Appellate decision means Maryland counties face uncapped liability in workplace discrimination and retaliation claims
Maryland’s top appeals court just ruled that local governments can’t cap damages in workplace discrimination cases—a decision with big implications for public sector HR.
On October 29, 2025, the Appellate Court of Maryland decided Joseph Watts v. Prince George’s County, Maryland, holding that the state’s Local Government Tort Claims Act does not limit how much a county must pay if found liable for discrimination or retaliation under state or local employment laws.
The case began when Joseph Watts, a former correctional officer, suffered a below-the-knee amputation due to complications from diabetes. After his doctor cleared him to return to work with a prosthetic leg, Watts was promoted to lieutenant, a position that involved mostly ministerial duties but still required him to conduct walk-throughs of jail cells.
According to the complaint, Watts was required to pass a physical agility test before being allowed to return to full duty. Watts alleged that this test was typically only given to new recruits and that he received less notice and preparation time than was standard for new recruits. He completed all eight events in the test, but was informed he failed and was not provided the results until six weeks later. Watts proposed reasonable accommodations, but the department did not accept them and continued to require he pass the physical agility test....
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