Justia Maryland Supreme Court Opinion Summaries

After Mr. Greenfield unsuccessfully filed criminal charges against Petitioner, Petitioner filed a complaint against Mr. and Mrs. Greenfield (Respondents) alleging, inter alia, defamation and false light/invasion of privacy. The circuit court granted summary judgment to Respondents as to all claims. Respondents subsequently moved for an award of attorney's fees and costs while acknowledging that their attorney's fees and costs had been paid by their insurance carrier (Insurer). The circuit court denied the motion as to Mr. Greenfield but granted it as to Mrs. Greenfield, finding that she had been joined in the action without substantial justification and that she had "incurred" the costs of her defense within the meaning of Maryland Rule 1-341, even though Insurer had paid the costs of litigation on her behalf. The court of special appeals affirmed. The Court of Appeals affirmed, holding that a party compelled to defend him or herself against abusive litigation may recover the costs associated with that litigation under Rule 1-341, regardless of the individual or entity that actually pays such expenses. View "Worsham v. Greenfield" on Justia Law

Ember Buckley was a passenger in a motor vehicle driven by Harvey Betts when the vehicle was involved in an accident. Buckley, who sustained injuries in the accident, settled with GEICO, Betts’ insurer, for the full policy limits and signed a full release of all claims against Betts and a hold harmless agreement in favor of GEICO. Buckley then attempted to recover for the remainder of her outstanding medical bills under her uninsured/underinsured motorist (“UM”) policy with The Brethren Mutual Insurance Company (“Brethren”), which denied coverage. Buckley filed suit, alleging breach of contract and seeking the policy limit in compensatory damages. The circuit court entered summary judgment for Brethren, concluding that the release was a general release, and thus released all entities from future claims, regardless of whether they were a party to the release. The court of special appeals reversed, holding that the general release did not prejudice Buckley’s claim against Brethren. The Court of Appeals affirmed, holding (1) the broad, all-inclusive language of the release must be read with an eye toward the parties’ overall intent; and (2) that the court of special appeals correctly held that the release did not waive Buckley’s UM claim against Brethren. View "Brethren Mut. Ins. Co. v. Buckley" on Justia Law

After she was injured in a motor vehicle accident, Petitioner filed suit against Charles Serio, the tortfeasor. Petitioner’s motor vehicle insurer, GEICO, with whom Petitioner had underinsured motorist (“UM”) coverage, intervened as a defendant to protect its possible interest in the litigation. At trial, the parties stipulated that Serio was at fault for the accident, and the only issues before the jury were causation and damages. Petitioner’s counsel offered a proposed jury instruction on the nature of UM coverage, but the trial court refused the instruction, noting that insurance was not the issue at trial. The jury returned a verdict in favor of Petitioner for the amount of her medical bills but did not award damages for future medical expenses or pain and suffering. Petitioner unsuccessfully filed a motion for a new trial, arguing in not giving an instruction about the nature of UM coverage, the trial court confused the jury. The Court of Appeals affirmed, holding that the trial court did not err in declining to instruct the jury about the reason Plaintiff’s UM carrier was a party to the tort suit because the issue of UM coverage was not before the jury. View "Keller v. Serio" on Justia Law

A holding company, whose subsidiaries owned power-generating facilities, filed a complaint against multiple insurers regarding the terms of liability policies the company purchased in the 1970s and 1980s. At issue in this case was whether New York or Pennsylvania law applied to the interpretation of the policies. The circuit court granted summary judgment in favor of the holding company, determining that Pennsylvania law governed the interpretation of the policies. One of the insurers, TIG Insurance Company (“TIG”), appealed. The court of special appeals affirmed, concluding that there was no genuine dispute of material fact that the insurance contracts were made in Pennsylvania, and therefore, Pennsylvania law applied to the policies at issue. The Court of Appeals affirmed and adopted the opinion of the court of special appeals with the exception of the court’s discussion addressing TIG’s argument that the place of countersigning a policy determines the applicable state law because that argument was not preserved for appeal. View "TIG Ins. Co. v. Monongahela Power Co." on Justia Law

A county-owned police patrol vehicle was damaged in a single-car collision while Respondent, a county police officer, operated the vehicle under the influence of alcohol. The County, a self-insured entity, filed a complaint against Respondent seeking to recover the cost of repairs to the vehicle. The district court ruled that the County could recover damages against Respondent based on an exclusion in the self-insurance guarantee purportedly excluding or disclaiming all insurance coverage on the basis that Respondent operated his vehicle under the influence of alcohol. The circuit court reversed. The Supreme Court affirmed, holding (1) Maryland's compulsory motor vehicle insurance scheme does not permit a self-insurer such as the County to disclaim or exclude insurance coverage in a self-insurance guarantee where an individual causes a collision while driving under the influence of alcohol; and (2) the exclusion in the guarantee in this case was invalid because it violated the state compulsory motor vehicle insurance scheme, was not expressly authorized by the General Assembly, and was against public policy. View "Montgomery Co. v. Distel" on Justia Law

This case arose when six employees of the Baltimore Washington Conference of the United Methodist Church filed workers' compensation claims, claiming they had sustained physical injury as a result of exposure to mold in the Conference's office. The employees profferred Dr. Ritchie Shoemaker as their expert to prove causation. Defendant moved to exclude Shoemaker under Frye-Reed on the grounds that his methodology to determine causation was not generally accepted in the relevant scientific community. On remand, after a Frye-Reed hearing, the circuit court determined that Shoemaker's methodology was generally accepted by the relevant scientific community and satisfied the Frye-Reed test. The court of special appeals reversed. The Court of Appeals affirmed, holding that Shoemaker's technique and theory were not shown to be generally accepted in the relevant scientific community. View "Chesson v. Montgomery Mut. Ins. Co." on Justia Law

CareFirst, Inc., a nonstock, nonprofit Maryland corporation, is a holding company with two subsidiaries that provides health insurance for millions of Maryland residents. State law confers broad authority on the Maryland Insurance Commissioner to oversee its operation and adherence to its mission. This case arose from the termination of Leon Kaplan, a former executive of CareFirst. CareFirst declined to pay part of the post-termination compensation set forth in Kaplan's employment contract, reasoning that the compensation was not for "work actually performed," as that standard had been interpreted by the Commissioner. The Commissioner affirmed the decision not to pay the benefits, concluding that the payments would violate Md. Code Ann. Ins. 14-139. The Court of Appeals affirmed, holding (1) the Commissioner's determination was not preempted by ERISA; (2) the Commissioner's construction of the insurance code was legally correct; and (3) there was substantial evidence to support the Commissioner's determination in this case. View "Md. Ins. Comm'r. v. Kaplan" on Justia Law

Petitioner was a passenger in a motor vehicle accident in which her husband, the driver, was killed and Petitioner suffered serious injuries. At the time of the accident, Petitioner and her husband had a motor vehicle liability insurance policy with State Farm Auto and an umbrella policy with State Farm Fire and Casualty Company (collectively, State Farm). State Farm denied Petitioner's claim under the umbrella policy pursuant to a household exclusion, which excluded coverage in certain instances for injury the insured's family members. Petitioner contended that the household exclusion in the umbrella policy was void in light of Md. Code Ann. Ins. 19-504.1, which requires an insurer to offer liability coverage for family members in the same amount of liability coverage for nonfamily members under a policy of "private passenger motor vehicle liability insurance." The circuit court ruled in favor of State Farm. The Court of Appeals affirmed, holding that the umbrella policy did not fit within the definition of "private passenger motor vehicle liability insurance" as contained in section 19-504.1, such that State Farm was not required to offer Petitioner and her husband liability coverage for family members in the same amount as the liability coverage for nonfamily members. View "Stickley v. State Farm Fire & Cas. Co. " on Justia Law

When a property or casualty insurer becomes insolvent, the Maryland Property & Casualty Insurance Guaranty Corporation (PCIGC) assumes responsibility for any outstanding claims or litigation. In this case, an insurance company settled a claim with an insured party but became insolvent before the agreement could be approved by a court. Respondents filed a complaint against PCIGC seeking declaratory relief, asking the circuit court to find they settled the claim and that PCIGC was obligated to pay the statutory maximum on both an underlying insurance policy and an umbrella policy. PCIGC sought to challenge the settlement reached by the parties and argued that it should not have to pay its statutory maximum on the policies when the claims stemmed from a single incident. The court of special appeals held (1) PCIGC may challenge a settlement only on limited grounds, such as fraud or collusion, and the corporation bears the burden of proving its reason for challenging a claim, and (2) PCIGC was liable for the statutory maximum on both policies. The Court of Appeals affirmed, holding (1) PCIGC had no sufficient grounds for properly challenging the settlement; and (2) requiring PCIGC to pay covered claims under separate policies was within its statutory mandate. View "Prop. & Cas. Ins. Guar. Corp. v. Beebe-Lee" on Justia Law

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