ANNAPOLIS, Md. — Maryland’s Appellate Court has ruled that records documenting police use of force in Ocean City are subject to public disclosure under the Maryland Public Information Act, marking a significant interpretation of the state’s police transparency law known as Anton’s Law.
In a decision filed April 3, 2026, the court found that use-of-force reports and internal review records created by the Ocean City Police Department are not protected as personnel records and must be made available to the public, with certain redactions.
The case stems from a lawsuit filed by The Washington Post after Ocean City denied requests for records related to police use-of-force incidents between 2016 and 2021, including several high-profile encounters on the Ocean City boardwalk.
At issue was whether “use of force” reports and internal reviews—known as UOF Reports and UOF Reviews—could be withheld under exemptions that protect personnel records.
The court determined that the reports themselves are largely factual and administrative, created as part of routine reporting requirements rather than for evaluating employee performance. Because of that, they do not qualify as personnel records and cannot be withheld on that basis.
“UOF Reports… are not exempt from disclosure as personnel records,” the court wrote, noting they are generated to meet statutory reporting requirements and contain objective data about police interactions with the public.
The ruling also addressed internal review documents, which Ocean City argued were not part of misconduct investigations and therefore exempt. The court rejected that argument, finding that the reviews function as internal investigations into officers’ conduct during use-of-force incidents.
Under Anton’s Law, enacted in 2021 as part of broader police reform efforts, records related to investigations of police misconduct are no longer automatically shielded from public disclosure.
The court emphasized that the law was intended to expand transparency and allow the public to examine how police departments review use-of-force incidents—even when those reviews do not result in discipline.
“The overarching goal of Anton’s Law… is to make records regarding investigations of police misconduct publicly available,” the opinion states.
However, the court stopped short of ordering full, unredacted release of all records. While it upheld the requirement to disclose use-of-force reports—including officers’ names—it ruled that internal review documents must first be examined for required redactions.
Those redactions may include personal contact information, medical details, and other sensitive material protected under the Public Information Act.
The case has been sent back to the Circuit Court for Worcester County to allow officials to review the records and apply any necessary redactions before release.
The decision affirms, in part, a lower court ruling that sided with The Washington Post in its effort to obtain the records, while clarifying that disclosure must still comply with privacy protections under state law.
Anton’s Law was passed following nationwide calls for police accountability and specifically reclassified many records related to police misconduct, shifting them from mandatory secrecy to a more transparent, case-by-case review process.
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