Ellsworth v. Baltimore Police Department

In this case we are called upon to interpret the Law Enforcement Officers’ Bill of Rights (“LEOBR”),1 which is triggered when a “law enforcement officer”2 is under investigation or subject to interrogation for a reason that may result in “a recommendation of demotion, dismissal, transfer, loss of pay, reassignment, or similar action that is considered punitive”. Section 3-107(a). Under Section 3-104(n)(ii) of the LEOBR, a law enforcement officer must be provided with “any exculpatory information” upon completion of an investigation, at least ten days before a hearing, upon certain conditions…