Haupt v. State

BELL, Judge.

Once again we are required to construe the restrictions on actions provision, § 12-106 of the Maryland Tort Claims Act (“MTCA”), Maryland Code (1984, 1993 Repl.Vol.), § 12-101 et seq. of the State Government Article.1 On this occasion, we address an issue left open by Leppo v. State Highway Administration, 330 Md. 416, 431, 624 A.2d 539, 546 (1993), the most recent case to construe § 12-106: When does the 180-day clock begin to run in the case of third-party claims?

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Sandra Lee Haupt, the appellant, was involved in an automobile accident with Margaret Lynn Keehan, the plaintiff,…