Moonlighting has long been described as the practice of holding a second job, often at night. In the law enforcement community, moonlighting evolved into secondary employment, meaning the private employment of off-duty police officers in a number of capacities, but usually as security guards. Secondary employment became so ingrained in the law enforcement profession that in some states, by law, police agencies cannot prohibit it; they can only reasonably regulate it. The liability landscape in Maryland for secondary employment dramatically changed 10 years ago when the Maryland Court of Appeals decided the case Lovelace v. Anderson. Law enforcement agencies across the country can take important lessons from this case.