Justia Maryland Supreme Court Opinion Summaries

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

Decedent worked as a firefighter for Baltimore City. After Decedent died, his widow, Petitioner, began receiving survivorship benefits from Decedent's pension. Petitioner later filed a dependent's claim for death benefits under the Maryland Workers' Compensation Act. The dispute at the hearing concerned what provision of the Act was applicable to Petitioner's claim. The City argued that Md. Code Lab. & Empl. 9-610, which reduces compensation death benefits by the amount of pension benefits, should apply. Petitioner argued that Md. Code Lab. & Empl. 9-503(e), which allows firefighters' dependents to collect both pension and workers' compensation up to the amount of what had been the firefighter's weekly salary, should apply. Petitioner's claim was pending when section 9-503(e) was amended to include dependents in its scope of coverage. The Workers' Compensation Commission determined that section 9-503(e) governed the claim and awarded Petitioner benefits. The circuit court granted summary judgment for the City, ruling that Petitioner had no preexisting right to dual benefits prior to the statute's amendment. The Court of Appeals affirmed, holding that the amendments involved a substantive change in the law that precluded it from applying retroactively to pending cases. View "Johnson v. Baltimore" on Justia Law

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

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

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

The Maryland Insurance Commissioner approved a filing by Allstate Insurance Company and Allstate Indemnity Company (collectively, Allstate) giving notice of its intent to cease writing new property insurance policies in certain geographic areas of the state. The Commissioner concluded that the filing was subject to administrative review under Md. Code Ann. 19-107(a) and Md. Code Ann. Ins. 27-501(a) and that it satisfied the pertinent criteria under both statutes. The circuit court affirmed both aspects of the Commissioner's ruling. The court of special appeals affirmed but on alternative grounds, holding that section 27-501(a) did not apply to the filing and that, even if it did, the statute was not violated. The Court of Appeals affirmed but, again, on different grounds, holding (1) the Commissioner did not err in finding that section 27-501 did apply to the Allstate filing, and (2) the evidence was sufficient to support the Commissioner's decision. View "People's Ins. Counsel Div. v. Allstate Ins. Co." on Justia Law

Petitioner, the Maryland insurance commissioner, issued a cease-and-desist order to Respondents, several premium finance companies that provided loans primarily to customers of the Maryland Automobile Insurance Fund, purporting to prevent them from charging interest on loans to consumers to pay automobile insurance premiums in excess of the statutory maximum. Respondents requested a hearing. An associate deputy insurance commissioner presided over a hearing at the Maryland Insurance Administration (MIA) and issued a final order affirming the commissioner's cease-and-desist order. The circuit court concluded that the administrative hearing violated Respondents' right to fundamental fairness and due process of law because the commissioner delegated the decision-making authority to a subordinate. The court of special appeals affirmed. The Court of Appeals vacated the court of special appeals and circuit court and affirmed for the most part the decision of the MIA, holding, inter alia, that (1) the MIA hearing was fair and without undue "command influence"; and (2) the commissioner's interpretation of Md. Code Ann. Ins. 23-304 was correct, and Respondents violated the statute when their premium finance agreements operated to assess a finance charge in excess of 1.15 percent for each of thirty days. View "Md. Ins. Comm'r v. Cent. Acceptance Corp." on Justia Law