Appellate Court of Maryland Holds that the Three-Year Statute of Limitations for Claims Filed by Minors under the Maryland Tort Claims Act Begins When the Minor Turns Eighteen, Rather Than at the Time the Cause of Action Arose.
Cameron Cunningham v. State of Maryland, et al ., No. 0216, Sept. Term, 2025. Opinion Filed on July 2, 2026, by Wells, C.J. In the matter of Cameron Cunningham v. State of Maryland , Cunningham, a minor at the time, was arrested in October 2019 at his high school and injured his left knee during the arrest. He was transported to the hospital for treatment and was released into the Department of Juvenile Services’ (“DJS”) custody with specific instructions to seek follow-up care from his medical providers. However, Cunningham asserted that the State, through its agencies, failed to provide him with the necessary prescribed care while he was in DJS custody for over one (1) year. Cunningham turned eighteen (18) in November 2021. In November 2024, five (5) years after he was injured, but less than three (3) years after he turned eighteen (18), Cunningham filed suit against the State, DJS, and Department of Public Safety and Correc...
