Supreme Court of Maryland

Walters Art Gallery v. Walters Workers Un.

July 29, 2025

Summary

The Supreme Court of Maryland held that the Trustees of the Walters Art Gallery is not a governmental unit or instrumentality subject to the Maryland Public Information Act. Applying a functional, multifactor analysis, the Court concluded that the Board’s private charitable origins, fiduciary purpose, self-perpetuating structure, operational independence, limited governmental funding, and lack of sovereign immunity outweighed the City’s ownership of some assets and other ties. The Court reversed the intermediate appellate judgment and remanded for entry of judgment in favor of the Board.