Two weeks ago in Esteppe v. Balt. City Police Dept., (No. 47, Sept. Term 2020) (Sept. 1, 2021) the Maryland Court of Appeals held that a police department was not responsible for a judgment against a corrupt police detective simply because his unlawful arrest was done for personal reasons and, thus, outside the scope of his employment.
Summary of Esteppe v. Baltimore City Police
David Esteppe, a resident of Baltimore City, was going through a bad breakup back in 2012. In an effort to get back at Mr. Esteppe, his jilted ex-girlfriend enlisted the help of her childhood friend Adam Lewellen who was a Baltimore City Police Detective. To appease the ex-girlfriend, Detective Lewellen committed perjury to obtain a bogus warrant to search Mr. Esteppe’s house and pursued a false criminal prosecution of Mr. Esteppe.