HARRELL, J., concurring and dissenting, in which BARBERA, J., joins.
After being charged criminally, but incorrectly, as it turned out, for the murder of his wife, Keith Longtin (“Longtin”) asserted thirteen different civil causes of action1 against Prince George’s County and certain of its police officers. The jury in the Circuit Court for Prince George’s County that *501considered the evidence returned a verdict of more than $5 million. On appeal, we are asked, among the questions presented, to decide when the causes of action accrued, triggering the 180-day notice requirement of the Local Government Tort Claims Act (“LGTCA”). We are asked also to determine whether the damages cap in the LGTCA applies to the verdict, so as to reduce the jury award accordingly.
The Majority opinion, concluding neatly that each claim accrued on the date of Longtin’s release from detention, employs a one-size-fits-all analysis of the LGTCA notice question. It also declines to address an unavoidable constitutional challenge associated with application of the damages cap to the verdict, which included a State constitutional tort violation. Although I agree with the conclusion of the Majority opinion that Longtin’s claims should not be frustrated by the circumstances surrounding Longtin’s giving of notice regarding his claims, it is not because—as the Majority opinion explains—all of his distinct, and some fundamentally different, causes of action accrued on the same date, 13 June 2000 (the date of his release from the County detention center), after which he gave notice within 180 days. Moreover, although I agree with the isolated principle articulated in the Majority opinion that the Maryland Constitution prevents the Legislature from impairing retrospectively a vested right, I disagree that the unliquidated, unspecified, and unknown damages claims associated with Longtin’s claims at the time of their accrual (whenever that occurred) represented a substantive protected or vested right under the circumstances of this case.
Thus, I: concur with the result only reached in Part 1 of the Majority opinion; dissent as to Part 2; and, concur with the reasoning and results of Parts 3 and 4.
I. The Notice Requirement.2
The Majority opinion concludes that Longtin satisfied literally the notice requirement of the LGTCA. In attaining that *502result, it determines that, while Longtin asserted many different causes of action, the trigger of the commencement of the notice period as to all of them began running at the same time—his release from detention. In essence, the Majority opinion crafts a one-size-fits-all analysis and holding for not just the false arrest and false imprisonment causes of action discussed in the bulk of the opinion, but also the largely neglected other causes of action. A closer and more comprehensive examination suggests to me a different analysis supplies the better course of reasoning, albeit the same outcome.
A. Applicable Law.
The relevant provision of the LGTCA is codified at § 5-304 of the Courts and Judicial Proceedings Article, titled “[ajctions for unliquidated damages.” Maryland Code (1974, 2006 Repl. Vol.), Courts and Judicial Proceedings Article, § 5-304. In pertinent part, it provides that “an 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.” § 5-304(b)(1) (emphasis added). In Heron v. Strader, 361 Md. 258, 263-64, 761 A.2d 56, 59 (2000), we interpreted the phrase “after the injury” in § 5-304(b)(l) as synonymous with “after the cause of action accrued.” Therefore, post-Heron, a court determines whether notice was timely by first identifying the accrual date or event.
The Majority opinion approaches this analysis in Longtin’s case largely by analogizing the LGTCA notice requirement to *503statute of limitations jurisprudence. See Majority op. at 475, 19 A.3d at 874 (“[W]e are ... guided by false arrest and imprisonment cases involving the accrual date for the statute of limitations____[as] their policies of protecting defendants against stale claims are similar.”); see id. at 476, 19 A.3d at 875 (“The general rule for false arrest and imprisonment case[s,] when a person is arrested and released prior to trial[,] is that the statute begins to run only when the imprisonment ends ....”) (internal quotation marks and citations omitted). Such an analogy is inapposite, as well as unnecessary. We have said clearly that, to determine when a cause of action accrues under the LGTCA notice provision, we “must examine the elements of the cause of action”—for, under our precedents, “a cause of action is said to have arisen when facts exist to support each element,” including injury. Heron, 361 Md. at 264, 761 A.2d at 59 (internal quotation marks and citations omitted).3
*504Thus, we should ask “when the legally operative facts permitting the filing of his [or her] claims came into existence.” Heron, 361 Md. at 264, 761 A.2d at 59; see also Hecht v. Resolution Trust Corp., 333 Md. 324, 334, 635 A.2d 394, 399 (1994) (“This Court [has] adopted what is known as the discovery rule, which now applies generally in all civil actions, and which provides that a cause of action accrues when a plaintiff in fact knows or reasonably should know of the wrong.”); Lumsden v. Design Tech Builders, Inc., 358 Md. 435, 444, 749 A.2d 796, 801 (2000) (“[W]e now hold the discovery rule to be applicable generally in all actions and the cause of action accrues when the claimant in fact knew or reasonably should have known of the wrong.”).4 Because each *505cause of action possesses distinct elements (usually), we should examine each cause of action separately. Not surprisingly, under such an approach, each claim may have a unique accrual date. Heron, 361 Md. at 262, 761 A.2d at 58 (“[T]o assess the timeliness of [the] Notice of Claim under the LGTCA, it is necessary, first, to determine the time of [the] alleged injury for each of the appealed claims.”) (emphasis added).
B. False Arrest and Imprisonment.
The Majority opinion devotes the bulk of its notice analysis (understandably perhaps) to the torts of false arrest and false imprisonment. These torts seem to be the lynchpins guiding the Court’s treatment of the accrual dates for Longtin’s other claims. Majority op. at 480, 19 A.3d at 877 (“Our resolution of the notice issue for false arrest and imprisonment resolves the notice issue for most of Longtin’s claims.”). I will focus likewise on these torts because applying the proper analysis to them alone reproves the reasoning of the Majority opinion. I submit nonetheless that a majority opinion of this Court should conduct a more comprehensive examination for each cause of action, rather than employ shortcuts.5
*506Unusually, the “elements of false arrest and false imprisonment are identical”; thus, they may be considered together. Heron, 361 Md. at 264, 761 A.2d at 59. The elements are: “[ (1) ] the deprivation of the liberty of another[,] [ (2) ] without consentí,] and [ (3) ] without legal justification. ” Heron, 361 Md. at 264, 761 A.2d at 59 (emphasis added). “Whatever technical distinction there may be between an ‘arrest’ and a detentionf,]’ the test whether legal justification existed in a particular case has been judged by the principles applicable to the law of arrest.” Great Atl. & Pac. Tea Co. v. Paul, 256 Md. 643, 655, 261 A.2d 731, 738 (1970) (emphasis added) (reviewing the distinction between the torts of false arrest and imprisonment).
A police officer possesses legal justification “to make a warrantless arrest where he has probable cause to believe that a felony has been committed, and that the arrestee perpetrated the offense.” Ashton v. Brown, 339 Md. 70, 120, 660 A.2d 447, 472 (1995) (citations omitted); see also Montgomery Ward v. Wilson, 339 Md. 701, 721, 664 A.2d 916, 926 (1995) *507(“[A] police officer carrying out ... an arrest ... is not liable for false imprisonment in connection with that arrest if the officer had ... legal [justification] to arrest under the circumstances.”) (citation omitted). “[T]he act of arrest,” however, “is ordinarily a momentary event.” State v. Dett, 391 Md. 81, 93, 891 A.2d 1113, 1121 (2006). As a result:
“[T]he legal justification for the arrest ... can dissipate over time. The detaining authority may come into possession of information, not known at the time of arrest or not known at some earlier point in the detention, which ... may cause the legal justification ... to disappear. The standards used to determine legal justification remain the same, but, in the course of a continuing detention, their application needs to be reexamined whenever changes in the factual underpinning of their application become known.”
See id. (emphasis added).6
In Longtin’s case, at the moment police arguably arrested him, viz., placed him into an interrogation room at 1:30 p.m. on 5 October 1999,7 they had probable cause, i.e., legal justifica*508tion, to do so. On the day of the murder, 4 October 1999, the police discovered the victim with her pants and underwear at her feet and with multiple stab wounds. On the day of the “marathon” interrogation, 5 October 1999, the police learned, before Longtin was placed in the interrogation room, that: (1) Longtin called the police to report his estranged wife missing, (2) he knew where to locate the victim, (3) he asked, at the crime scene, if the victim was his wife, and (4) he allegedly carried a “buck knife,” “used [it] very well,” and had been “very abusive” to his past two ex-wives. Detective Herndon, Primary Investigator, Notes from Telephone Conversation with Charles County Sheriffs Office, 12:45 p.m.; see also Mobley v. State, 270 Md. 76, 81, 310 A.2d 803, 807 (1973) (“[W]hether probable cause is shown to exist may be measured in terms of the collective information demonstrated by the record to be within the possession of the entire police team.”) (citations omitted).8
Over time, however, the probable cause/legal justification dissipated, which at some point in the continuum Longtin’s cause of action accrued. Specifically, in February 2000, Long-tin was excluded as a possible donor of DNA taken from the victim, to wit, a vaginal swab. Taken together with the fact that the police knew the victim was raped9 and then mur*509dered, the police no longer had probable cause/legal justification to detain Longtin.10 Thus, the false arrest/imprisonment causes of action accrued actually in February 200011—when facts existed to support each element of the torts.12
*510C. Heron.
In arriving at its determination that all of Longtin’s causes of action accrued on his date of release from detention, the Majority opinion discusses and distinguishes Heron. In Heron, the plaintiff was “arrested and charged with resisting arrest, obstructing the police in the performance of their duties, and disorderly conduct.” Heron, 361 Md. at 261, 761 A.2d at 57. He was acquitted eventually of all charges and, subsequently, filed a civil suit for malicious prosecution, false arrest, and false imprisonment. See id. We held that Heron’s false arrest.and false imprisonment claims accrued upon his arrest. See Heron, 361 Md. at 265, 761 A.2d at 59. The Majority opinion suggests that the conclusion reached in Heron was achieved haphazardly.
In particular, the Majority claims that “[tjhere was no need [in Heron ] to distinguish between the date of arrest and the date of release; whichever was used, the notice was too late.” Majority op. at 473, 19 A.3d at 873. In fact, it observes that, in Heron, we cited “with approval multiple decisions which *511identified the date of release as the date a false arrest or false imprisonment claim accrues.” Majority op. at 473-74,19 A.3d at 873 (citing Collins v. County of Los Angeles, 241 Cal.App.2d 451, 50 Cal.Rptr. 586, 588 (1966); Ragland v. New York City Hous. Auth., 201 A.D.2d 7, 613 N.Y.S.2d 937, 939 (App.Div.1994); Boose v. Rochester, 71 A.D.2d 59, 421 N.Y.S.2d 740 (1979); Alice v. New York, 42 A.D.2d 899, 347 N.Y.S.2d 708 (App.Div.1973)). In each of the foreign cases relied on by the Majority opinion, “[tjhere was [similarly] no need to distinguish between the date of arrest and the date of release; whichever was used, the notice was too late.” Majority op. at 473,19 A.3d at 873. Indeed, all of the cases involved plaintiffs who, like Heron, were detained for a very brief period of time, ie., one day. Given the Majority’s reason for deeming Heron unenlightening, one wonders why these foreign cases were more persuasive to the Majority than Heron seemed to be.
Three of those foreign cases (ie., all but Collins) appear in unanalyzed string citations in Heron. I find more relevant and persuasive the cases the Heron Court cites and fleshes out. They include Collins; Allen v. District of Columbia, 533 A.2d 1259, 1263 (D.C.App.1987); Livingston v. Consolidated City of Indianapolis, 398 N.E.2d 1302 (Ind.App.1979); Pisano v. City of Union City, 198 N.J.Super. 588, 487 A.2d 1296, 1299 (N.J.Super.Law Div.1984); Michaels v. New Jersey, 955 F.Supp. 315 (D.N.J.1996); and Deary v. Three Un-Named Police Officers, 746 F.2d 185 (3rd Cir.1984).
In Collins, the California Court of Appeal held that “it is only reasonable to assume that immediately upon their arrest and imprisonment [the plaintiffs] would have believed the same to be unlawful, at which time they could and should have sought legal assistance to determine the cause and the reason for their arrest.... ” Collins, 50 Cal.Rptr. at 589 (emphasis added) (observing that false arrest/imprisonment and malicious prosecution do not share the same accrual date because they do not share the same elements). In Allen, the District of Columbia Court of Appeals stated that “[a \ccording to the facts of this case, any injury for the alleged false arrest ... would have been sustained at the time of [plaintiffs] arrest *512and transport to police headquarters----” Allen, 533 A.2d at 1263 n. 9 (emphasis added) (citation omitted) (interpreting statute which required notice within six months “after the injury or damage was sustained”). In Livingston, the Indiana Court of Appeals concluded that “[the plaintiffs] claims for false arrest, false imprisonment, and assault and battery accrued on ... [a single] day”—when “[she] was arrested, charged, and released from custody.” Livingston, 398 N.E.2d at 1303 (citation omitted).
In Pisano, the Superior Court of New Jersey held that a “plaintiffs cause of action for false arrest accrued as of the date of arrest____” Pisano, 487 A.2d at 1299 (citing Collins for the proposition that “[t]he interpretation of the California statute, upon which the New Jersey Tort Claims Act is modeled, provides authority for the view that a cause of action accrues at the time of the arrest”); see id. (observing that false arrest and malicious prosecution do not share the same accrual date because they do not share the same elements). In Michaels, the federal District Court found that a plaintiffs causes of action “accrued ... when [she] had reason to know that the elements of the claims existed,” which “occurred at or about the time of [her] arrest....” Michaels, 955 F.Supp. at 326 (citations omitted). Finally, in Deary, the United States Court of Appeals for the Third Circuit—interpreting the Virgin Islands Tort Claims Act, V.I. CODE ANN. tit. 33, § 3401 (2000)—provided that false arrest/imprisonment accrued when the plaintiff “knew or had reason to know of the injury that constitutes the basis of this action,” which it held was the date of arrest. Deary, 746 F.2d at 193 (stating that when the plaintiff was arrested, her cause of action accrued because “nothing further had to occur”; “so far as she knew[,] she was arrested without probable cause”).
Returning to Heron, we said that “to determine when ... causes of actions arise, we must examine the elements of the cause of action ... as a cause of action is said to have arisen when facts exist to support each element.” Heron, 361 Md. at 264, 761 A.2d at 59 (internal quotation marks and citation omitted). Heron demonstrated that other jurisdictions exam*513ine also the elements of each claim to determine when it accrued—they did not opine that all tort claims in a complaint accrue on the same date, nor that false arrest and imprisonment claims always, regardless of the particular circumstances of each case, accrue on the same date. Such a one-size-fits-all, “domino” approach, in which one accrual date dictates the rest, is inconsistent with well-established tort law. At the very least, these cases militate against the Majority opinion’s suggestion that Heron’s reliance on foreign cases actually supports its position that the accrual date for all false arrest/imprisonment claims is the plaintiffs date of release.
In sum, we did not in Heron select haphazardly the date of arrest as the accrual moment. Rather, the Court examined the record and held that “[t]he facts alleged to support each element of his claim were in existence” when “he was arrested and detained by the police.” Heron, 361 Md. at 265, 761 A.2d at 59. As a result, Heron’s “causes of action ... arose” on the date of arrest. Id. Assuming the Majority opinion employs the wrong analysis in evaluating the notice question and that a proper analysis yields a conclusion that the day of Longtin’s arrest was the correct accrual date of these causes of action, must Longtin’s claims fail for improper notice? The answer is “No.”
D. Substantial Compliance or Waiver for Good Cause under the LGTCA?
Because, in my view, Longtin’s false arrest/imprisonment causes of action accrued in February 2000, his October 2000 notice to the County was untimely. If, however, Longtin complied substantially with the LGTCA notice requirement or demonstrated good cause, he should be permitted nonetheless to pursue his civil claims. Substantial compliance is possible ordinarily when a plaintiff files timely notice, but fails to abide some other procedural requirement, e.g., service on a proper recipient. See Faulk v. Ewing, 371 Md. 284, 299, 808 A.2d 1262, 1272-73 (2002) (“[Sjubstantial compliance is such communication that provides ... requisite and timely notice of facts and circumstances giving rise to the claim.”) (internal *514quotation marks and citation omitted). In the present case, Longtin’s notice was untimely and, thus, a poor fit for substantial compliance.
Waiver for good cause, in the context of the § 5-304 notice requirement, is possible where “the claimant prosecuted his [or her] claim with that degree of diligence that an ordinarily prudent person would have exercised under the same or similar circumstances.” Heron, 361 Md. at 271, 761 A.2d at 63. Based on a survey of other jurisdictions, we recognized in Heron that circumstances justifying good cause “fit [normally] into several broad categories: excusable neglect or mistake, see e.g., ... Kleinke v. Ocean City, 147 N.J.Super. 575, 371 A.2d 785 (N.J.Super.App.Div.1977); serious physical or mental injury and/or location out-of-state; the inability to retain counsel in cases involving complex litigation; and ignorance of the statutory notice requirement____” Heron, 361 Md. at 272-73, 761 A.2d at 63-64 (citations omitted). A plaintiff is not excused, however, because he or she is occupied preparing for a criminal trial. See id.
In Kleinke, the Superior Court of New Jersey found excusable neglect where the plaintiff, among other things, was “confine[d] to a hospital for two months” and was “incapacitated by a complication] of an embolism.... ” Kleinke, 147 N.J.Super. at 580, 371 A.2d at 788. Unlike the plaintiff in Kleinke, Heron was imprisoned for two days, but then released and delayed filing his notice. He argued that the Court should grant a waiver for good cause because, post-release, he was immersed in the planning of his defense to the criminal charges. We held that Heron, who was no longer imprisoned, was not so burdened by his preparation for the impending criminal trial as to prevent the filing of a simple written notice. Heron, 361 Md. at 271, 761 A.2d at 63 (“We agree ... that an ordinarily prudent person, in [Heron’s ] circumstances, would have been able, through the exercise of reasonable diligence, to file ... a Notice of Claim.”) (emphasis added).
*515In the present case and unlike Heron, Longtin was imprisoned for a substantial period of time, while the notice period(s) for his causes of action was (were) running. It was not a matter simply of finding time to file the notice; it was finding a way to file notice while “confine[d]” and “incapacitat[ed],” like the plaintiff in KleinJce. At bottom, then, I would conclude that Longtin acted with the due diligence of a reasonable person isolated in a detention center for eight months, such that his neglect should qualify under the first Heron category for waiver of strict compliance with the LGTCA notice requirement.
II. The Damages Cap.
A. Vested Rights Analysis Is Inapposite.
The Maryland Constitution prohibits the Legislature from impairing retrospectively vested rights. One necessarily asks, in performing such an analysis, what constitutes a protected vested right? From its infancy, our vested rights jurisprudence focused on a plaintiffs ability (or inability) to bring a cause of action. Thus, 150 years ago in Thistle v. The Frostburg Coal Co., 10 Md. 129, 144 (1856), we confronted a purported retrospective legislative provision which enabled adverse possessors of real property to challenge paper title holders on the basis of mere use, rather than the then-law, actual enclosure. Because the statutory provision “changed the elements of adverse possession” to make it easier for adverse possessors to challenge successfully paper title holders, we deemed it invalid. Dua v. Comcast Cable of Md., Inc., 370 Md. 604, 623, 805 A.2d 1061, 1072 (2002) (citing Thistle); see also Thistle, 10 Md. at 145 (“Hence, ... it was not in the power of the legislature to change this rule of law, so far as to give it retroactive operation, because it would virtually be taking the land of one man, held [previously] by a good legal title, and giving it to another, who the law has said had none.”). We made clear in Thistle, however, that “it was within the power of the legislature, to alter and remodel the rules of evidence and remedies, to which parties claiming title *516and possession of land, might resort----” Thistle, 10 Md. at 145 (emphasis added).
Reflecting in Dua on our Thistle holding, we concluded that “there is a vested right in an accrued cause of action.” Dua, 370 Md. at 632, 805 A.2d at 1077. As in Thistle, we recognized that there is a difference between the Legislature abrogating the right to bring a cause of action, and the Legislature altering the remedy sought by, but not yet conferred upon, a plaintiff. In particular, we relied on Baugher, et al. v. Nelson, 9 Gill 299, 308 (1850), which upheld a retrospective provision because “[i]t [was] no more than the exercise of the legislative authority over the subject of remediesf, a] power which the legislative may unquestionably exercise at pleasure in relation to past as well as future contracts.” We looked also to WSSC v. Riverdale Fire Co., 308 Md. 556, 564, 520 A.2d 1319, 1323 (1987), in which we observed that “a statute governing [only] procedure or remedy will be applied to [all] cases,” whether they be “accrued, pending or future.... ” WSSC, 308 Md. at 563 n. 2, 564, 520 A.2d at 1323. In addition, we invoked Allen v. Dovell, 193 Md. 359, 363, 66 A.2d 795, 797 (1949), which acknowledged that “[i]t is thoroughly understood that a statute of limitations, which does not destroy a substantial right, but simply affects remedy, does not destroy or impair vested rights.”
We expressed some reservations in Dua regarding the distinction between remedy and substantive right, but, in the process, strengthened further the ultimate holding that the Legislature may change, under many circumstances, the former with retrospective effect, but not the latter. In particular, we quoted from State, use of Isaac v. Jones, 21 Md. 432, 437 (1864) for the contention that the “ ‘abrogation or suspension of a remedy, necessary to enforce the obligation of an existing contract, ... is void.’ ” Duet, 370 Md. at 635, 805 A.2d at 1079 (emphasis added). We relied on Allen, 193 Md. at 363-64, 66 A.2d at 797 to underscore that by “cut[ting] off all remedy ... in such a way as to preclude any opportunity to bring suit,” the Legislature “deprive [s improperly] a party of his [accrued] cause of action----” (Emphasis added.) In *517these and other cases, we recognized that the Legislature may legislate retrospectively, as long as the effect does not cut off all remedy. Contrary to this principle, the Majority concludes that the Maryland Constitution protects not only a plaintiffs accrued right to bring a cause of action, but also his or her associated prospect of recovering an amount of as-of-yet unidentified, uncertain, and unawarded damages. See Majority op. at 486-87, 19 A.3d at 881.
B. Dua.
The Majority opinion relies heavily on Dua to bolster its conclusion that the Maryland Constitution protects against the legislative impairment of the recovery of any amount of damages associated with causes of action. See id. It seizes upon the Dua Court’s description of the statute there as one that abrogates the plaintiffs’ rights to “particular sum[s] of money....” Dua, 370 Md. at 642, 805 A.2d at 1083. Seemingly, the Majority opinion equates “particular sum[s] of money” with the unliquidated damages claims Longtin sought at the time the Legislature amended the damages cap in the LGTCA. The Majority does so wrongly.13
*518In Dua, we confronted consolidated cases where two plaintiffs sought to recover “particular sum[s] of money” already paid to two creditors. When the plaintiffs made the payments, however, the creditors did not have a right to demand or receive the money. Dua, 370 Md. at 611-16, 805 A.2d at 1066-68. In a sense, then, the plaintiffs were pursuing replevin-type actions to recover wrongfully relinquished and unreturned liquidated amounts of money, ie., property.
Subsequent to the wrongful payments, the Legislature passed laws purporting to grant to those creditors retrospectively a right to the money. The Legislature was not limiting, however, the amount of damages the aggrieved plaintiffs could recover from the creditors, over and above their already-paid sums of money. Rather, it purported to ehminate the heart of the dispute—the plaintiffs’ right to brings claims to recover their already-paid, known sums. It was, in other words, “taking the [property] of one man, held [previously] by a good legal title,” ie., the money paid by the plaintiffs, “and giving it to another, who the law has said had none,” ie., the creditors. Thistle, 10 Md. at 145.
In the present case, the heart of the dispute was the underlying torts of false arrest/imprisonment, malicious prosecution, etc. By limiting, through the LGTCA, the amount of possible damages Longtin could recover, the Legislature was not affecting his ability to bring and pursue his claims in the first instance. As we stated in a related context, punitive damages:
[T]he limitation upon recoverable noneconomic tort damages under § 11-108 of the Courts and Judicial Proceedings Article does not amount to a restriction upon access to the courts.... The plaintiffs’ cause of action based on negligence was not abolished by § 11-108. Instead, § 11-108 *519simply modifies the law of damages to be applied in tort cases.
Murphy v. Edmonds, 325 Md. 342, 366, 601 A.2d 102, 114 (1992) (emphasis added).14
C. Does the LGTCA Damages Cap Vitiate Effectively a Substantive Right?
Having concluded that the Legislature may limit retrospectively the amount of damages to some extent and under certain circumstances, I now ask (rhetorically) whether the LGTCA damages cap limits recovery effectively “in such a way as to preclude any opportunity to bring suit____” Allen, 193 Md. at 363-64, 66 A.2d at 797. By enacting the $200,000/ $500,000 LGTCA damages limit, I conclude that the Legislature did not so transform plaintiffs’ substantive rights.
Prior to the LGTCA, local governments (but not their officers or employees) enjoyed immunity against most non-constitutional tort claims. See Housing Auth. v. Bennett, 359 Md. 356, 359-60, 754 A.2d 367, 368-69 (2000). Through the LGTCA, the Legislature altered the common law, giving plaintiffs limited access to the often sizable assets of local government, which must satisfy the awards returned by juries. Ashton, 339 Md. at 107-08, 660 A.2d at 465-66 (stating that the Legislature, through the LGTCA, provided “a remedy for those injured by local government officers ..., while ensuring that the financial burden ... is carried by the [ultimately responsible] local government”). In the process, it encour*520aged coincidentally local governments to better train their officers and employees. To mitigate the budgetary impact of this statutory sea change, the Legislature also limited the amount that plaintiffs could recover. See Murphy v. Edmonds, 325 Md. at 370, 601 A.2d at 115-16 (holding that “the Legislature did not act arbitrarily in enacting” a $350,000 cap on noneconomic damages in personal injury actions, as it possessed “several studies which concluded that $250,000 would cover most noneconomic damage claims”); Gooslin v. State, 132 Md.App. 290, 296, 752 A.2d 642, 645 (2000), cert. denied, 359 Md. 334, 753 A.2d 1031 (2000) (finding constitutional the Maryland Tort Claims Act, Maryland Code (1984, 2009 Repl. Vol) State Government Article, §§ 12-101 et. seq., because the $50,000 waiver represented the level at which the Legislature chose to waive governmental immunity). The $200,000/$500,000 damages cap was a reasonable, rational, and constitutional balancing. Indeed, it may well have been a necessary prerequisite to the passage of the LGTCA.
D. May a Statutory Damages Cap Apply to an Award for Successful Constitutional Tort Claims?
Because the Legislature is permitted to cap damages recovery retrospectively and because the LGTCA cap is not so unduly low as to equate with cutting off all remedy, the damages cap should apply to the jury award in the present case. The fact that Longtin brought and proved constitutional tort violations does not dictate a different result under the Maryland Constitution or the legislative history of the LGTCA.
At common law (that is, before the LGTCA), a plaintiff could bring a constitutional tort claim directly against local government officers and employees, as well as their employers—the local governments. After the passage of the LGTCA, a plaintiff lost, however, his/her/its ability to recover from the officers and employees, provided those tortfeasors acted within the scope of employment. The LGTCA restriction on liability ultimately applies to constitutional and non-*521constitutional tort claims alike, such that a plaintiff bringing a constitutional claim may recover only from the employing-local government. See DiPino v. Davis, 354 Md. 18, 52, 729 A.2d 354, 371 (1999) (“[LJocal governmental entities do, indeed, have respondeat superior liability for civil damages resulting from State Constitutional violations committed by their agents and employees within the scope of the employment.”); Ashton, 339 Md. at 108 n. 19, 660 A.2d at 465 n. 19 (“[T]here is no exception in the [LGTCA] for constitutional torts.... [T]he local government is required to pay the judgment against the employee .... ”); see also Lee v. Cline, 384 Md. 245, 256, 863 A.2d 297, 304 (2004) (holding that the Maryland Tort Claims Act applies to constitutional and non-constitutional torts, such that the State steps into the shoes of public officials for purposes of liability).
Moreover, we recognize, at least implicitly, that the LGTCA procedural requirements (e.g., notice) apply also to constitutional tort claims. Ashton, 339 Md. at 108 n. 19, 660 A.2d at 465 n. 19 (“[Although] there is no exception in the [LGTCA] for constitutional torts[,] .... [t]he parties in this case[, who raised constitutional and non-constitutional claims,] would appear to have waived [its] procedural requirements.”); see also Gonzalez v. Cecil County, 221 F.Supp.2d 611, 615-16 (D.Md.2002) (dismissing state constitutional tort claims because plaintiffs did not comply with the LGTCA notice requirement). The Court of Special Appeals has applied the notice requirement to constitutional tort claims in at least three cases. See Wilbon v. Hunsicker, 172 Md.App. 181, 913 A.2d 678 (2006) cert. denied 398 Md. 316, 920 A.2d 1060 (2007); White v. Prince George’s County, 163 Md.App. 129, 877 A.2d 1129 (2005), cert. denied, 389 Md. 401, 885 A.2d 825 (2005); Chappells v. McCarter, 162 Md.App. 163, 873 A.2d 458 (2005).
We implied that the LGTCA damages cap should apply to constitutional claims. In Ashton, 339 Md. at 108 n. 19, 660 A.2d at 465 n. 19, we observed that “there is no exception in the [LGTCA] for constitutional torts.” Therefore, “[a]s long as the local government employee is acting in the scope of his employment and without malice, the local government is required to pay the judgment against the employee to the extent it represents compensatory damages, up to certain statutory *522limits.” Id. (emphasis added); see also Ashton, 339 Md. at 108, 660 A.2d at 466 (holding that “plaintiffs are entitled to a trial” for their constitutional tort claims and that “[a]ny judgment rendered should, under the [LGTCA], be paid by the City”) (emphasis added).
We also held relevantly that the cap on noneconomic damages in § 11-108 of the Courts and Judicial Proceedings Article applies to constitutional claims. Specifically, in Green v. N.B.S., Inc., 409 Md. 528, 544, 976 A.2d 279, 288 (2009), we agreed with the Court of Special Appeals that:
[Njothing in the legislative history [of § 11-108] suggests that the General Assembly even thought of the difference between actions claiming personal injury due to common law torts as opposed to causes of action claiming personal injury arising out of statutory or constitutional torts. And, when interpreting a statute, a court must presume that the legislature did not intend to make any alteration other than what is specified and plainly pronounced. Also, in light of the reasons for the original cap statute, and its amendment, it is impossible to believe that the legislature intended to narrow the statute in the way appellant suggests so that insurers would now have to cover non-economic damages awards that exceeded the cap so long as the personal injury action arose out of the violation of a statute or a constitutional provision.
(citation omitted) (emphasis added).
Regarding the damages cap provided by the Maryland Tort Claims Act, we observed in Benson v. State, 389 Md. 615, 628, 887 A.2d 525, 532 (2005), that not “all constitutional tort claims must [necessarily] comply with the ... MTCA.” We reasoned thus, however, because the constitutional provision at issue— Article 14 of the Maryland Declaration of Rights—was not “compensable in monetary damages.” Id. Presumably, therefore, constitutional violations that are compensable in monetary damages are governed by the MTCA.15
*523In sum, I would hold that good cause existed to waive Longtin’s failure to comply strictly with the LGTCA notice requirement. I would conclude also that the LGTCA damages cap limits Longtin’s overall recovery. In all other respects, I agree with the Majority opinion.
Judge BARBERA authorizes me to state that she joins the views expressed in this concurring and dissenting opinion.
. Longtin advanced the following counts in his civil complaint: (1) violation of Article 21 of the Maryland Declaration of Rights, (2) violation of Article 24 of the Maryland Declaration of Rights, (3) false arrest; (4) false imprisonment, (5) malicious prosecution, (6) intentional infliction of emotional distress, (7) invasion of privacy/false light, (8) pattern or practice of improper conduct, (9) intentional misrepresentation, (10) negligent detention, (11) civil conspiracy, (12) a request for declaratory judgment, and (13) negligence.
. Before proceeding, I pause to note that neither the Court of Special Appeals nor the Majority opinion in this Court address Longtin's *502argument that the County’s notice contentions are "effectively not reviewable.” Longtin observes that the County protested in the Circuit Court his failure to provide timely notice only in a motion for summary judgment, which the trial court denied. In Metropolitan Mortgage Fund, Inc. v. Basiliko, 288 Md. 25, 29, 415 A.2d 582 (1980), we held that the "denial ... of a summary judgment motion ... involves ... an exercise of discretion .... and ... absent clear abuse ... the manner in which this discretion is exercised will not be disturbed.” Because no appellate court deigned to bestow scrutiny on this point, I shall confine my solitary views to the merits of the notice contentions decided actually.
. The two legal concepts—statutes of limitations and notice requirements—are quite different and ordinarily one should not be used as persuasive evidence in our construction of the other. Rios v. Montgomery County, 386 Md. 104, 139, 872 A.2d 1, 21 (2005) ("The notice provision of the LGTCA is a condition precedent to the right of action; limitations statutes create defenses. The focus of the two, i.e., notice vis á vis limitations, is very different.”); see also White v. Prince George’s County, 163 Md.App. 129, 144, 877 A.2d 1129, 1137 (2005) cert. denied, 389 Md. 401, 885 A.2d 825 (2005) ("The notice requirement operates independent of the limitations period that applies generally to the filing of suit. Serving timely notice is essential to preserve a claimant's right to file suit at any time during the limitations period. In contrast to the tolling of limitations, nothing in the LGTCA expressly provides for tolling the notice period.”); Simon v. United States, 244 F.2d 703, 704-05 (5th Cir.1957) (declining to extend an "exception[] to the operation of a statute of limitations” to the notice of claims provision in the Federal Tort Claims Act ("FTCA”) because "[a] statute of limitations should be differentiated from conditions which are annexed to a right of action created by statute. A statute which in itself creates a new liability, gives an action to enforce it unknown to the common law, and fixes the time within which that action may be commenced, is not a statute of limitations.... Such a provision will control, no matter in what form the action is brought”) (internal quotation marks and citation omitted); 3-14 Jayson & Longstreth, Handling Federal Tort Claims § 14.01 (2007) (observing that "the Supreme Court adopted [Simon in United States v. Kubrick, 444 U.S. 111, 100 S.Ct. 352, 62 L.Ed.2d 259 (1979)]”); id. ("The characterization of the FTCA's time limitation as a substantive condition of the *504United States’ waiver of immunity, and therefore a jurisdictional prerequisite to recovery rather than a true statute of limitations, has been almost universally applied by the courts.”); Felder v. Casey, 487 U.S. 131, 140, 108 S.Ct. 2302, 2308, 101 L.Ed.2d 123, 139 (1988) (distinguishing sharply between statutes of limitations and the notice-of-claim provisions on the grounds that the former are "universally familiar aspects of litigation considered indispensable to any scheme of justice,” whereas the latter "are neither universally familiar nor in any sense indispensable prerequisites to litigation,” though they may "significantly inhibit the ability to bring federal actions”) (internal quotation marks and citation omitted).
. The Majority opinion assails this conclusion on the grounds that the common law provides an exception for false arrest and imprisonment claims to the general rule that "a claim accrues when the legal elements materialize.” Majority op. at 476, , 19 A.3d at 875 n. 18. The Majority opinion looks to Wallace v. Kato, 549 U.S. 384, 388-89, 127 S.Ct. 1091, 1095, 166 L.Ed.2d 973 (2007), for the contention that:
There is, however, a refinement to be considered, arising from the common law’s distinctive treatment of the torts of false arrest and false imprisonment----The running of the statute of limitations on false imprisonment is subject to a distinctive rule—dictated, perhaps, by the reality that the victim may not be able to sue while he is still imprisoned: "Limitations begin to run against an action for false imprisonment when the alleged false imprisonment ends.” 2 H. Wood, Limitation of Actions § 187d(4), p 878 (rev. 4th ed.1916); see also 4 Restatement (Second) of Torts § 899, Comment c (1977); A. Underhill, Principles of Law of Torts 202 (1881). Thus, to determine the beginning of the limitations period in this case, we must determine when petitioner’s false imprisonment came to an end.
My reading of this language leads me to conclude that the Supreme Court did not hold that the common law provides an exception, for the *505torts of false arrest and imprisonment, to the general rule that "a claim accrues when the legal elements materialize.” Rather, it held that the common law provides an exception to the general rule that “[l ]imitations begin to run against an action” when the legal elements materialize. After making this point, the Supreme Court cited three sources— § 187d(4) of Limitations of Actions, comment c of the Restatement (Second) of Torts, and page 202 of Principles of Law of Torts—all of which concern statutes of limitation, not notice provisions.
The Majority opinion concedes that “[n]ot every contour of limitations jurisprudence is applicable to the LGTCA[] notice requirement!],” Majority op. at 475, 19 A.3d at 874 n. 17, and that the policies behind statutes of limitation and notice provisions “are not perfectly convergent,” merely similar. Majority op. at 475, 19 A.3d at 874. I agree, as mentioned in footnote 3, supra. These two legal concepts and the long line of relevant, interpretive Maryland caselaw relating thereto should be respected, rather than collapsed into one. By holding that some, but not all "contour[s] of limitations jurisprudence” apply to the LGTCA notice provision, the Majority opinion invites a host of future litigation from parties trying to understand, reasonably so, just where that line is drawn. Shortcuts have consequences.
. For purposes of ratification only, I extend the analysis (explained infra) to one other cause of action pleaded by Longtin, invasion of *506privacy. To prove false light invasion of privacy, a plaintiff must show that the defendant "intentionally intrude[d], physically or otherwise, upon the ... seclusion of another or his private affairs or concerns ... [in a way that] would be highly offensive to a reasonable person.” Bailer v. Erie Ins. Exch., 344 Md. 515, 526, 687 A.2d 1375, 1380-81 (1997) (internal quotation marks and citation omitted). In the case sub judice, Longtin alleged that the police placed him in a false light by making false representations, via "public statements, public documents and public press releases .... ”
The crux of Longtin's claim in this regard, as the Majority opinion acknowledges, was the statement of probable cause. See Majority op. at 482, 19 A.3d at 878 ("Longtin’s false light claim arises from the assertions contained in the Statement of Probable Cause.”). As such, the claim's accrual date should be the date of publication of the statement—7 October 1999. Even if we held that (1) the continuing harm rule applies in the context of notice requirements, as opposed to statutes of limitation—its legal field of origin—and (2) the press releases, issued after the statement of probable cause, constituted "continuing harm,” the accrual date should be the latter’s publication, not the date of Longtin's release from custody. See MacBride v. Pishvaian, 402 Md. 572, 584, 937 A.2d 233, 240 (2007) ("Under th[e continuing harm] theory, violations that are continuing in nature are not barred by the statute of limitations merely because one or more of them occurred earlier in time.”) (citation omitted).
. Although Dett involved a case of mistaken identity—a motorist was stopped and arrested under an open warrant pertaining to another individual—its conclusions regarding the possibility of legal justification waning in false arresVimprisonment tort actions are applicable broadly. See State v. Dett, 391 Md. 81, 891 A.2d 1113 (2006).
. One may claim, as the police did, that Longtin was not “arrested” until after the interrogation. Longtin came to the police station and gave a statement voluntarily, or so the argument went. Indeed, during the early stages of the criminal prosecution against Longtin, a trial judge—considering the facts and arguments offered—found that Long-tin acted voluntarily before and during the interrogation; therefore, the police did not need to “Mirandize” him and his statement was admissible. This does not impact the substance of my analysis—although the police possessed probable cause at one time, it dissipated over time.
On the other hand, one may argue that Longtin was “arrested” at 12:40 p.m., when a police cruiser commenced driving Longtin to the police department. Longtin argues that, during the entire incident, he was acting against his will. At the civil trial, however, conflicting evidence was adduced as to whether Longtin accompanied the police officer involuntarily or voluntarily. Testimony suggested that at some point during the interrogation, police took Longtin’s belt, wallet, shoelaces, and cell phone—indicators of custody. Thus, 1:30 p.m. seems to *508be a better settling point as to the time of arrest or perhaps 2:30 p.m., when records reflect someone (perhaps Longtin) last used Longtin’s cell phone.
If Longtin was "arrested” at the crime scene, we may say simply that his false arrest/imprisonment causes of action accrued then, as police did not have probable cause at that moment—according to Detective Herndon’s notes, the telephone call with the Charles County Sheriff's Office did not occur until 12:45 p.m., 5 minutes after Longtin was detained initially.
. During the interrogation, but extrinsic to the questioning of Longtin, Detective Herndon learned that, on the day before the murder, Longtin engaged the victim in a heated, public argument. He learned also that allegedly Longtin once choked a female at the local gym.
. During the civil proceedings, it was taken as a foregone conclusion that the police knew the victim had been raped. She was discovered with her pants and underwear at her feet. After the murder, the detectives became aware that another neighbor had reported an at*509tempted rape in the same vicinity and provided a description that did not match Longtin's appearance. The application for the statement of charges against the actual killer, Antonio Oesby, stated that the victim “appeared to have been ... sexually assaulted,” and the statement of charges included first degree rape. Moreover, to retrieve the DNA from the victim, the police employed presumably a rape kit.
. The police took a specimen of Longtin's DNA on 5 October 1999, the day of the interrogation. The police lab tested the DNA against the vaginal swab in February 2000. This was not an unreasonable period of time. Unreasonable delay, however, might provide additional good cause for a waiver of strict adherence to the LGTCA notice requirement.
. The Majority opinion suggests that this analysis "would create perverse policy incentives for the State,” for, under the " 'date of dissipation’ rule ... the State is rewarded for keeping a prisoner after it has lost its legal justification for doing so.” Majority op. at 477, 19 A.3d at 875 n. 19. “If the State continues the false imprisonment past that point, the clock continues to run on the prisoner's notice period, and it is less likely that the prisoner will file timely notice.” Id.
Instead of focusing on that which is most likely, the Majority opinion becomes preoccupied by that which is least likely. The "date of dissipation” approach provides the State with a strong and undeniable incentive to release a prisoner the moment probable cause has dissipated—by doing so, the State prevents a critical element in the torts of false arrest and imprisonment from materializing, namely, detention "without legal justification.” As a result, the State eliminates the possibility of an action being filed against it for false arrest or imprisonment—an adequate incentive, I think. Moreover, the longer the State holds a prisoner beyond the "date of dissipation,” the more good cause exists for waiver of strict compliance with the notice requirement.
. The Majority opinion perceives that this analysis "causes more problems than it solves.” Majority op. at 476, 19 A.3d at 876 n. 20. It avers that identifying the " ‘date of dissipation’ ... is a fact-intensive issue, requiring weighing of evidence that is inappropriate for an appellate court.” Id. Moreover, the Majority predicts that ascertaining any such date "will be heavily disputed by the State....” Id. The Majority opinion describes my conclusion of February 2000 for the "date of dissipation” in the present case as "[tjroublingly” because I "resolved ... disputed factual issues in a way unfavorable to Longtin, who was victorious at trial.” Id. (quoting Hoffman v. Stamper, 385 Md. 1, 10, 867 A.2d 276, 282 (2005), for the proposition that "[w]e must view that evidence in a light most favorable to the part(ies) who *510prevailed on the issues to which it relates”). "The [concurrence] has disregarded our standard of review and attempted to resolve contested factual issues in a manner contrary to the jury’s verdict.” Id.
The Majority’s argument highlights the frequent division between advocates and critics of bright line legal tests. While bright lines have their virtues, such as ease of application, they should not be deployed merely for convenience; they must be consistent with the law. Here, the Majority creates a bright line from whole cloth, while endeavoring unpersuasively to distinguish contrary controlling caselaw.
I am unpersuaded by the Majority's critique of the procedural burden of my analytical approach. Our state trial courts demonstrate, on a daily basis, the capacity to tackle a myriad of "fact-intensive issue[s]”— even those that are "heavily disputed by the State....” Indeed, the Maryland Civil Pattern Jury Instructions include, for use in false arrest and imprisonment cases, an instruction for probable cause. Although I engaged in a probable cause analysis supra, as the DNA tests and associated dates were uncontested, such an inquiry is best left, in most instances, to the trial courts. Regarding the standard of review—and notwithstanding the fact that this concurrence agrees Longtin should have been able to pursue his claims—I observe only that our charge to "view th[e] evidence in a light most favorable to the [prevailing] partly]” does not compel appellate courts to reach otherwise incorrect conclusions of law.
. It is a bit unclear what exactly the Majority opinion holds on this issue. It seems to state that the Legislature is prevented from reducing retrospectively any particular sum of money. It suggests also, however, that the Legislature is prevented only from so reducing "significantly” sums of damages. Compare Majority op. at 488-89, 19 A.3d at 882 (quoting favorably the Florida Supreme Court, in Kaisner v. Kolb, 543 So.2d 732, 739 (Fla.1989), for the proposition the Legislature may not impair even partially the amount of recovery) with id. at 488-90, 19 A.3d at 882-83 (quoting favorably Allstate Ins. Co. v. Kim, 376 Md. 276, 296, 829 A.2d 611, 622 (2003), for the proposition that "the standard for determining whether retroactive legislation violates ... the Maryland Constitution is whether it abrogates or significantly impairs Vested rights' "), and Majority op. at 489, 19 A.3d at 883 ("It is patent that the enormous loss to Longtin from application of the statutory cap would 'impair' his cause of action.”) (emphasis added).
By holding (possibly) that a retrospective damages cap is unconstitutional when it caps "significantly” impairs an ad damum claim and/or resultant verdict, the Majority opinion sidesteps a difficult question. Assuming the ability to obtain a verdict to some amount of damages constitutes a protected "vested right” (a suggestion with which I disagree), is any retrospective cap constitutional? If so, we should then address whether the LGTCA $200,000/$500,000 limit—taken in iso*518lation—is appropriate constitutionally. Instead, the Majority opinion implies that a retrospective damages cap becomes more or less valid, depending on the size of the trial award. Such an oscillating approach is inconsistent with our State Constitution, caselaw, and commonsense.
. In Part II.A-B, supra, I conclude that, although the Maryland Constitution protects only a plaintiffs right to bring an accrued cause of action, his or her ability to recover unliquidated (i.e., not yet determined or awarded) damages is not protected quite so sweepingly. The Majority opinion is unfazed by the fact that there was "no 'particular' sum” to which Longtin was entitled "when the statute was changed!.]” Id. at 488, 19 A.3d at 882. In Cooper v. Wicomico County, 284 Md. 576, 584, 398 A.2d 1237, 1241 (1979), however, we highlighted the important distinction between constitutionally-protected liquidated sums and unprotected unliquidated sums. We stated that the Legislature may not alter retrospectively the amount of workers’ compensation an employer already had to pay an employee. See Cooper, 284 Md. at 582-83, 398 A.2d 1237. The employer’s monetary obligation was not *520"speculative,” but was known and vested. Cooper, 284 Md. at 584, 398 A.2d at 1241.
. Longtin argues there is another reason why the LGTCA damages cap should not apply. The LGTCA provides that an "employee shall be fully *523liable for all damages awarded in an action in which it is found that the employee acted with actual malice.” "In such circumstances, the Rule continues, ‘the judgement may be executed against the employee and the local government may seek indemnification for any sums it is required to pay....’” Maryland Code (1974, 2006 Repl.Vol.), Courts and Judicial Proceedings Article, § 5-302(b)(2)(i)-(ii); see also Housing Auth. v. Bennett, 359 Md. 356, 361, 754 A.2d 367, 370 (2000) (same).
The jury found here that all of the employees-defendants acted with actual malice. After ruling that "there was insufficient evidence of actual malice to submit the issue to the jury as to Detectives Harding, Frankenfield and Clerk,” the trial judge, in his post-verdict rulings, found nonetheless that Detective Herdon acted with actual malice. The trial court, however, reduced Detective Herdon's personal judgment from S350,000 to $50,000, after considering various mitigating factors. See Prince George’s County v. Longtin, 190 Md.App. 97, 143 n. 60, 988 A.2d 20, 47 n. 60 (2010). According to Longtin, under § 5-302(b)(i)-(ii), Detective Herdon should pay not only his $50,000 judgment, but also the $5 million judgment against Prince George’s County. Neither the trial court nor the Court of Special Appeals confronted this issue. Moreover, we did not grant certiorari on this precise question. I suspect this question may need to get sorted-out as efforts to collect the award proceeds.