Manger v. Fraternal Order of Police

ROBERT A. ZARNOCH, J. (Retired, Specially Assigned).

The Law Enforcement Officers’ Bill of Rights (“LEOBR”), enacted in 1974 and presently codified at Maryland Code (2003, 2011 RepLVol.), §§ 3-101 through -113 of the Public Safety Article (“P.S.”), provides procedural protections for law enforcement officers under internal investigation. At issue in this appeal is the requirement that a police department keep a “complete record” of any interrogation of a police officer facing potential disciplinary proceedings. See P.S. § 3-104(k).

In late 2014, appellant, the Montgomery County Police…