In McCullough v. Wittner, 314 Md. 602 (1989), an inmate brought a common law assault and battery action against a correctional officer. The circuit court granted the correctional officer's motion to dismiss the action on the ground that the inmate failed to file a grievance with the IGO and thus failed to exhaust his administrative remedies. Id. In the Court of Appeals, the inmate argued that the IGO did "not have jurisdiction over tort claims seeking damages for personal injuries." Id. at 606. The Court rejected that argument, reasoning, id. at 609: In light of the nature of McCullough's complaint, the necessity for invocation and exhaustion of administrative remedies could not have been more forcefully expressed in the statute. The General Assembly mandated that "no court shall entertain an inmate's grievance or complaint within the jurisdiction of the Inmate Grievance Commission unless and until" the inmate has invoked and exhausted his remedies before the Commission. Art. 41, 4-102.1(1). This sweeping language, delineating the need to invoke and exhaust the administrative remedy, is totally inconsistent with the notion that the Commission's jurisdiction over inmate grievances can be circumvented by the simple expedient of making a claim for money damages.