Supreme Court of Maryland

Bd. of Education v. Sturm

June 23, 2026

Summary

The Court held that an order denying a State agency's claim of complete sovereign immunity is immediately appealable under the collateral order doctrine when the order presents a pure legal question and satisfies the doctrine's other requirements. On the merits, the Court held that county boards of education retain sovereign immunity for tort claims based on conduct occurring before July 1, 1971, because no effective funding mechanism exists for judgments on those claims. The Court reversed the dismissal of the appeal and directed dismissal of the complaint without prejudice.