CHARLES COUNTY, Md. — The Appellate Court of Maryland affirmed a permanent injunction on June 30, 2025, barring Charles County Commissioner Thomasina O. Coates from voting on matters related to County Administrator Mark Belton’s employment. The ruling stems from a 2020 investigation that found Coates had engaged in discriminatory conduct against Belton, prompting the Charles County Board of Commissioners to restrict her authority. The decision, detailed in Thomasina Coates v. Charles County Board of Commissioners, et al., No. 1623, September Term, 2023, upholds the circuit court’s order and addresses allegations of racial discrimination, governance disputes, and legal standing.
The controversy began in early 2020 when Belton, the county administrator, filed a personnel complaint with the county’s human resources director, alleging Coates sent hostile and abusive emails and made disparaging remarks about him to county employees, residents, and state officials. In response, Coates filed a complaint against Belton, alleging racial discrimination. The Board retained Bernadette Sargeant, a former counsel to the U.S. House of Representatives Ethics Committee, to investigate both complaints. Sargeant’s investigation, which included interviews with seven individuals and a review of 137 documents, concluded that Coates’ allegations against Belton were unsubstantiated. However, it found that Coates had engaged in discriminatory conduct toward Belton, creating a hostile work environment based on his race.
On June 9, 2020, during a closed session, the Board voted to adopt Prompt and Remedial Action (PRA), restricting Coates’ interactions with Belton. The PRA prohibited Coates from participating in decisions regarding Belton’s employment, performance evaluations, or contract negotiations. It also required her to communicate policy initiatives and staff requests through the Board president or vice president and to refrain from directly contacting Belton. Coates voted against the PRA. In open session, the Board amended its Rules of Procedure to establish a policy protecting county employees from discrimination, harassment, or bullying by commissioners, creating a complaint process and protocol for investigations.
The issue resurfaced on December 13, 2022, after the November 2022 election, which returned Commissioners Reuben B. Collins II, Gilbert O. Bowling, Amanda M. Stewart, and Coates to the Board, alongside newly elected Commissioner Ralph E. Patterson. During a closed meeting, Commissioners Collins, Patterson, and Coates attempted to discuss Belton’s employment, prompting objections from Stewart and Bowling, who cited the PRA’s restrictions. The meeting raised concerns about whether the PRA remained enforceable under the newly composed Board.
On December 30, 2022, Commissioners Stewart and Bowling filed a complaint in the Circuit Court for Charles County, seeking a temporary restraining order, permanent injunction, and declaratory judgment to enforce the PRA. Belton intervened as a plaintiff without objection. Coates filed a counterclaim, seeking a declaratory judgment that the Board had terminated Belton’s employment on December 13, 2022. On February 15, 2023, the circuit court issued a temporary restraining order enforcing the PRA. After discovery and hearings, the court granted a permanent injunction on October 17, 2023, prohibiting Coates and the Board from rescinding or modifying the PRA or the 2020 Rules amendment with a vote including Coates. The court dismissed Coates’ counterclaim and other counts of the plaintiffs’ complaint.
Coates appealed, raising six issues, which the Appellate Court consolidated into two: whether the circuit court erred in entering the permanent injunction and dismissing her counterclaim, and whether it abused its discretion in limiting discovery and evidentiary rulings. The Appellate Court affirmed the injunction, vacated the dismissal of Coates’ counterclaim, and remanded for entry of a declaratory judgment consistent with the circuit court’s findings.
The court found that the plaintiffs had standing under the Maryland Uniform Declaratory Judgment Act, which allows parties to seek resolution of disputes involving administrative rules if antagonistic claims indicate imminent litigation or a party’s legal rights are challenged. “The Commissioners brought an action for equitable relief against Commissioner Coates and the Board because they all were participants in this internal governance dispute,” the court stated, distinguishing the case from Provident Bank of Maryland v. DeChiaro Ltd. Partnership, where a third party lacked standing. The court also recognized common law standing, noting the Commissioners’ duty to protect the county from legal violations and maintain public confidence in governance.
Coates argued that the controversy was a non-justiciable political question, citing the Express Powers Act, which grants the Board authority to appoint and remove county officers. The court rejected this, citing Jones v. Anne Arundel County (2013), which held that such disputes are justiciable unless expressly committed to the county alone. “Neither LG § 10-303 nor § 12-107 states expressly that the county alone is charged with removing county officers,” the court noted, emphasizing that the authority resides with the Board as a whole, not individual commissioners.
The court upheld the PRA as a valid administrative action, rejecting Coates’ claim that it was legislative or ultra vires. “The Board adopted the PRA in response to a specific personnel problem involving allegedly illegal conduct,” the court stated, aligning it with the Board’s executive function under the Charles County Code. The PRA was deemed consistent with federal and state anti-discrimination laws, including Title VII of the Civil Rights Act of 1964 and the Maryland Fair Employment Practices Act (FEPA).
A key issue was whether Belton qualified as an “employee” under Title VII, which excludes high-level policy-making appointees. Coates argued Belton was a political appointee, not entitled to protection. The court applied the Eighth Circuit’s test from Reardon v. Herring (2016), focusing on whether the appointee operates at the policy-making level. The Charles County Code and testimony from Commissioners Stewart and Collins described Belton’s role as executive, managing daily operations without formulating public policy. “The Board has not entrusted the county administrator with the kind of high-level responsibilities that an appointee on the policymaking or cabinet level would possess,” the court concluded, affirming Belton’s status as an employee protected by Title VII.
Coates’ First Amendment challenge, claiming the PRA restricted her speech, was dismissed, as the court classified the PRA as an administrative action, not a legislative one subject to free speech protections. The court also rejected her claim that the PRA was a bill of attainder, noting it was not a legislative act inflicting punishment without judicial process.
The court found sufficient evidence to support the injunction, citing the risk of irreparable harm to Belton and the county if Coates were allowed to vote on his employment. “Allowing Commissioner Coates to cast the deciding vote to fire Mr. Belton would have placed the Board in dereliction of its own rules,” the court stated, highlighting potential legal liability and damage to public trust. The public interest favored the injunction to ensure compliance with anti-discrimination laws.
On evidentiary rulings, the court upheld the circuit court’s decision to limit discovery, quash subpoenas for Sargeant’s investigation records, and deny Coates’ motion to compel County Attorney Wesley Adams’ deposition. The circuit court focused on future enforcement of the PRA, deeming past investigation details irrelevant. “The forward-focused scope of the proceedings was consistent with the purpose of injunctions,” the court noted, citing El Bey v. State (2000). The court also found no waiver of attorney-client privilege, as the Board had not voted to waive it, and individual commissioners lacked authority to do so.
The Appellate Court vacated the dismissal of Coates’ counterclaim, remanding for a declaratory judgment that no valid vote occurred on December 13, 2022, due to the PRA’s restrictions. “The court should have entered a declaratory judgment embodying its conclusions,” the court stated, citing Broadwater v. State (1985).
The case underscores tensions in local governance, particularly when internal disputes intersect with legal obligations to prevent workplace discrimination. Charles County, with a population of approximately 166,000, operates under a code home rule system, governed by a five-member Board elected to four-year terms. The county administrator, appointed by the Board, oversees daily operations, managing departments and implementing Board policies. The PRA and injunction reflect the Board’s efforts to address alleged misconduct while navigating legal and ethical responsibilities.
The ruling has implications for county governance, reinforcing the Board’s authority to discipline its members administratively and protect employees from discrimination. It also highlights the judiciary’s role in resolving intra-governmental disputes without infringing on political questions. The court’s emphasis on Belton’s employee status under Title VII clarifies protections for county administrators, potentially influencing similar cases in Maryland.
Coates’ appeal arguments, including claims of insufficient evidence and procedural errors, were systematically addressed, with the court finding the circuit court’s rulings legally sound and evidence-based. The decision to limit discovery to future actions ensured the case remained focused on enforcing the PRA, avoiding re-litigation of the 2020 investigation.
The permanent injunction remains in effect, prohibiting Coates from participating in votes or actions related to Belton’s employment. The remanded declaratory judgment will formalize the court’s finding that no termination occurred in 2022, closing a procedural gap in the circuit court’s order. The ruling affirms the Board’s commitment to anti-discrimination policies and its authority to enforce internal rules, while underscoring the legal consequences of workplace misconduct allegations in public office.
