Justia Maryland Supreme Court Opinion Summaries

Articles Posted in Injury Law
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Dozens of Jacksonville, Maryland households (Respondents) brought suit against Exxon Mobil Corporation for damages from an underground gasoline leak from an Exxon-owned gasoline service station that leaked approximately 26,000 gallons into the underground aquifer and contaminated wells supplying water to a number of households. Respondents sought compensatory and punitive damages based on allegations of fraudulent concealment, strict liability, trespass, punitive nuisance, and negligence. The jury returned a verdict in favor of Exxon with respect to the fraudulent concealment and punitive damages claims but found in favor of Respondents as to all other claims for compensatory damages. Exxon appealed, challenging the sufficiency of the evidence supporting the awards for complete diminution of property value, damages for emotional distress, and damages for future medical monitoring costs. The court of special appeals affirmed in part and reversed in part, reducing the $147 million in damages awarded to Respondents by more than half. The Court of Appeals reversed the judgments in favor of Respondents for diminution in property value, emotional distress, and medical monitoring, holding that the evidence was insufficient to support to the awards for these claims. Remanded. View "Exxon Mobil Corp. v. Ford" on Justia Law

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In 2006, Exxon Mobil Corporation reported a leak of approximately 26,000 gallons of gasoline from the underground tanks at its fueling station in Jacksonville, Maryland. Hundreds of residents and business proprietors of Jacksonville (Appellees) subsequently filed suit against Exxon for damages stemming from the contamination of their water supply, other consequential effects, and alleged misrepresentations by Exxon. The jury awarded $496,210,570 in compensatory damages and $1,045,550,000 in punitive damages for Appellees. Exxon appealed both damages awards as to all recovering Appellees. The Court of Appeals (1) reversed the judgments in favor of all Appellees for fraud, emotional distress for fear of contracting cancer, medical monitoring, and emotional distress for fear of loss of property value, holding that Appellees did not prove by clear and convincing evidence Exxon's liability as to these claims; and (2) reversed the judgments for loss of use and enjoyment and for diminution in value of real property in favor of certain Appellees and affirmed as to the others. View "Exxon Mobil Corp. v. Albright" on Justia Law

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Insured was injured in an accident. Insured's policy with Insurer included uninsured motorist (UM) bodily injury coverage and personal injury protection (PIP) coverage. Insured's Employer's third-party workers' compensation (WC) administrator asserted a subrogation right against any PIP or UM recovery by Insured. At issue in this case was the correct interpretation of Md. Code Ins. 19-513. The district court asked the Court of Appeals to determine whether section 19-513(e) requires an insurance company to deduct WC benefits payable to an insured for UM and PIP when the insured has not reimbursed its provider and the insured intends to reimburse the WC provider in the future. The Court of Appeals held (1) under the plain meaning of section 19-513(e), an insured's benefits payable under UM and PIP coverage shall be reduced to the extent that the insured recovered benefits under WC and the WC provider has not been reimbursed; and (2) if the applicable workers' compensation law treats "write-downs" of medical bills as WC benefits, and the WC benefits have not been reimbursed, then the insurer shall deduct those benefits, calculated as discounts, from its benefits payable to the insured under section 19-513(e). View "Travco Ins. Co. v. Williams" on Justia Law

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In 1982, two elderly widows (the Millers) sold land to one party. Four years later, the Millers purported to sell the same land to Petitioner (the Partnership). The Partnership engaged two title companies (the Title Companies) to complete the title work, and the Title Companies failed to locate and report the Millers' first land sale. Chicago Title Insurance Company (Chicago Title) underwrote the insurance policies on the land. These transactions led to numerous lawsuits. At issue in this appeal was (1) whether a title company owes a duty of care when conducting a title search; and (2) whether a title insurance company may be held vicariously liable as a result of the title company's negligent title search. The Court of Appeals held (1) the Title Companies owed a duty of care to the Partnership in conducting the title search and issuing the title commitment; and (2) under the circumstances, Chicago Title may not be held vicariously liable for the Title Companies' negligence. View "100 Investment Ltd. P'ship v. Columbia Town Ctr. Title" on Justia Law

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Respondent was injured while performing his job as a school police officer in Baltimore City. After the City terminated his employment, Respondent applied for line-of-duty disability retirement. A hearing examiner denied Respondent's application, concluding that Respondent did not satisfy the eligibility requirements of Baltimore, Md., Code 22, 9(j), which requires a claimant to prove he sustained at least a fifty percent total impairment as the direct result of a line-of-duty accident. The hearing examiner concluded that Respondent did not satisfy the statutory requirements because the impairment to Respondent's back was not independent of all other causes, reasoning that Respondent's degenerative disc disease contributed to the disability of his back. The circuit court reversed, and the court of special appeals affirmed. The Court of Appeals affirmed, holding that Respondent's preexisting condition did not preclude him from qualifying for line-of-duty disability retirement because he proved that fifty percent of his total level of disability was the direct result of the injury he sustained while performing in the line of duty. View "Employees' Ret. Sys. of City of Baltimore v. Dorsey" on Justia Law

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These petitions for certiorari pertained to contribution among joint tort-feasors and arose from a medical malpractice action in which Petitioners, the Spences, alleged wrongful death and survival claims against Petitioner Mercy Medical Center and Respondents, a medical doctor and his practices. The issue of contribution arose because the Spences and Mercy entered into a pre-trial settlement by which the Spences agreed to dismiss their claims against Mercy without exacting an admission of liability. After Mercy was dismissed as a party, the case proceeded to trial against Respondents, which resulted in a verdict in favor of the Spences. Respondents subsequently initiated a separate action against Mercy seeking contribution. The Spences contemporaneously brought suit against Respondents seeking a declaration that Respondents were not entitled to contribution. At issue before the Court of Appeals was whether the Spences' release extinguished any right Respondents had to seek contribution against Mercy because Respondents did not join Mercy as a third party defendant in the original action after it was dismissed as a party. The Court of Appeals held that Respondents were not prohibited from pursuing contribution from Mercy in a separate action because the release's conditional language did not fully relieve Mercy's contribution liability. View "Mercy Med. Ctr. v. Julian" on Justia Law

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This consolidated opinion resolved two cases heard by the Court of Appeals concerning the appropriate scope of the Washington Metropolitan Area Transit Authority's (WMATA) immunity from suit. In both cases, Veronica Tinsley and Kim Hodge, Petitioners, slipped, fell, and were injured at WMATA operated metrorail stations. Petitioners presented a common question of whether their claims were barred by Section 80 of the WMATA Compact, and Hodge presented an additional question of whether Section 75 of the Compact limited the scope of WMATA's immunity, such that its alleged failure to abide by various County code sections rendered an immunity defense unavailable. The Court upheld WMATA's immunity from suit, concluding (1) WMATA was immune because its underlying decision regarding proper maintenance procedures was grounded in concerns of economic and public policy; and (2) Hodge's contention that Section 75 waived WMATA's immunity in her case was without merit. View "Tinsley v. Washington Metro. Area Transit Auth." on Justia Law

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Respondent entered a gas station owned and operated by Petitioner, where she mis-stepped on even ground and twisted her knee. Respondent subsequently filed a negligence suit against Petitioner. The trial court denied Petitioner's request to include on the special verdict sheet a question specifically addressing the assumption of risk defense and thereafter entered judgment in favor of Respondent. The court of special appeals affirmed. The Court of Appeals reversed, holding that the trial court's failure to adequately present assumption of the risk constituted error because Petitioner had a right to present the defense to the jury, and that error prejudiced Petitioner's case. Remanded for a new trial. View "S&S Oil, Inc. v. Jackson" on Justia Law

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Respondent sustained six injuries while playing for the Washington Redskins on four separate occasions. Consequently, Respondent filed with the Maryland Workers Compensation Commission six separate claims against his employer, the Washington Redskins (Petitioner). The Commission denied five of Respondent's claims on the ground that he was not a "covered employee" because he was working for the Redskins outside of the State when he sustained the injuries underlying the claims. The circuit court affirmed. The court of special appeals reversed. The Court of Appeals affirmed, holding that a football player employed by the Washington Redskins is a "covered employee," and therefore entitled to avail himself of Maryland's workers' compensation laws, when injured while practicing and playing football outside of Maryland. View "Pro-Football, Inc. v. McCants" on Justia Law

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This case involved a claim by a former professional football player (the athlete) for benefits under the Maryland Workers' Compensation Act based on an injury during pre-game warm-up at the employer's stadium in Maryland. The employment agreement contained a forum selection clause providing, inter alia, that claims for workers' compensation benefits should be governed by Virginia law and that the Virginia Workers' Compensation Commission should have exclusive jurisdiction to resolve such claims. The Maryland Workers' Compensation Commission decided that it could properly exercise jurisdiction over the athlete's claim, that the athlete had sustained an accidental injury arising out of the course of his employment, and that the athlete's disability was causally related to his accidental injury. The circuit court upheld the decision. The court of special appeals affirmed. The Court of Appeals affirmed, holding (1) the forum selection clause in the employment contract was ineffective to divest the Commission of the ability to exercise jurisdiction; and (2) injuries occurring while playing and practicing professional football are accidental injuries and thus compensable under the Act. View "Pro-Football, Inc. v. Tupa" on Justia Law