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RUDOLPH L. BELL JR. v. BALTIMORE CITY POLICE DEPARTMENT, ET AL.

TORTS -- FAILURE TO PROPERLY TRAIN OFFICES -- SOVEREIGN IMMUNITY -- Rudolph Bell Jr., appellant, brought suit, in the Circuit Court for Baltimore City, against the Baltimore City Police Department (“BCPD”) and “several unidentified” police officers who shot and killed his father, Rudolph Bell Sr. Bell Jr.’s complaint alleged that the BCPD was negligent in failing to properly train its officers in how to handle “mentally ill” suspects such as his father and that, in failing to so train its officers, the BCPD had also violated Article 24 of the Maryland Declaration of Rights. When the BCPD—the only defendant who was identified, with any specificity, by the complaint and subsequently served by Bell Jr.—moved to dismiss the complaint on the grounds of sovereign immunity, the Baltimore City circuit court granted that motion. This appeal from that dismissal followed.

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