dissenting.
The majority opinion, Chief Judge Bell’s dissenting opinion, the courts below, and the parties, all treat this case as an appropriate common law breach of contract action which was timely filed. The majority takes the position that this “breach of contract” action is controlled by the so-called business *112judgment rule, i.e., “the strong judicial policy against interfering with the business judgment of private business entities.” Opinion at 76, 862 A.2d at 945, emphasis added. This action, however, does not involve the business judgment of a private entity. The defendant Towson University is a state government entity. Conte’s employment contract was a public contract with an agency of the State of Maryland.
The difference between private employment contracts and public employment contracts, terminable only for cause, has substantial ramifications. •
First, if it were appropriate to treat this lawsuit as a common law breach of contract action, I believe that the lawsuit would be untimely under the one-year limitations period for breach of contract actions against state government agencies set forth in Maryland Code (1984, 1999 Repl.Vol.), § 12-202 of the State Government Article. Therefore, the suit would be barred by governmental immunity.
Second, I believe that it would be more appropriate to treat this action as a Maryland common law action for judicial review of a state government adjudicatory administrative proceeding, and to remand the matter to the agency for proper findings of fact and conclusions of law.
Finally, regardless of whether Conte is entitled to an administrative hearing with findings of fact and conclusions of law, or to a judicial breach of contract action, the “business judgment” rule applied by the majority has no application to a governmental employment relationship terminable only for cause. Under due process principles applicable to the state government, an employee in Conte’s position is entitled to present his defenses and obtain a de novo determination either in an administrative hearing which complies with Maryland law or in court.
I.
If the majority, Chief Judge Bell, the courts below, and the parties were correct in treating this case as a common law breach of contract action, it was not filed within one year of the date on which the claim arose, as required by Maryland *113Code (1984, 1999 Repl.Vol.), § 12-202 of the State Government Article. Therefore, the suit was barred by governmental immunity.
Although a private breach of contract action is subject to a three-year statute of limitations which may be waived by a failure to raise the issue, a breach of contract action against a state agency must be filed within one year. Furthermore, as recently reaffirmed by this Court in State v. Sharafeldin, 382 Md. 129, 140, 854 A.2d 1208, 1214 (2004), the one-year period for bringing a breach of contract action against a state government agency is not “a mere statute of limitations, waivable at will by State agencies or their respective attorneys.” The Court in Sharafeldin, 382 Md. at 148, 854 A.2d at 1219, concluded that the enactment of §§ 12-201 and 12-202 of the State Government Article
“was intended as a conditional waiver of the State’s sovereign immunity in contract actions, which was to be accomplished by precluding the State and its agencies from raising that defense if the action was founded on a written contract executed by an authorized official or employee and the action was brought within the one-year period. If the action was not brought within that period, however, it was ‘barred.’ The sovereign immunity that the State enjoyed remained in effect; it could not be waived by subordinate agencies or their attorneys, and thus the agencies were required by law to raise the defense. We hold, therefore, that § 12-202 is not a mere statute of limitations but sets forth a condition to the action itself. The waiver of the State’s immunity vanishes at the end of the one-year period....”
Because neither Towson University nor its attorneys may waive the issue of governmental or sovereign immunity by failing to raise it, this Court “must consider whether the doctrine of sovereign immunity is applicable in this case even though it was not previously raised by the parties.” Board v. John K. Ruff, Inc., 278 Md. 580, 583, 366 A.2d 360, 362 (1976).1
*114After Conte refused to resign, Towson University, on November 20, 1998, notified Conte by letter that it had cause to terminate his employment and “that the University will proceed to terminate your University employment for cause.” The November 20,1998, letter went on to state that Conte was being “reliev[ed] of your responsibilities as RESI Director” and was being placed “on administrative leave, with full pay and benefits” until the termination became effective. Then, on December 10, 1998, a ten-page letter signed by the Provost of Towson University was hand-delivered to Conte, informing Conte that the University terminated his employment; the December 10th letter set forth “the reasons supporting your termination.”
Conte requested a hearing before the President of Towson University, as provided for in the employment contract, and President Hoke L. Smith held the hearing on January 18, 1999. On January 21, 1999, President Smith notified Conte that he was terminated for the reasons set forth in the December 10, 1998, letter and that the termination was “effective the close of business January 26, 1999.” President Smith’s January 21st decision consisted of one short paragraph and contained no findings of fact or conclusions of law based upon evidence introduced or arguments made at the hearing.
The statutory time limit for filing a breach of contract action begins to run from the initial breach of the contract. Jones v. Hyatt, 356 Md. 639, 648-649, 741 A.2d 1099, 1104 (1999), and cases there cited. The complaint in the case at bar was filed in the Circuit Court on Monday, January 24, 2000.
If January 21, 1999, the date on which Conte was last notified of his termination, was the date on which his cause of action arose, the action was barred by the one year period set *115forth in § 12-202 of the State Government Article. The one-year period from January 21, 1999, expired either on Thursday, January 20, 2000, or at the latest, Friday, January 21, 2000. Obviously, if his breach of contract cause of action accrued earlier, on November 20, 1998, when Conte was first notified of the proposed termination and was suspended, or December 10, 1998, when he was again notified of his termination and given detailed reasons, the one-year period prescribed by § 12-202 had long expired. Conte’s breach of contract suit was timely only if the one-year period under § 12-202 did not begin to run until his termination was effective and he was removed from the payroll on January 26, 1999.
The majority opinion baldly asserts, without citing any case-law or other authorities, and without any reasoning, that Conte’s “cause of action for the actual breach” of his employment contract arose when the contract was “effectively terminated on January 26, 1999.” Opinion at 96, 862 A.2d at 957. This assertion is erroneous and contrary to authority in this Court and elsewhere.
If there were a breach of the employment contract between Conte and Towson University, it is likely that the breach occurred on November 20, 1998, or December 10, 1998, when the University informed Conte that the contract was terminated and suspended Conte. A change in an employee’s status, such as a suspension, has been held to constitute a breach of the employment contract even though the employee’s pay is not terminated or changed. See 9 Corbin On Contracts § 958, at 752 (Interim Edition 2002). Furthermore, the fact that a plaintiff may have defenses to the defendant’s action does not necessarily prevent the running of limitations. Cf. Himelfarb v. American Express Company, 301 Md. 698, 705, 484 A.2d 1013, 1016 (1984) (“From the standpoint of the Maryland common law of contracts, ... [the] claimed defense is ... ineffective to prevent accrual of [the plaintiffs] cause of action.... The limitations clock begins to tick while the [contracting party] is deciding whether an asserted defense is meritorious”). Consequently, the one year period under § 12-*116202 probably started to run on November 20, 1998, or December 10, 1998, despite Conte’s assertion of defenses at the January 18,1999, hearing.
At any rate, the breach of contract had certainly occurred, and Conte’s cause of action had clearly arisen, by January 21, 1999, when Conte for the third and final time was notified that the contract was terminated.
This Court has held that repudiation of an employment contract, even before the time for performance, “in our judgment, constituted a breach which gave an immediate right of action and entitled the plaintiff to recover damages,” Dugan v. Anderson, 36 Md. 567, 585 (1872). The majority opinion implies that, for purposes of “injunctive relief,” Conte’s cause of action may have accrued when Conte was notified of the termination, but that for purposes of an “actual breach” of contract action, for money damages, Conte’s cause of action accrued on the effective date of the termination, which was January 26, 1999. Majority opinion at 96, 862 A.2d at 957. This position is directly contrary to Dugan v. Anderson, supra, 36 Md. 567. The Dugan case was a breach of contract action at law, for money damages, in a court which had jurisdiction only in actions at law (the Superior Court of Baltimore City).2
In common law breach of employment contract actions, as well as statutory actions based upon wrongful breaches of employment contracts or wrongful terminations of employment, the general rule is that the running of limitations begins when notice of termination is issued by the employer and not when the termination becomes effective.
For example, in the leading case of Chardon v. Fernandez, 454 U.S. 6, 102 S.Ct. 28, 70 L.Ed.2d 6 (1981), employees were notified prior to June 18, 1977, that their employment would terminate at effective dates between June 30 and August 8, 1977. One of these employees on June 19, 1978, brought an *117action for unlawful employment termination pursuant to a statute which, like Maryland’s § 12-202, had a one-year period of limitations. The United States Court of Appeals for the First Circuit, like the majority today, held that the limitations period did not begin running until the employment termination became effective and the employment actually ended, and that, therefore, the action was timely. The Supreme Court of the United States, however, reversed, holding that the limitations period began to run when the employee was notified of the termination. The Court explained that “[t]he fact that they [respondent and other employees] were afforded reasonable notice cannot extend the period within which suit must be filed.” Chardon v. Fernandez, supra, 454 U.S. at 8, 102 S.Ct. at 29, 70 L.Ed.2d at 9.
Another leading Supreme Court case is Delaware State College v. Ricks, 449 U.S. 250, 101 S.Ct. 498, 66 L.Ed.2d 431 (1980), which was an action by a college professor based upon the alleged unlawful termination of his employment. The Supreme Court held that the statute of limitations began to run from the time the college professor was notified that he would be denied tenure and would be terminated, and not from the later date when the termination was effective.
Numerous cases, both federal and state, have relied upon the Supreme Court’s Chardon and Ricks opinions, as persuasive authority, to hold that the statute of limitations, in an employee’s action based upon termination of employment, begins to ran from the time the employee received notice of the termination and not from a later date when the termination became effective or the employment actually ceased. See, e.g., Cooper v. St. Cloud State University, 226 F.3d 964, 965, 967 (8th Cir.2000) (Relying upon Delaware State College v. Ricks, supra, the United States Court of Appeals stated: “[W]e hold that the statute of limitations began to run when the college announced its official tenure decision, rather than at the time of termination”); Holmes v. Texas A & M University, 145 F.3d 681, 684-685 (5th Cir.1998) (Texas statute of limitations ran from the notice to the university professor that he would be terminated rather than from the later date when *118the university re-affirmed its decision, with the United States Court of Appeals stating: “Although Ricks concerned the statute of limitations for filing a complaint with the EEOC rather than the Texas limitations period at issue here, we still consider the Ricks opinion persuasive on this point”); Thurman v. Sears, Roebuck & Co., 952 F.2d 128, 133-134 (5th Cir.), cert denied, 506 U.S. 845, 113 S.Ct. 136, 121 L.Ed.2d 89 (1992) (Employee’s action under a state statute for allegedly improper termination); Miller v. International Telephone and Telegraph Corp., 755 F.2d 20, 23 (2d Cir.), cert. denied, 474 U.S. 851, 106 S.Ct. 148, 88 L.E.2d 122 (1985) (citing Chardon v. Fernandez, supra, and Delaware State College v. Ricks, supra, the court stated that the statute of limitations “starts running on the date when the employee receives a definite notice of the termination, not upon his discharge”); Daniels v. Fesco Division of Cities Service Co., 733 F.2d 622, 623 (9th Cir.1984) (“[A]n employer’s liability for wrongful discharge commences upon notice of the employee’s termination even though the employee continues to serve the employer after receipt of such notice,” citing Delaware State College v. Ricks, although the cause of action before the Ninth Circuit was under California law); Eastin v. Entergy Corp., 865 So.2d 49, 54 (La.2004) (“[W]e adopt the Ricks/Chardon rule____Consequently, in the instant case, the prescriptive period of one year began to run for each of the ... Plaintiffs on the dates each of them were notified of their respective terminations”); Martin v. Special Resource Management, Inc., 246 Mont. 181, 185, 803 P.2d 1086, 1088-1089 (1990) (In an employee’s breach of contract action, after discussing the Chardon and Ricks cases, the Montana Supreme Court agreed that the employee’s “cause of action accrued upon notice of her termination,” as “[a]ll the elements needed for a claim of breach ... were present then” and “[i]t is from the decision to terminate itself which Martin seeks redress”) (emphasis in original); Delgado Rodriguez v. De Ferrer Y Otros, 121 P.R. Dec. 347, 357 (Supreme Court of Puerto Rico 1988) (The employee’s “cause of action accrued on March 19, 1981, when he was notified of his removal. * * * The action was time-barred and should *119have been dismissed,” relying upon Chardon v. Fernandez); Webster v. Tennessee Board of Regents, 902 S.W.2d 412, 414 (Tenn.App.1995) (A state university’s Director of Finance and Accounting received notice on September 3, 1991, “that he would be terminated from his employment, effective 30 September 1991, the day on which his contract for services ended. Plaintiff continued to work until 30 September 1991.” After discussing Delaware State College v. Ricks, the court held that limitations began to run on September 3, 1991, and that the action, filed on September 28, 1992, was barred by the one-year statute of limitations); Yoonessi v. State University of New York, 862 F.Supp. 1005, 1014 (W.D.N.Y.1994), appeal denied, 56 F.3d 10 (2d Cir.1995), cert. denied, 516 U.S. 1075, 116 S.Ct. 779, 133 L.Ed.2d 730 (1996) (“[T]he date the decision to terminate was made [is when] the limitations period begins to run ..., or on the date the employee was notified of the decision,” citing Chardon and Ricks); Montalban v. Puerto Rico Marine Management, Inc., 774 F.Supp. 76, 77 (D.P.R. 1991) (Applies the principle of Chardon and Delgado Rodriguez v. Nazario de Ferrer, supra, “that all causes of actions for employment termination accrue” when the employee has notice or knowledge of the termination, and not from the later effective date).3
*120Many other cases, although not specifically relying on Char-don or Ricks, have taken the same position. See, e.g., Eisenberg v. Insurance Co. of North America, 815 F.2d 1285, 1292 (9th Cir.1987) (Holding, in a diversity case governed by California law, that “[a]n ‘employer’s liability for wrongful discharge commences upon notice of the employee’s termination even though the employee continues to serve the employer after receipt of such notice’ ”); Johnston v. Farmers Alliance Mutual Insurance Company, 218 Kan. 543, 548, 545 P.2d 312, 317 (1976) (An employee was notified of his termination on March 3, 1972, although he was paid through May 31, 1972, and the Supreme Court of Kansas, in holding that the action was time-barred, reasoned that “plaintiff sustained substantial injury upon receipt of official notice of termination on March 3, 1972, and his cause of action accrued on that date”); Nicholson v. St. John the Baptist Parish School Board, 707 So.2d 94, 95 (La.App.) writ not considered, 716 So.2d 879 (La.1998) (“The prescriptive period begins to run when the plaintiff has actual or constructive notice of the alleged wrongful termination”) (italics in original); Morgan v. Musselwhite, 101 N.C.App. 390, 393, 399 S.E.2d 151, 153, review denied, 329 N.C. 498, 407 S.E.2d 536 (1991) (“By no later than the spring of 1987, plaintiff ... knew [that] defendant no longer planned to employ him. It was at this time that his cause of action arose”).
Moreover, even in situations where, after notice of termination, an employee is entitled to invoke contractual or other grievance procedures or administrative procedures to challenge the termination, the statute of limitations for an independent breach of contract, tort, or statutory action based upon the termination, begins to run from the time of notice and not from the decision under the grievance or administrative procedures. See Holmes v. Texas A & M University, supra, 145 F.3d at 685 (“Holmes deserves no equitable tolling for the pendency of his university grievance procedures”); *121Walch v. University of Montana, 260 Mont. 496, 498, 502, 861 P.2d 179, 180, 182 (1993) (After notice of termination, the plaintiff “filed a grievance contesting his discharge,” but the Supreme Court of Montana held that limitations began running from the notice, stating “that a cause of action for wrongful termination from employment, whether it is based on breach of the covenant ... or a common law wrongful discharge claim, ‘accrued upon notice of [the employee’s] termination’ ”); Zachary v. State of Oklahoma ex rel. The Department of Corrections, 34 P.3d 1171, 1172-1173 (Okl.Civ.App. 2001) (Limitations began to run when the employee received his notice of termination and not when his administrative remedies were exhausted); Yoonessi v. State University of New York, supra, 862 F.Supp. at 1014 (“[T]he filing and pendency of his grievances with the union did not toll the ... period for filing”); Montalban v. Puerto Rico Marine Management, Inc., supra, 774 F.Supp. at 78.
If the present case is to be treated as a breach of contract action, it was untimely. Under these circumstances, the judgments below should be vacated and the case should be remanded to the Circuit Court -with directions to dismiss the action on the ground of governmental immunity. This Court has no occasion to reach the questions dealt with in the majority’s opinion and Chief Judge Bell’s dissenting opinion.
II.
Towson University’s status as an agency in the Executive Branch of the State Government, and Conte’s status as a government employee who could only be terminated for cause, coupled with the express contractual provision for a hearing before the head of the agency, i.e., the President of Towson University, necessarily presents the issue of whether a common law breach of contract action in the Circuit Court is an appropriate proceeding for resolving this dispute.
An employee in the Executive Branch of the State Government, who can only be disciplined or terminated for cause, is, as a matter of constitutional due process, entitled to a hearing *122at which the employee is given the opportunity to refute the charges against him or present defenses. Board of Regents v. Roth, 408 U.S. 564, 573, 92 S.Ct. 2701, 33 L.Ed.2d 548 (1972); Codd v. Velger, 429 U.S. 624, 97 S.Ct. 882, 51 L.Ed.2d 92 (1977); Maryland Classified Employees Association v. State of Mainland, 346 Md. 1, 22, 694 A.2d 937, 947 (1997); De Bleecker v. Montgomery County, 292 Md. 498, 513 n. 4, 438 A.2d 1348, 1356 n. 4 (1982). Such a hearing is normally an adjudicatory administrative hearing in the Executive Branch of government, subject to a statutory or common law judicial review action in a Maryland Circuit Court. See Brukiewa v. Police Comm’r, 257 Md. 36, 42, 263 A.2d 210, 213 (1970).
The majority opinion seems to suggest that a common law breach of contract action is a “remedy available” to an employee for purposes of defending against the charges brought by the state agency. Opinion at 96, 862 A.2d at 957. Although perhaps due process requirements could be satisfied by a de novo breach of contract action in a court at which the terminated employee would have an opportunity to refute the charges or offer defenses, such a proceeding involving a government employee would be highly unusual. Moreover, in Maryland Classified Employees Association v. State of Maryland, supra, 346 Md. at 22, 694 A.2d at 947, Judge Wilner for this Court took the position that the hearing must ordinarily be “pre-termination,” saying:
“[Wjhen the attributes attendant to public employment under State law are such as to give the employee ‘a legitimate claim of entitlement’ to the position, as under a tenure plan or where dismissal may only be for cause, a property interest in that employment is created, and the right to procedural due process ordinarily requires the opportunity of a pre-termination hearing.”4
*123Furthermore, the majority opinion in the present case, by treating Towson University as a private entity, applies a rule precluding the court in the breach of contract action from reviewing the factual basis of the termination, even under a “substantial evidence” standard. If a circuit court breach of contract action could provide the due process hearing for a governmental employee, the type of court action outlined by the majority opinion clearly does not provide due process. It does not give the employee any right to refute the charges or present defenses in a circuit court. The Due Process Clause of the Fourteenth Amendment and Article 24 of the Maryland Declaration of Rights are not applicable to private employment relationships. Towson University, however, is restrained by both constitutional provisions.
Considerations of due process, plus the express provisions of the employment contract, certainly appear to require an administrative hearing before the head of an agency within the Executive Branch of Maryland Government, i.e., the President of Towson University. In fact, the majority’s deference to the governmental “factfinder” confirms that the majority, although unwittingly, is actually treating the proceedings culminating in Conte’s termination as governmental administrative adjudicatory proceedings.
In its insistence that this case should properly be treated as a common law breach of contract action, the majority relies on Maryland Code (1978, 2004 Repl.Vol.), § 12-104(j)(2) of the Education Article, which provides as follows:
“(2) Except with respect to grievance appeals under Title 13, Subtitle 2 of this article, Title 10, Subtitles 1 and 2 of the *124State Government Article (‘Administrative Procedure Act’) are not applicable to the University.”
Title 13, Subtitle 2, of the Article deals -with classified employees of the University System of Maryland. Consequently, termination proceedings with regard to classified employees of Towson University are subject to the Administrative Procedure Act, and termination proceedings concerning non-classified employees, including Conte, are exempt from the Administrative Procedure Act.
The fact that the termination proceedings here are exempt from the Administrative Procedure Act furnishes no reason to conclude that a common law breach of contract action is appropriate. Numerous types of adjudicatory administrative proceedings are exempt from the Administrative Procedure Act, but such exemption does not change the inherent nature of such proceedings or convert them into common law breach of contract actions. See, e.g., Code (1984, 1999 Repl.Vol.), §§ 10-102(b) and 10-203 of the State Government Article, containing lists of administrative agencies or proceedings exempt from the Administrative Procedure Act.
An exemption from the Administrative Procedure Act or other administrative law statute simply means that the administrative proceeding is governed by Maryland common law administrative law principles and that judicial review in a circuit court takes the form of mandamus, certiorari, declaratory judgment, or equitable proceedings. It also means that the 30-day period of limitations set forth in Maryland Rule 7-203 is inapplicable. See Rule 7-201(a). The standards, however, are essentially the same regardless of whether the administrative/judicial review proceedings are pursuant to statute or are governed by Maryland common law administrative law principles. See, e.g., Board of License Commissioners for Anne Arundel County v. Corridor Wine, Inc., 361 Md. 403, 411-412, 761 A.2d 916, 920 (2000); Bucktail v. County Council of Talbot County, 352 Md. 530, 542-552, 723 A.2d 440, 446-450 (1999); State v. Board of Education, 346 Md. 633, 642-644, 697 A.2d 1334, 1338-1339 (1997); Goodwich v. Nolan, 343 Md. 130, 146, 680 A.2d 1040, 1048 (1996); Medical Waste *125v. Maryland Waste, 327 Md. 596, 610-611, 612 A.2d 241, 248 (1992); Silverman v. Maryland Deposit, 317 Md. 306, 324-326, 563 A.2d 402, 411-412 (1989); Criminal Inj. Comp. Bd. v. Gould, 273 Md. 486, 501-507, 331 A.2d 55, 65-68 (1975), and cases there cited.
In fact, the General Assembly’s express exemption of all University System of Maryland proceedings from the Administrative Procedure Act, except those involving classified employees, could hardly be a determination that no such proceedings are by nature adjudicatory administrative proceedings and that all disputes should be resolved by common law contract or tort actions in the courts. Obviously, numerous types of adjudicatory administrative proceedings take place in the University System. See, e.g., Frankel v. Board of Regents, 361 Md. 298, 308, 761 A.2d 324, 329 (2000). An exemption from the Administrative Procedure Act clearly does not reflect a legislative intention that governmental employment termination disputes should be treated as breach of contract actions. The General Assembly exempts administrative proceedings from the Administrative Procedure Act. It does not, to the best of my knowledge, enact statutes exempting common law breach of contract actions from the Administrative Procedure Act.
It would seem that the Towson University proceedings leading up to Conte’s termination should be regarded as adjudicatory administrative proceedings subject to normal judicial review for substantial evidence underlying factual findings, arbitrariness, legal error, etc.5 Under our cases, primary jurisdiction should be accorded to such administrative/judicial review proceedings, and exhaustion of the administrative/judicial review remedy is required. See, e.g., *126Foster v. Panoramic Design, Ltd., 376 Md. 118, 133-138, 829 A.2d 271, 280-283 (2003); Dorsey v. Bethel A.M.E. Church, 375 Md. 59, 76, 825 A.2d 388, 397-398 (2003); Furnitureland v. Comptroller, 364 Md. 126, 133, 771 A.2d 1061, 1065 (2001); Josephson v. Annapolis, 353 Md. 667, 674-678, 728 A.2d 690, 693-695 (1998); Holiday v. Anne Arundel, 349 Md. 190, 201, 707 A.2d 829, 834-835 (1998); Zappone v. Liberty Life Insurance, 349 Md. 45, 60-66, 706 A.2d 1060, 1067-1070 (1998).
Like governmental immunity, public policy considerations mandate that issues of primary jurisdiction, exhaustion of administrative remedies, and the propriety of bringing an action other than a judicial review action, “are issues which this Court will address sua sponte.” Furnitureland v. Comptroller, supra, 364 Md. at 132, 771 A.2d at 1065. See, e.g., Montgomery County v. Broadcast Equities, 360 Md. 438, 451 n. 7, 758 A.2d 995, 1002 n. 7 (2000); Maryland Reclamation v. Harford County, 342 Md. 476, 490 n. 10, 677 A.2d 567, 574 n. 10 (1996); Montgomery County v. Ward, 331 Md. 521, 526 n. 6, 629 A.2d 619, 621 n. 6 (1993); Moats v. City of Hagerstown, 324 Md. 519, 525-526, 597 A.2d 972, 975 (1991); Board of Education for Dorchester Co. v. Hubbard, 305 Md. 774, 787, 506 A.2d 625, 631 (1986).
If, as I believe, the appropriate circuit court action in this case was not a breach of contract suit but was a common law action for “substantial evidence” judicial review under the principles set forth in Bucktail v. Talbot County, supra, 352 Md. at 549-552, 723 A.2d at 448-450, and similar cases, this Court could in its discretion take any one of three different approaches. Since Conte failed to bring a judicial review action, and improperly sued for breach of contract, the Court could simply vacate the judgments below and direct that the breach of contract suit be dismissed. See Holiday v. Anne Arundel, supra, 349 Md. at 202-204, 214, 707 A.2d at 835-836, 841 (After a final administrative decision, the aggrieved party pursued a declaratory judgment action instead of a judicial review action, and this Court vacated the judgments below and directed the Circuit Court to dismiss the action). Or, the Court could vacate the judgments below, direct that Conte be *127allowed to amend his complaint to assert the proper type of action, and, if he so amends, direct the Circuit Court to perform a traditional judicial review function. Lastly, because the function of a trial court and an appellate court are the same in an action for judicial review of an adjudicatory administrative decision, this Court could treat Conte’s complaint as an action for judicial review and proceed to review the final administrative decision by the President of Towson University. See Holiday v. Anne Arundel, supra, 349 Md. at 204-214, 707 A.2d at 836-841 (This Court, as an alternative ground of decision, treated the improper declaratory judgment action as a judicial review action, reviewed the administrative decision, and took the position that the administrative decision should be upheld).
In the interests of justice, I would prefer this third alternative. Furthermore, I would direct that the administrative decision be vacated and that the case be remanded for findings of fact and conclusions of law. The short one-paragraph opinion of President Smith after the January 18, 1999, hearing, contains no findings of fact or conclusions of law. It fails to deal with any evidence or arguments that may have been advanced at the January 18th administrative hearing. Thus, in Bucktail v. Talbot County, supra, 352 Md. at 552-553, 723 A.2d at 450-451, a non-statutory judicial review action, the Court in an opinion by Judge Rodowsky summarized the applicable Maryland administrative law as follows:
“Logically, the next step in our analysis would be to determine if the facts found by the Council are supported by substantial evidence. The difficulty here, however, is that the Council’s ‘findings’ are insufficient to permit judicial review.
“ ‘The court’s task on review is not to substitute its judgment for the expertise of those persons who constitute the administrative agency[.]’ ” A reviewing “Court may not uphold the agency order unless it is sustainable on the agency’s findings and for the reasons stated by the agency.” A court’s role is limited to determining if there is substantial evidence in the record as a whole to support *128the agency’s findings and conclusions, and to determine if the administrative decision is premised upon an erroneous conclusion of law.
United Parcel Serv., Inc. v. People’s Counsel for Baltimore County, 336 Md. 569, 576-77, 650 A.2d 226, 230 (1994) (citations omitted). Accord Harford County v. Earl E. Preston, Jr., Inc., 322 Md. 493, 505, 588 A.2d 772, 778 (1991) (“[A] fundamental right of a party to a proceeding before an administrative agency [is] to be apprised of the facts relied upon by the agency in reaching its decision and to permit meaningful judicial review of those findings. In a judicial review of administrative action the court may only uphold the agency order if it is sustained by the agency’s findings and for the reasons stated by the agency.”); United Steelworkers of America AFL-CIO, Local 2610 v. Bethlehem Steel Corp., 298 Md. 665, 679, 472 A.2d 62, 69 (1984) (same).
“In accordance with the above standard of judicial review, in order for the reviewing court to determine whether the Council’s action was fairly debatable, findings of fact are required.
“Findings of fact must be meaningful and cannot simply repeat statutory criteria, broad conclusory statements, or boilerplate resolutions.”
See also, e.g., Turner v. Hammond, 270 Md. 41, 56, 310 A.2d 543, 551 (1973) (The agency “made no findings of fact worthy of the name”); Rodriguez v. Prince George’s County, 79 Md.App. 537, 550, 558 A.2d 742, 748, cert. denied, 317 Md. 641, 566 A.2d 101 (1989) (Where Judge Wilner for the court stated: “It is not permissible for ... any administrative body, simply to parrot general statutory requirements or rest on broad conclusory statements. * * * We have quoted in full the ‘determinations’ ... that the [agency] adopted as its findings and conclusions. They do not suffice — they do not even begin to suffice — as ‘specific written findings of basic facts and conclusions’ ”).
Nevertheless, regardless of the nature of the Towson University termination proceedings or the appropriate type of *129court action, there is one thing about this case which is clear. The “business judgment” rule applied by the majority has no application to a governmental employment relationship which can only be terminated for cause. Conte is entitled to and should receive either a proper administrative proceeding which complies with Maryland law or a de novo breach of contract trial at which his defenses to the charges should be considered and ruled upon. The majority gives him neither.
. The parties in ihe courts below did raise the issue of the timeliness of Conte’s claims for compensation in fiscal years 1997 and 1998, and the *114Court of Special Appeals held that those claims were barred by § 12-202 of the State Government Article. Conte’s cross-petition for a writ of certiorari challenging that holding was denied by the Court. It appears that no issue has previously been raised concerning the timeliness of Conte’s entire action.
. Furthermore, because an action for an injunction is equitable, in such an action against a private employer, the statute of limitations would not ordinarily be directly applicable, and the timeliness issue would be governed by principles of laches.
. In Oker v. Ameritech Corp., 89 Ohio St.3d 223, 729 N.E.2d 1177 (2000), the Supreme Court of Ohio, in an action under an Ohio statute relating to age discrimination, declined to apply the principle of Delaware State College v. Ricks. In holding that the period of limitations did not begin to run until the last day of employment, the Ohio Supreme Court did not disagree with the Ricks opinion. Instead, the court distinguished Ricks because of a provision in the Ohio statute expressly providing for liberal construction and because of other language in the Ohio statute.
The Supreme Court of Oregon, however, has disagreed with the rule set forth in Ricks, holding that, in a tort action based on wrongful discharge, limitations runs from the end of the employment relationship because the tortious discharge occurred on the last day of employment. Stupek v. Wyle Laboratories, 327 Or. 433, 439, 963 P.2d 678, 682 (1998). The position taken by the Oregon court is a distinct minority view. Moreover, the Stupek case is distinguishable from the case at bar, as it involved a tort action for abusive discharge. In an action for breach of an employment contract, Maryland law clearly appears to be in accord *120with the Ricks and Chardon opinions. See Dugan v. Anderson, 36 Md. 567, 585 (1872).
. The majority intimates that my position is that an administrative/judicial review proceeding "is a jurisdictional requirement.” Opinion at 96, 862 A.2d at 957. That is not my position. Exhaustion of a required administrative/judicial review remedy is ordinarily not a “jurisdictional” matter or a "jurisdictional requirement” under Maryland law. Board of Education for Dorchester Co. v. Hubbard, 305 Md. 774, 787, *123506 A.2d 625, 631 (1986) (Failure to invoke and exhaust a primary administrative/judicial review "remedy does not ordinarily result in a trial court's being deprived of fundamental jurisdiction,” per Eldridge, J., for the Court). See also, e.g., State Retirement v. Thompson, 368 Md. 53, 66, 792 A.2d 277, 284-285 (2002); Montgomery County v. Ward, 331 Md. 521, 526 n. 6, 629 A.2d 619, 621 n. 6 (1993). In the case at bar, the Circuit Court clearly had subject matter jurisdiction over Conte’s breach of contract action. The issues concern how that jurisdiction should have been exercised.
. In fact, using a breach of contract action instead of a "substantial evidence" judicial review action, to review an adjudicatory administrative proceeding and decision by the Executive Branch of the State Government, may well present serious Maryland constitutional problems under the principles set forth in Department of Natural Resources v. Linchester Sand and Gravel Corporation, 274 Md. 211, 222-229, 334 A.2d 514, 522-526 (1975), and its progeny.