maryland Legislature to “restore trust between the public and law enforcement” and “provide greater public oversight,[”] id. at *17. The OAG Opinion also clarified the legislative history and intent of the [MPAA] as stated by the Chair of Senate Judicial Proceedings Committee stating the process “from the PAB to the charging
11 committee, that’s for public [complaints],” id. at *14, and, as stated by counsel to the Speaker when “asked by a legislator whether the bill’s process was ‘just for public complaints,’ told a House subcommittee that it was, and that ‘the internal stuff to the police department, insubordination, showing up late, all of that stuff will still be handled internally,”’ id. at *17[.]
The legislative history appellants cite, however, relates to the former version of the MPAA.
See 110 Md. Op. Atty. Gen. 3 at *17 (“It thus appears that the Legislature understood that,
for the most part, the [MPAA] as enacted in 2021 did not address the process for handling
fully internal misconduct complaints.”). The OAG opinion went on to note that the purpose
of the enactment of the 2022 revisions was to “clarify the applicability of certain
provisions[,]” including that “[t]he disciplinary matrix applies to ‘all matters that may
result in discipline,’ regardless of whether a member of the public is involved.” 110 Md.
Op. Atty. Gen. 3 at *17-18.
Nor are we persuaded by appellants’ assertion that the applicable COMAR
provisions “reflect clearly the purpose of the [MPAA] as being for the purpose of
establishing an administrative process for handling allegations and complaints of police
misconduct involving a member of the public[.]” Although appellants are correct that
COMAR 12.04.09.01 provides that chapter nine of COMAR 12.04 “establishes a civilian
process to receive and process allegations of police officer misconduct involving a member
of the public,” COMAR 12.04.10 provides that the Matrix is “required for all matters that
may result in discipline of a police officer.” COMAR 12.04.10.01B. In other words, the
COMAR provisions, taken as a whole, do not reflect an intention to exclude non-public
matters from Public Safety § 3-106(a)(1)’s reach.
12 Finally, appellants, citing repealed LEOBR provisions, argue that “[i]f this Court
sides with [Mr. Handler’s] arguments presented in this appeal, it will result in an outcome
that interprets the [MPAA] as being even more pro-police officer rights than [the] LEOBR
was.” To support this argument, they assert that under the LEOBR, hearing boards were
provided only if there was “a recommendation of demotion, dismissal, transfer, loss of pay,
reassignment, or similar action that is considered punitive[,]” Public Safety § 3-107(a)(1)
(2018 Repl. Vol.) (repealed 2022) (cleaned up), or for minor infractions that may result in
“suspension of 3 days without pay or a fine of $150[,]” Public Safety§ 3-111(b)(2) (2018
Repl. Vol.) (repealed 2022) (cleaned up). Therefore, they argue that affirming the circuit
court’s decision would result in “a significant expansion” of the access to trial boards,
which, they contend, “was not the intention” of the General Assembly. We are not
persuaded. Indeed, such an expansion would not necessarily be inconsistent with an
intention to increase transparency in policing. See 2021 H.B. 670, Speaker Jones 2/9/21;
see also Public Safety § 3-106(e).
In sum, we hold Public Safety § 3-106(a)(1) is not ambiguous, and the legislative
history of the MPAA does not persuade us otherwise. Accordingly, we shall affirm the
circuit court.
JUDGMENT OF THE CIRCUIT COURT FOR FREDERICK COUNTY AFFIRMED. COSTS TO BE PAID BY APPELLANTS.