Surratt v. Prince George's County

ADKINS, Judge.

In Prince George’s County v. Fitzhugh, 308 Md. 384, 519 A.2d 1285 (1987), we held that § 1013 of the Prince George’s County Charter constituted a full waiver of governmental immunity because a purported limitation of the scope of the immunity embodied in a 1982 charter amendment was not authorized by the Express Powers Act. We now hold that 1986 amendments to § 1013 were equally ineffective to abolish the waiver of immunity. We further hold that a plaintiff who accepts a remittitur may, nevertheless, cross-appeal if the defendant appeals. As a consequence of that holding, we…