HARRELL, J.

The parties here challenge us to interpret the pre-suit notice requirement of the 2007 iteration of the Local Government Tort Claims Act ("LGTCA"). Petitioner, Jerry Hansen ("Hansen"),1 asserts that he complied, strictly or at least substantially, with the required notice provision of the LGTCA as regards Prince George's County (notice of a claim must be served on the county solicitor or attorney) by delivering written notice of his claims against the City of Laurel ("City") to the City Administrator. Respondent, the City, contests vigorously his assertions. Although the focus of the parties' arguments before this Court are aimed at whether Hansen's efforts were compliant at all with the LGTCA, the City argued in the trial court and the Court of Special Appeals also that Hansen did not plead expressly in his complaint satisfaction of the LGTCA notice provision. Such failure, the City averred, should prevent Hansen from pursuing his claim. We agree with the City's latter contention and, accordingly, do not decide whether Hansen's conduct complied with the applicable notice provision (although we shall comment in dicta, where appropriate, about some aspects of that dispute). As a result, we affirm the Court of Special Appeals's judgment, which affirmed the dismissal of Hansen's suit by the Circuit Court for Prince George's County.

I.

We shall provide the relevant procedural facts, as well as some substantive background, for contextual purposes. No finder of fact has evaluated the credibility of any factual allegation because this case was disposed of ostensibly by the trial court through its grant of the City's motion to dismiss. Thus, we—like the Court of Special Appeals—derive the "facts" related here from Hansen's complaint (and, as it turns out, other pleadings and papers filed in the Circuit Court).

Hansen served as the City's "Chief Building Official" for seventeen years before his employment ended, against his will, in 2007. In the Spring of 2006, he experienced a heart attack, after which he assumed disabled status and did not seek to return to work with the City for a while. As the Court of Special Appeals recounted in its reported opinion in this case:

Hansen v. City of Laurel, 193 Md.App. 80, 85-86, 996 A.2d 882, 885-86 (2010).

The three documents attached to Hansen's opposition to the City's motion to dismiss expressed his intent to file claims with "local and federal administrative agencies," to wit, the Prince George's County Human Rights Commission and the U.S. Equal Employment Opportunity Commission. The documents did not reflect expressly an intent to file a complaint or claim in the Circuit Court for Prince George's County or any other court. Hansen's proffered pre-suit notice to the City Administrator made no reference, explicitly or otherwise, to the LGTCA. On 10 March 2009:

Hansen, 193 Md.App. at 86-87, 996 A.2d at 886.

In deciding Hansen's appeal of the Circuit Court's dismissal of his suit, the intermediate appellate court acknowledged in its opinion the City's contention that Hansen's complaint failed to plead satisfaction of the notice provision of the LGTCA, but grounded its analysis instead on whether Hansen's sending of notice to the City Administrator complied strictly or substantially with the notice requirement of the LGTCA prevailing at the relevant time of occurrence of Hansen's operative facts.4 See Hansen, 193 Md.App. at 89, 996 A.2d at 888 ("The only controversy for purposes of our discussion concerns whether the City Administrator was the proper recipient of notice under the LGTCA. . . ."). It concluded that Hansen did not comply strictly with the LGTCA because he delivered his notice to the City Administrator, not to the County Attorney of Prince George's County, as specified in § 5-304(c)(2) of the version of the statute in effect at the time of accrual of Hansen's claims. See Hansen, 193 Md.App. at 92-93, 996 A.2d at 890. Assuming, without deciding, that Hansen, in the alternative, in 2007 could have sent notice to the "corporate authorities of [the] defendant local government," § 5-304(c)(1), the Court of Special Appeals held that notice should have been provided to the Mayor or City Council, not the City Administrator. See Hansen, 193 Md.App. at 93, 996 A.2d at 890.

With respect to whether substantial compliance with the LGTCA requirement occurred, the Court of Special Appeals deduced that Hansen found no refuge there either, as he "notified the City Administrator," a "position that is not charged with investigating tort claims against the City." Hansen, 193 Md.App. at 96, 996 A.2d at 892; Hansen, 193 Md.App. at 95, 996 A.2d at 891 ("`[T]he tort claimant has substantially complied with the notice provisions of the LGTCA'" where he or she "`provides the local government, through the unit or division with the responsibility for investigating tort claims against that local government, or the company with whom the local government or unit has contracted for that function, the information required by § 5-304[ ] . . ., who thus acquires actual knowledge within the statutory period . . . .'" (quoting Faulk v. Ewing, 371 Md. 284, 302, 808 A.2d 1262, 1274 (2002) (citation omitted))).

Hansen petitioned us for a writ of certiorari, which we issued, Hansen v. Laurel, 415 Md. 607, 4 A.3d 512 (2010), to consider potentially whether "the lower court erred as a matter of law in holding a city administrator is not a proper recipient or `corporate authority of the defendant local government' pursuant to CJ [§] 5-304(c)(4)?" After examining the record, we conclude that addressing the precise question pressed by the parties upon us would be injudicious on the particular circumstances of this case, given the omission in Hansen's complaint that he pleaded fulfillment of the notice requirement under the LGTCA.5 We explain.6

II.

We choose to address first (and ultimately only) the City's contention, preserved at each previous level of this litigation, that Hansen was required to plead affirmatively in his complaint satisfaction of the notice obligation of the LGTCA. Although the LGTCA notice provision may not be jurisdictional, as explained in footnote 5 supra, failure to plead satisfaction, if required, carries consequences nonetheless.

A. Satisfaction of the LGTCA Notice Provision is a Condition Precedent to Maintaining Suit Against a Local Government.

It is a longstanding principle of Maryland jurisprudence that the LGTCA notice provision is a condition precedent to maintaining an action directly against a local government7 or its employees. See Rios v. Montgomery County, 386 Md. 104, 127, 872 A.2d 1, 14 (2005) (reaffirming that "the LGTCA notice requirements are a condition precedent to maintaining an action against a local government or its employees") (citations omitted); Faulk, 371 Md. at 304, 808 A.2d at 1275 ("[N]otice requirements of th[e] type [contained in the LGTCA] have been viewed as conditions precedent to maintaining subsequent legal actions." (citations omitted)); Grubbs v. Prince George's County, 267 Md. 318, 320-21, 297 A.2d 754, 755 (1972) (interpreting the notice provision of the LGTCA predecessor statute, Md.Code (1957, 1972 Repl.Vol.) Art. 57, § 18,8 "as a condition precedent to the right to maintain an action for damages") (citations omitted); Neuenschwander v. Washington Suburban Sanitary Comm'n, 187 Md. 67, 77, 48 A.2d 593, 599 (1946) (stating that the notice provision of "the Act of 1943,"9 another ancestor of the current LGTCA, is "a condition precedent to the right to maintain the suit") (citation omitted), overruled on other grounds by statute as stated in Arnold v. Prince George's County, 270 Md. 285, 311 A.2d 223 (1973); Madore v. Balt. County, 34 Md.App. 340, 345, 367 A.2d 54, 56 (1976) (construing the notice provision of Art. 57, § 18 as "a condition precedent to the right to maintain the suit") (citation omitted); Renn v. Bd. of Comm'rs, 352 F.Supp.2d 599, 602 (D.Md.2005) ("Maryland courts have consistently held that the LGTCA[ ] notice requirement is a condition precedent to the right to maintain an action for damages." (citation omitted)); Lyles v. Montgomery County, 162 F.Supp.2d 402, 404 (D.Md.2001) ("The [LGTCA] notice is a condition precedent to the right to maintain an action for damages. . . ." (citations omitted)); 5-71 ANTIEAU ON LOCAL GOVERNMENT LAW § 71.08 (2d ed. 2009) ("Since legislatures can withhold the opportunity to sue local governments, they can impose whatever conditions precedent to suit they deem proper. Conditions precedent to suit against local governments are found in nearly all State statutes and local charters." (footnote omitted)).

B. A Plaintiff Must Plead Satisfaction of the Condition Precedent That Is the LGTCA Notice Requirement.

Ordinarily, a plaintiff must plead affirmatively satisfaction of a condition precedent. See Maryland Rule 2-303(b) ("A pleading shall contain . . . such statements of fact as may be necessary to show the pleader's entitlement to relief or ground of defense."); Rule 2-304(b) ("In pleading the performance or occurrence of conditions precedent, it is sufficient to aver generally that all conditions precedent have been performed or have occurred." (emphasis added)); Cannon v. McKen, 296 Md. 27, 38, 459 A.2d 196, 202 (1983) ("It is a basic rule of law that where a cause of action is dependent upon a condition precedent, plaintiff must allege performance of such condition or show legal justification for nonperformance."); Jewell v. Malamet, 322 Md. 262, 272, 587 A.2d 474, 479 (1991) (same).

At the very least, our precedent seems to require that tort claimants plead affirmatively, albeit generally, this particular condition precedent, i.e., the LGTCA notice requirement. In construing the notice provision in the comparable Act of 1943, see footnote 9 supra, the Neuenschwander Court explained that:

187 Md. at 76-77, 48 A.2d at 599 (emphasis added) (citations omitted).

In other cases, this Court, the Court of Special Appeals, and the U.S. District Court for the District of Maryland have reiterated the same canon. See Cotham v. Bd. of County Comm'rs, 260 Md. 556, 562-64, 273 A.2d 115, 119 (1971) (explaining the state of Maryland local government tort law by quoting favorably the above passage of Neuenschwander, 187 Md. at 76-77, 48 A.2d at 599); Engle v. Cumberland, 180 Md. 465, 469, 25 A.2d 446, 448 (1942) (interpreting the notice provision in the Act of 192210—which concerned also the right to sue local governments—and ruling that "the failure to make such allegations [of notice being given] can be raised either by demurrer or plea") (citations omitted); Madore, 34 Md.App. at 342, 367 A.2d at 56 (1976) (interpreting the notice provision in Art. 57, § 18 and concluding that "compliance with the notice statute should be alleged in the declaration as a substantive element of the cause of action") (citations omitted); Hargrove v. Mayor of Baltimore, 146 Md.App. 457, 462-63, 807 A.2d 149, 152 (2002) ("`[T]ypically, a plaintiff must notify the municipality to be sued, and indeed plead notification in the complaint, in compliance with § 5-404'"11 of the LGTCA) (quoting favorably Downey v. Collins, 866 F.Supp. 887, 889 (D.Md.1994)); Renn, 352 F.Supp.2d at 602 ("[C]ompliance with the [LGTCA] notice provision should be alleged in the complaint as a substantive element of the cause of action." (citation omitted)); Curtis v. Pracht, 202 F.Supp.2d 406, 414 (D.Md.2002) (same); Lyles, 162 F.Supp.2d at 404 (same); Bibum v. Prince George's County, 85 F.Supp.2d 557, 564 (D.Md.2000) (same); MARYLAND RULES COMMENTARY at 300 ("Certain causes of action require that conditions precedent to entitlement to relief be pleaded as an element of the cause of action. . . . Statutory provisions may also create conditions precedent.").

Other jurisdictions have considered whether "a plaintiff's pleading need . . . show compliance with applicable statutory. . . provisions requiring the filing of notice with . . . a municipality prior to instituting a suit" for certain tort actions. V. Woerner, Necessity and Sufficiency of Plaintiff's Pleading of Having Given Requisite Notice or Presented Claim to Municipality or Other Public Body, 83 A.L.R.2d 1178, 1 (1965). "Most . . . subscribe to the view that the plaintiff's pleading must allege compliance with such applicable provisions, on the theory that the requirement for notice or claim is a condition precedent to the plaintiff's right of action. . . ." Id.; see ANTIEAU ON LOCAL GOVERNMENT LAW § 39.01 (2d ed. 2009) ("Plaintiffs must ordinarily plead compliance with statutory notice provisions governing tort claims against local government defendants." (footnote omitted)). But see id. ("[U]nder a number of statutes, the failure of a plaintiff to give notice to a local government is a matter of defense that must be pleaded by the local government." (footnote omitted)); ANTIEAU ON LOCAL GOVERNMENT LAW at § 71.08 ("Courts differ on whether the plaintiff must plead compliance with conditions precedent or the defendant local government must plead noncompliance."). Maryland rules and decisions reach somewhat of a compromise—plaintiffs must allege the performance of conditions precedent, but they may do so generally. See Rule 2-304(b). It is up to defendants, then, to show that "a particular condition precedent has in fact [not] been satisfied. . . ." MARYLAND RULES COMMENTARY at 300.

C. But Is the LGTCA Notice Provision Actually a Condition Precedent?

Some may argue, despite the longstanding nature of the principle, that the LGTCA notice provision is not a condition precedent actually. We derive our understanding of what constitutes a "condition precedent" from the Supreme Court, which, in 1886, was confronted by statutes that created new causes of action. These statutes also imposed time limitations. The Supreme Court said that:

The Harrisburg, 119 U.S. 199, 214, 7 S.Ct. 140, 147, 30 L.Ed. 358, 362 (1886) (emphasis added).12 In the present case, one may observe (as footnotes 5 and 7 make clear) that the LGTCA does not create any new causes of action, or "rights." Rather, it merely shapes how previously-available causes of action may proceed. Thus, a "condition precedent" analysis is inconsonant, or so the argument goes.

It has been surmised that, by enacting the LGTCA, the Legislature responded, at least in part, to the perceived threat that tort suits "discourage" local government employees from "vigorous[ly] proseucti[ng]. . . their duties." Pavelka v. Carter, 996 F.2d 645, 650 (4th Cir.1993). To affect that end, the Legislature could have "simply extend[ed] governmental immunity to those [local government-employee] tortfeasors," albeit "at the expense of tort victims," who would then have no recourse for their injuries. Id.; see also MARK M. VIANI, MARYLAND LOCAL GOVERNMENT LAW AND STRUCTURE 1-A (1999) ("[I]n practice, every incorporated municipality remains subject to the absolute control of the General Assembly."). In other words, the Legislature could have tweaked simply employees' tort liability exposure. Instead, "it simply shifted the cost of employee negligence[, i.e., tort damages exposure,]. . . to a party better able to pay, their local government employer. . . ." Pavelka, 996 F.2d at 650 (emphasis added). As a tradeoff for this shifting, the Legislature altered the terms under which a plaintiff could bring already-available causes of action, so as to give local governments fair notice of tort suits, for which they would be responsible financially. See CJ § 5-304(b)(1) ("[A]n action for unliquidated damages may not be brought against a local government or its employees unless the notice of the claim required by this section is given within 180 days after the injury."); Martino v. Bell, 40 F.Supp.2d 719, 722 (D.Md.1999) ("In conjunction with shifting some financial responsibility to local governments, the LGTCA requires a potential plaintiff to give the government notice of his claim within 180 days of the injury as a prerequisite to filing suit against a local government or one of its employees." (citation omitted)); Ashton v. Brown, 339 Md. 70, 104, 660 A.2d 447, 464 (1995) ("[T]he General Assembly has recently enacted the [LGTCA], which shifts financial liability for wrongs committed by local government officials, acting in the scope of their employment and without malice, from the public officials to the local government entity itself." (citation omitted)); Karen J. Kruger, Governmental Immunity in Maryland: A Practitioner's Guide to Making and Defending Tort Claims, 36 U. BALT. L.REV. 37, 63 (2006) ("The LGTCA does not waive the governmental immunity of the local government; thus, the LGTCA does not create liability on the part of the local government, but does create financial responsibility for the government for the non-malicious acts of its employees." (footnotes omitted)).

With respect to tort claimants (as opposed to tortfeasor-employees), the General Assembly was shifting financial obligations, rather than changing substantive rights. The Legislature left intact all common law and statutory causes of action. At the same time, it clarified what procedural requirements tort claimants must satisfy in order to maintain suit. See ANTIEAU ON LOCAL GOVERNMENT LAW at § 71.08 ("Where a right against a local government has been created by the legislature, it may be circumscribed by procedural requirements in any way the legislative body sees fit."). The fact that the statutes creating some substantive rights—see footnote 7 supra; Williams v. Maynard, 359 Md. 379, 754 A.2d 379 (2000) (interpreting Md.Code (1974, 2009 Repl.Vol.), Transportation Art., § 17-107 and CJ § 5-524)— and the procedural requirements are different is, in our view, inapposite. The way in which a plaintiff may bring a claim is connected fundamentally to the type of claims that a plaintiff may bring, such that whatever restrictions the General Assembly imposes should be deemed "conditions precedent."

III.

We are aware, if not understanding, that pleading satisfaction of the LGTCA notice obligation may not be evident immediately to a potential tort claimant. In the case sub judice, however, the City advised Hansen of the pleading shortcoming through its motion to dismiss. Hansen did not amend his complaint, however, which he could have accomplished without leave of the trial court, pursuant to Rule 2-341(a). Nor did he dismiss voluntarily and refile his complaint. See Rule 2-506(a). After the trial court granted the motion to dismiss/motion for summary judgment, Hansen also did not seek leave of the trial court to file an amended complaint. See Rule 2-322(c) ("If the court orders dismissal, an amended complaint may be filed only if the court expressly grants leave to amend."). He likewise did not file a motion to alter or amend the trial court's judgment. See Rule 2-534 ("In an action decided by the court, on motion of any party filed within ten days after entry of judgment, the court . . . may amend its findings . . ., may enter new findings or new reasons, may amend the judgment, or may enter a new judgment.").

Rather, confronting more frontally the tendered grounds of the motion, Hansen tendered documents, which he proclaimed as "indisputable evidence that ample notification of pending tort claims was received by the City of Laurel within 180 days of the injury and the objective of the [LGTCA] was realized." Assuming, without deciding, that appending such documents in this manner and at that point in a case may compensate for a plaintiff's failure to plead satisfaction of the LGTCA notice provision, the City would prevail nonetheless. Hansen attached the documents and referred to them in his response to the City's motion to dismiss, but not in his complaint. See 83 A.L.R.2d 1178, at 6 ("[C]ourts have rarely discussed. . . the propriety of incorporating the notice or claim in the complaint either by reciting or quoting its contents or by attaching a copy as an exhibit to the complaint and incorporating it by reference. . . ." (emphasis added)). Hansen's documents also expressed a singular intent to file administrative claims with government agencies, as opposed to "an action for unliquidated damages" in a circuit court.13 CJ § 5-304(b)(1); Rule 1-202 ("`Action' means collectively all the steps by which a party seeks to enforce any right in a court. . . ." (emphasis added)). While less relevant were we to engage in a substantial compliance analysis, this fact impacts our analysis of whether Hansen plead satisfaction of certain statutory conditions precedent, i.e., the LGTCA notice requirement.14 See Moore v. Norouzi, 371 Md. 154, 807 A.2d 632 (2002) (finding substantial compliance where the plaintiffs expressed little intent to sue, but provided information regarding the incident to the party responsible for investigation tort claims on behalf of the local government). But see Chappelle v. McCarter, 162 Md.App. 163, 171-72, 873 A.2d 458, 462 (2005) (discerning a lack of substantial compliance, in part, because plaintiff's workers' compensation claim did not constitute seemingly "notice of a claim for unliquidated damages, . . . [as] required by CJ § 5-304(a)").

In sum, then, the LGTCA creates a procedural obligation that a plaintiff must meet in filing a tort action. A plaintiff must not only satisfy the notice requirement strictly or substantially, but also plead such satisfaction in his/ her complaint. If a plaintiff omits this step, he or she is subject to a motion to dismiss, for instance, based on a failure to state a claim upon which relief can be granted. See § 2-322(b). That is the case here essentially. Although Hansen draws our attention to some concerning and worthwhile issues, sounding in discrimination and ethics, he did not abide the procedural requirements of the LGTCA that would allow the asserted merits of his complaint to reach the eyes and ears of a fact finder.15,16

JUDGMENT OF THE COURT OF SPECIAL APPEALS AFFIRMED; COSTS TO BE PAID BY PETITIONER.

ADKINS, J., Dissents.

ADKINS, J., dissenting.

I respectfully dissent from the majority opinion, which throws a plaintiff out of court, permanently, for failure to allege in his complaint that "all conditions precedent have been performed." See Md. Rule 2-304(b). It does so without allowing him leave to amend his complaint, even though he made good-faith attempts to comply with the notice requirement and alleges in a responsive pleading that he has complied with the condition precedent at issue. This result, I fear, is another step towards a "gotcha jurisprudence" which makes unreasonable demands of "lawyers in the trenches." See Smith v. Kent County Comm'rs, 418 Md. 692, 742, 18 A.3d 16, 40 (2011) (Adkins, J., dissenting).

I.

The majority avoids consideration of whether Hansen substantially complied with the notice requirement of the LGTCA by sending his letter to the City Administrator and Deputy City Administrator within the 180 daywindow,1 preferring instead to impose a strict pleading requirement regarding that notice, and rejecting Hansen's efforts to bring his pleading into compliance by proving his delivery of notice. See Maj. Op. at 678, 683-85, 25 A.3d at 127, 130-31.

To be sure, Hansen, in his complaint, failed to include an allegation that he gave the City notice within 180 days. But, as soon as the City filed its Motion to Dismiss, Hansen filed "Plaintiff's Opposition to Defendant's Motion To Dismiss." In his Opposition, Hansen alleged that "[o]n March 12, 2007, [he], through his counsel, delivered by hand to the Office of the City Administrator a comprehensive letter, detailing the types of claims pending against the City, the factual basis for the claims, and an offer to resolve this matter privately." Hansen also asserted that the Prince George's County Human Relations Commission sent to the City Administrator a "Notice of Charge of Discrimination," along with a copy of his filing with the Commission. Attached to Hansen's Opposition motion was a copy of his detailed letter setting forth the alleged discrimination, and his injury, which, he alleges, was timely hand-delivered to Ms. Mills. With this Opposition, Hansen clearly alleged, although not in his complaint, that within 180 days of his termination, he had given the City Administrator notice of his claim.2

The majority cites various cases to support its holding that where there are conditions precedent to a cause of action, the plaintiff must allege his fulfillment of those in his complaint. I do not contest this pleading requirement. But what the majority ignores is that in the vast majority of cases addressing this issue, the plaintiff is given leave to amend his complaint to include such allegation, either at the trial or appellate level. The first case cited by the majority, Cannon v. McKen, 296 Md. 27, 37-38, 459 A.2d 196, 202 (1983), when this Court held the complaint was properly dismissed for failure to allege compliance with a condition precedent, it directed that the case be remanded to allow the defendant to amend her pleadings. See Cannon, 296 Md. at 38, 459 A.2d at 202 ("Accordingly, we shall remand this case to the Circuit Court for Prince George's County under Rule 871 for further proceedings as necessary to allow the plaintiffs to plead facts which show whether or not their claim falls within the Act."). In the second case cited, a medical malpractice action, we remanded the action to the Health Claims Arbitration Office, but "[i]n all fairness, the tort case in the circuit court must be kept alive pending the outcome of the arbitration proceedings to prevent the running of limitations." Jewell v. Malamet, 322 Md. 262, 276, 587 A.2d 474, 481 (1991). No similar fairness consideration was given to the plaintiff, Hansen, although in his brief to this Court he requested leave to amend his complaint.

The Majority only cites two cases in which this Court dismissed a suit without granting leave to amend. See Neuenschwander v. Washington Suburban Sanitary Comm., 187 Md. 67, 48 A.2d 593 (1946); Engle v. Cumberland, 180 Md. 465, 25 A.2d 446, (1942). Both of these cases, however, are from the 1940s, and do not even address the issue of whether a party should be entitled to leave to amend.

Indeed, as we said in Hall v. Barlow, Corp., 255 Md. 28, 255 A.2d 873 (1969), and often since, the modern trend is to freely allow amendments in the interests of justice:

Hall, 255 Md. at 39-42, 255 A.2d at 878-79.

We have continued to adhere to Hall's preference for granting leave to amend. See, e.g., RRC Northeast, LLC v. BAA Md., Inc., 413 Md. 638, 674, 994 A.2d 430, 451-52 (2010) (Harrell, J., for the Court) (citing Hall for the proposition that "it is the rare situation in which a court should not grant leave to amend[.]"). The policy goal behind our liberal amendment policy is to have cases decided on the merits. See Crowe v. Houseworth, 272 Md. 481, 485, 325 A.2d 592, 595 (1974) ("We have said that amendments should be freely allowed in order to promote justice, . . . so that cases will be tried on their merits rather than upon the niceties of pleading[.]"). See also McMahon v. Piazze, 162 Md.App. 588, 599, 875 A.2d 807, 813 (2005) ("The general rule is that amendment should be allowed liberally.").

On this same point, the Seventh Circuit has explained the federal policy against dismissal with prejudice on a failure to meet a technical pleading requirement:

Redfield v. Continental Casualty Corp., 818 F.2d 596, 609-610 (7th Cir.1987)

Certainly, the rules of procedure must be followed. But, we are here to administer justice, and doing so requires temperate, not harsh, administration of rules. Regardless of the merits of this one case, we should demonstrate in our decision-making that we maintain a high decree of appreciation for the fact that rules of procedure are a mechanism for achieving fair results across the board, but that they are only a mechanism, not traps for good faith pleaders. We are not here to fix lawyer's mistakes, but by the same token, I firmly believe that when a party or his lawyer has made a timely, good faith effort to respond to a motion to dismiss by making additional written allegations that address the deficiency that is highlighted by the motion, dismissal without leave to amend is not the just result.

The majority even goes so far as to suggest that had Hansen included in his complaint an allegation that he mailed the letter, describing its contents, it would be deficient because he said he was filing his claim of discrimination with the appropriate administrative agencies, not that he was filing suit. In its words, "The three documents attached to Hansen's opposition to the City's motion to dismiss expressed his intent to file claims with `local and federal administrative agencies,' to wit, the Prince George's County Human Rights Commission and the U.S. Equal Employment Opportunity Commission. The documents did not reflect expressly an intent to file a complaint or claim in the Circuit Court for Prince George's County or any other court." Maj. Op. at 675, 25 A.3d at 125. The purpose of the notice requirement of the LGTCA is simply to enable the local government to perform a timely investigation and plan for contingent financial liabilities. It is pretty obvious that when a person hand-delivers a notice of his intent to file a discrimination claim against a city with the appropriate agencies, when exhaustion of administrative remedies is required, that ultimately, a suit against the city will follow. The majority's taking Hansen to task in this manner simply reinforces an impression that we are hostile to claimants, or that we sit here searching for imperfections that may trip up a litigant. Given the complexities of modern law and procedure, even for litigants who are represented, it is not so easy to get every technical point exactly right the first time. In pursuing such a "zero tolerance" standard, I submit that we make the practice of law, and litigation a hazardous occupation, and encourage lawyers to focus on how they may trip up their opponents on a procedural mistake rather than resolve the substance of the dispute. This trend not only warps the administration of justice, but contributes to the lack of civility and professionalism that we frequently lament. I submit that a more tolerant view is called for.

II.

If Hansen were permitted to amend, the issue then will be: whether serving the City Administrator constitutes substantial compliance within the requirement of Md. Code, Courts & Judicial Proceedings Article ("CJ") § 5-301 that the City must be given notice within 180 days after the injury.

Although the majority chooses not to decide this issue, it takes the privilege of offering strong dictum on several of the issues subsidiary to this question. For example, the majority sets forth its views, as dictum, on how Hansen should have provided notice under the LGTCA. Maj. Op. at 674, 25 A.3d at 124 n. 3. It pronounces: "According to the plain words of the statute, a plaintiff whose cause of action was `[i]n Prince George's County' should provide notice to `the county solicitor or county attorney.'" Id.

Subpart (c) of Section 5-304 provides that `[e]xcept in . . . Prince George's County, the notice shall be given . . . to the county commissioner, county council, or corporate authorities of a defendant local government[.]" (emphasis added). It goes on to say that "in . . . Prince George's County, the notice shall be given in person or by certified mail . . . to the county solicitor or county attorney." Although it is clear that a litigant suing Prince George's County should not serve the relevant "corporate authorities," but instead serve the "county attorney," it is not as clear whether that exception to the LGTCA's general rule applies for all municipalities within Prince George's County, including the defendant municipality of Laurel in this case. It is just as likely that the General Assembly intended that with respect to a municipality, the notice be sent to the "corporate authorities" of that municipality rather than to the county attorney. Often towns or cities within counties do not have unified governmental functions, and sometimes a municipal government is at odds with the local county government. A better interpretation of this statute is that it was specific in identifying the recipient for the county governments, but general as to the municipalities, lumping the latter together and calling for notice to the "corporate authorities." At the very least, Section 5-304(c) is ambiguous, not "plain" as the majority declares.

So, the issue before us is whether notice to the City Administrator constitutes notice to the "corporate authorities." Without a known common usage of the term or any statutory definition, and considering that this Court has declined to define that term,3 we should not hold that Hansen's delivery of notice to the Town Administrator is deficient as a matter of law. This is especially so given past instances when, based on the factual circumstances of the plaintiff's attempts at notice, we have held that the plaintiff had "substantially complied" with the LGTCA's notice provisions. See, e.g., Faulk v. Ewing, 371 Md. 284, 308, 808 A.2d 1262, 1278 (2002) (holding there was "substantial compliance" when claimant against local municipality sent a notice to the municipality's insurer providing notice, because it "satisfied the underlying purpose of the notice statute."); Moore v. Norouzi, 371 Md. 154, 807 A.2d 632 (2002) (plaintiffs effected "substantial compliance" with LGTCA by sending notice to the defendant county's third-party claims administrator).

A claimant should not have to guess the mystery incantation that will unlock the gates to LGTCA compliance. At the very least, Hansen should have the right to conduct discovery into what happened to the letter after receipt by the Town Administrator.

For the above stated reasons, I dissent.