Justia Maryland Supreme Court Opinion Summaries

Respondent was injured in an automobile collision involving Norman Iglehart while both were acting within the scope of their employment with the Board of Education of Prince George's County. The workers' compensation commission awarded Respondent compensation. Subsequently, Respondent filed a complaint against Iglehart and the Board (collectively, Petitioners) seeking damages as a result of Iglehart's negligence and the respondeat superior liability of the Board. The trial judge dismissed the Board from the action but directed it remain a party for the purposes of potential indemnification of Iglehart required under Md. Code Ann. Cts. & Jud. Proc. 5-518(h). The judge then ordered that judgment be entered against Iglehart and the Board. The intermediate appellate court affirmed. The Court of Appeals affirmed, holding (1) section 5-519 contains an indemnification provision that allows an injured party to bring a tort suit against the county board of education employee who caused the injury, and accordingly, the injured party must join the employer board as a defendant in the action; and (2) this statutory scheme does not violate the exclusivity rule stating that an injured employee's sole remedy against her employer is through the Workers' Compensation Act. View "Bd. of Educ. v. Marks-Sloan" on Justia Law

Respondents, a county, city, village, and other government officials, established speed cameras that recorded, among others, Petitioners traveling in their vehicles over the posted speed limit. Respondents issued citations to Petitioners. Petitioners subsequently filed a complaint in the circuit court, asserting claims sounding in tort and seeking declaratory and injunctive relief. Petitioners asserted that Respondents' contracts with their common speed monitoring contract, ACS State and Local Solutions, violated Md. Code Ann. Transp. 21-809(j), which prohibited the county from remunerating, on a per-citation basis, a contractor who operates a speed monitoring system on the county's behalf. The circuit court granted Respondents' motions for summary judgment on all counts. The intermediate appellate court affirmed. The Court of Appeals affirmed but on different grounds, holding (1) section 21-809 does not provide an express or implied private cause of action in tort; and (2) Petitioners lacked the necessary taxpayer standing to pursue their injunctive and declaratory relief claims. View "Baker v. Montgomery Co." on Justia Law

Michael Barclay was injured in a collision with a car driven by Christopher Richardson, a longshoreman, who had fallen asleep at the wheel while traveling home after a twenty-two hour shift at his job site located at the Port of Baltimore. Barclay and his wife filed a complaint against several parties, including Richardson's employer, Ports America Baltimore, Inc., alleging that Ports was liable for Barclay's injuries under the theory of respondeat superior and primary negligence. The trial court granted summary judgment in favor of Ports, finding (1) respondeat superior was inapplicable because Richardson was not acting within the scope of his employment was commuting home from work; and (2) Ports could not be held primarily liable for the injuries because it owed no duty to the public to ensure that an employee was fit to drive his personal vehicle home. The court of special appeals affirmed. The Court of Appeals affirmed, holding (1) under the circumstances, Ports may not be held vicariously liable for Richardson's motor vehicle tort; and (2) Ports had no duty to Barclay based solely on the fact that Richardon's fatigue was a foreseeable consequence of the employment. View "Barclay v. Briscoe" on Justia Law

Appellant Angelia Anderson brought a medical malpractice action in the U.S. District Court against the United States under the Federal Tort Claims Act (FTCA). The FTCA contains a two-year statute of limitations regarding the timeliness of bringing claims against the government. However, if there is substantive law in the state where the claim arose governing the timeliness of a similar claim, the state provision controls over the FTCA's statute of limitations. A state statute of repose is considered substantive law and prevails over the procedural FTCA statute of limitations. The district court granted the government's motion to dismiss for lack of subject matter jursidiction. The Fourth Circuit Court of Appeals certified a question of law to the Maryland Supreme Court. At issue was whether Md. Code Ann. Cts. & Jud. Proc. 5-109(a)(1), which provides that the time period allowed for bringing a medical malpractice action is five years from the time the injury was committed, was a statute of limitation or a statute of repose. The Court held that the plain language of section 5-109(a)(1), confirmed by its legislative history, demonstrates that the statute is a statute of limitations, rather than repose. View "Anderson v. United States" on Justia Law

Decedent Elliott Multi died in March 2005. Plaintiffs were the widow of Decedent and the adult children of her marriage with Decedent. Plaintiffs filed a claim against the University of Maryland Medical Systems Corporation (Defendant), alleging medical malpractice and wrongful death. Defendant moved to dismiss the complaint for failure to join a necessary party, a stepson whom Decedent had adopted during a prior marriage. The circuit court dismissed Plaintiffs' wrongful death claims for failure to join the stepson as a "use" plaintiff. The Court of Appeals reversed, holding that, under the totality of the circumstances, the circuit court abused its discretion in dismissing Plaintiffs' wrongful death claims as a sanction for the omission of the stepson as a use plaintiff, as there was no basis for inferring that the stepson was omitted for the purpose of hiding the litigation from him or in the hope that Plaintiffs would increase their recovery. Remanded. View "Univ. of Md. Med. Sys. Corp. v. Muti" on Justia Law

Petitioners, a pair of adult children, sued Griffith Energy Services, an energy company that spilled heating oil in Petitioners' parents' home, and its attorneys for fraud and negligent supervision. Petitioners' parents (Parents) had previously sued Griffith and won a judgment after a jury trial. The circuit court dismissed Petitioners' lawsuit, holding, inter alia, that Petitioners' claims were barred by res judicata. The court of special appeals affirmed, reaching only the res judicata issue. The Court of Appeals affirmed, holding (1) Petitioners were in privity with Parents, and (2) thus, the intermediate appellate court did not err in holding that Petitioners' claim was barred by res judicata. View "Cochran v. Griffith Energy Servs., Inc." on Justia Law

A pit bull named Clifford escaped from its pen and attacked Dominic Solesky, a minor, who initially sustained life threatening injuries as a result of his mauling. Dominic's parents, as next friends of Dominic, sued Defendant landlord. The trial court granted judgment for Defendant, concluding that the evidence was insufficient to permit the issue of common law negligence to be presented to the jury. The court of special appeals reversed, finding that the evidence had been sufficient to create a valid jury issue as to the extent of Defendant's knowledge of Clifford's dangerousness with respect to the then common law standards in dog attack negligence cases. The Court of Appeals affirmed after modifying the Maryland common law of liability as it relates to attacks by pit bull dogs against humans, holding that when an owner, landlord, or other person who has the right to control the pit bull's presence on the subject premises knows, or has reason to know, that the dog is a pit bull or pit bull mix, that person is strictly liable for the damages caused to a plaintiff who is attacked by the dog on or from the owner's or lessor's premises. Remanded for a retrial. View "Tracey v. Solesky" on Justia Law

Lynne Swartzbaugh purchased motor vehicle insurance with Encompass Insurance Company. The policy named Lynne, her husband, and their daughter Kelly (Petitioners) as drivers. Lynne executed a waiver of higher uninsured motorist (UM) coverage on the standard Maryland Insurance Administration form. Immediately beneath the signature line below the waiver appeared the legend: "Signature of First Named Insured." By its terms, consistent with Maryland law, the waiver remained in effect until withdrawn, and the waiver was never withdrawn. Later, Kelly was injured in an accident involving an under-insured driver. Kelly was unable to collect further damages from Encompass under that policy's UM coverage. Petitioners sought a declaration that the waiver was ineffective because Lynne was not in fact the "first named insured" on the policy. The circuit court ruled that the waiver signed by Lynne was valid and enforceable. The court of special appeals affirmed. The Court of Appeals affirmed, holding that, in the context of a motor vehicle insurance policy, the phrase "first named insured" refers to a person insured under the policy and specifically named in the policy who acts on behalf of the other insured parties and is designated as "first named insured" in the policy documents. View "Swartzbaugh v. Encompass Ins. Co. of Am." on Justia Law

Respondents Wayne Singleton and his eight-year-old son were passengers in a bus when the bus left the road and collided with a tree. Respondents sued Petitioner, the District of Columbia, alleging that it was liable vicariously for the negligence of its assumed employee, the driver. Respondents produced at trial only themselves as witnesses and argued that res ipsa loquitur supplied an adequate inference of negligence to complete their prima facie case. The trial judge granted the District's motion for judgment. The Court of Appeals affirmed, holding that under the circumstances of this case, Respondents failed to show that they were entitled to an inference of negligence, as Respondents' evidence failed to demonstrate that negligence on the part of the bus driver was more probably than not the cause of the accident or to eliminate other potential causes of the accident. View "Dist. of Columbia v. Singleton" on Justia Law

The mother of a kindergarten student, who suffered a serious allergic reaction after consuming peanut butter given to her under her school's free lunch program, brought suit against the State and its agents (collectively, Defendants), alleging that the State's obligations under the National School Lunch Act (NSLA) imposed upon Defendants a statutory duty of care to ensure that children with food allergies are not served lunches containing allergens. The trial court granted the State Defendants' motion to dismiss, concluding that the NSLA simply establishes a subsidized lunch program to benefit children at participating schools and does not impose a specific statutory duty of care towards children with food allergies. The court of special appeals affirmed. The Supreme Court affirmed, holding that the NSLA does not impose a statutory duty on the State Defendants to exercise a greater degree of care for students with food allergies than the general level of care the State Defendants exercise for all students in public schools. Because Petitioner could not maintain a suit in negligence, the complaint was properly dismissed. View "Pace v. State" on Justia Law