Breck v. Maryland State Police

This case addresses the meaning of “secondary employment” as that phrase is used in the Law Enforcement Officers’ Bill of Rights (“LEOBR”), codified in Title 3, Subtitle 1 of the Public Safety Article of the Maryland Code. See Md. Code Ann., Pub. Safety § 3-101(b) (2003, 2011 Repl. Vol., 2016 Supp.). 1 Under § 3-103(b), Maryland law enforcement agencies may not prohibit law enforcement officers from working secondary employment. Resolution of the dispute in the present case turns on what sort of work comes within the meaning of “secondary employment.”

Petitioner in this case is Sheila Breck,…