The Zimmer-Rubert court also expressed its view that the waiver contained within Md.Code Ann., Cts. & Jud. Proc. § 5-518(c) extended to the board of education’s Eleventh Amendment immunity. Id. at 242-43; see also, id. at 241 n. 6 (acknowledging the potential conflict between Eleventh Amendment immunity in federal court and common law principles of sovereign immunity in state court, but deciding that “[the court] need not resolve that conflict in this case, for [the court] conclude[s] that the plain language of § 5-518(c) of the Court and Judicial Proceedings Article waives the Board’s governmental immunity, including its Eleventh Amendment immunity, to claims for $100,000 or less”); but see, BEKA Indus., Inc. v. Worcester Cnty. Bd. of Educ., 419 Md. 194, 18 A.3d 890, 907 (2011) (<HOLDING>) (internal quotations omitted). Federal courts
holding that a defamation claim is a personal injury tort claim holding that claims under 42 usc  1983 are not personal injury tort claims holding that a negligence claim is not a personal injury tort claim holding that zimmerrubert did not extend to contract claims against a county board of education because zimmerrubert only addressed the applicability of  5518 to a tort or insurable claim such as those for personal injury and for claims arising from alleged employment law violations holding that the tucker acts waiver of sovereign immunity for contract claims does not extend to claims for contracts implied in law