Justia Maryland Supreme Court Opinion Summaries

LaBonte worked for Electrical General, which had workers’ compensation insurance. LaBonte injured his back at work when he caught a ladder that was falling. The Workers’ Compensation Commission awarded him temporary total disability benefits and temporary partial disability benefits. Later, LaBonte was injured during a traffic stop of a vehicle that LaBonte was driving outside the course of his employment. According to LaBonte, the officer pushed him down onto the vehicle, causing his existing back pain to be aggravated. The Commission awarded LaBonte permanent partial disability benefits, finding that his disability was partly due to his work-related injury and partly due to “pre-existing and subsequent conditions[.]” Years later, LaBonte claimed that his back condition had worsened. The Commission reopened the case but found that a “subsequent intervening event” broke the “causal nexus” between LaBonte’s work-related injury and his existing condition. A jury found that LaBonte’s work injury was the cause of the recent worsening of LaBonte’s back condition. The Court of Special Appeals affirmed, holding that the later incident did not preclude Electrical General’s liability for the worsening of LaBonte’s back condition. The Maryland Court of Appeals affirmed, stating that liability for a temporary disability depends on the injury that occurred last, but liability for a permanent disability should be apportioned among all of the injuries that caused the permanent disability, not just the injury that occurred last. View "Electrical General Corp. v. LaBonte" on Justia Law

Between 2011 and 2013, a labor union held demonstrations at Walmart stores throughout Maryland, protesting Walmart’s employment conditions. Consequently, Walmart sued the union for trespass and nuisance and sought an injunction against the union. The circuit court granted summary judgment in favor of Walmart and issued a permanent injunction against UFCW. The court of special appeals affirmed. The Court of Appeals affirmed, holding (1) Walmart’s claims for trespass and nuisance were not preempted by the National Labor Relations Act, and therefore, the circuit court properly denied the union’s motion to dismiss; and (2) the circuit court properly ruled that this case did not involve a labor dispute within the meaning of Maryland’s Anti-Injunction Act. View "United Food & Commercial Workers International Union v. Wal-Mart Stores, Inc." on Justia Law

Petitioner, a former researcher employed by Johns Hopkins University School of Medicine (JHU), filed suit against JHU alleging (1) he was wrongfully terminated in retaliation for his repeated protests of research misconduct in violation of 42 U.S.C. 289b and 42 C.F.R. 93; and (2) conversion because after the termination of his employment, he was denied access to stored research materials he had collected. The circuit court granted JHU’s motion to dismiss because Petitioner failed to identify a public policy exception to the at-will employment doctrine and because JHU “could not have converted what it in fact had ownership of.” The Court of Special Appeals affirmed. The Court of Appeals affirmed, holding (1) Plaintiff was not wrongfully terminated, and his at-will employment came to an end due to the expiration of his employment contract; and (2) Plaintiff’s claim of conversion must fail because JHU owned the research materials pursuant to its stated policies. View "Yuan v. Johns Hopkins University" on Justia Law

Under Md. Code Ann. Pub. Safety, 3-103(b), Maryland law enforcement agencies may not prohibit law enforcement officers from working secondary employment. Petitioner, a former employee of the Maryland State Police Department (MSP), began working overtime in a law enforcement capacity securing National Security Agency (NSA) facilities pursuant to an agreement between MSP and NSA. The next year, MSP informed Petitioner that she could no longer work overtime at NSA. Petitioner brought a show cause action, alleging a violation of section 3-103(b)(1). MSP argued, in response, that troopers who work overtime at NSA are not engaged in “secondary employment” as that term is used in the statute but, rather, “on duty overtime.” The circuit court dismissed the action. The Court of Special Appeals affirmed. The Court of Appeals affirmed, holding that the Court of Special Appeals did not err in ruling (1) that Petitioner’s work at NSA was on-duty overtime work rather than secondary employment protected by section 3-103(b); and (2) that MSP did not take punitive action in prohibiting Petitioner from working at NSA. View "Breck v. Maryland State Police" on Justia Law

The Department of Public Safety and Correctional Services (DPSCS) sent Laura Hughes a notice of termination from her position with the agency. Hughes followed the directions for invoking the first tier of the administrative appeal process. The Secretary of DPSCS did not respond within the statutory time limit, thus denying Hughes first-tier appeal. Hughes was unaware that this silent denial triggered the limited time for her to invoke a second-tier appeal, and therefore she did nothing before the deadline passed. Hughes belatedly attempted to pursue her administrative appeal, but DPSCS did not respond. Hughes then commenced this mandamus action in the circuit court. The circuit court dismissed the mandamus action. The Court of Special Appeals affirmed. The Court of Appeals reversed, holding that, in order to discharge its responsibility to provide a disciplined employee with notice of the employee’s administrative appeal rights, an agency must advise the employee of the possibility of a second-tier appeal and alert the employee as to the significance of silence in response to a first-tier appeal. Remanded for consideration whether Hughes should be afforded the opportunity to pursue a second-tier appeal. View "Hughes v. Moyer" on Justia Law

Baltimore County and the Fraternal Order of Police have entered into numerous collective bargaining agreements over the years. This case arose out of a dispute over the interpretation of a provision in some of those agreements that provided for a fixed subsidy of health insurance costs for officers who retired during certain years. The dispute proceeded to binding arbitration. The FOP won the arbitration, but the County sought to overturn the arbitration award in the courts. Among other things, the County argued that the arbitration award was invalid because it was subject to the County’s executive budget process. The Circuit Court rejected the County’s various challenges to the award – a decision ultimately upheld by the Maryland Supreme Court. When the case returned to the Circuit Court, the County balked at complying with the arbitration award arguing that the award, even if valid, was unenforceable because it was subject to the County’s executive budget process. That argument was indistinguishable from one of the issues that the County had advanced on its prior trip up the appellate ladder and that the Supreme Court had previously rejected. The repetition of the issue from the prior appeal allowed the lower courts to dispose of the issue under the "law of the case" doctrine. However, the Supreme Court held that the lower courts properly applied the law of the case doctrine here. "An arbitration award that arises from a grievance process under an MOU previously approved by the County Executive and County Council and that interprets the provisions of the MOU is not subject to the executive budget process in the same way as an interest arbitration award that resolves an impasse in negotiations." The judgment of the Court of Special Appeals was affirmed. View "Baltimore Co. v. FOP Lodge No. 4" on Justia Law

Brenda Smith slipped on the floor in the course of her employment and landed on her left knee when she fell. Smith filed a workers’ compensation claim seeking benefits from Delaware North Companies and its insurer (together, Delaware North) for a full knee replacement. The Workers’ Compensation Commission denied her claim. Smith filed a petition for judicial review and requested a jury trial. During trial, Smith presented the expert testimony of Dr. Kevin McGovern. Delaware North, in turn, sought to admit a consent order that Dr. McGovern entered into with the Maryland Board of Physicians in order to impeach Dr. McGovern’s testimony. The trial court admitted into evidence a portion of the consent order. Based on the jury verdict, the trial judge affirmed the decision of the Commission. The Court of Appeals reversed, holding (1) Md. Code Ann. Health Occ. 14-410 generally prohibits the admission of a Board of Physicians’ consent order into evidence in a civil or criminal proceeding; and (2) the trial court erred as a matter of law in admitting a redacted version of the consent order in this case, causing prejudice to Smith’s case. View "Smith v. Delaware North Cos." on Justia Law

Under Md. Code Ann. Lab. & Empl. (LE) 9-632, an award of benefits by the Workers’ Compensation Commission survives the death of an injured employee. Under Md. Code Ann. Lab. & Empl. (LE) 9-640, an award of benefits survives the death of an injured employee only up to $45,000. Appellant, an injured worker’s daughter, sought to collect benefits under the Maryland Workers’ Compensation Act that would have been due to her father had he not died of causes unrelated to his accidental work injury. At dispute between Appellant and Appellees, the worker’s former employer and employer’s insurer, was whether LE 9-632 or 9-640 applied. The Commission determined that Appellees were not obligated to make further payments under an award of compensation to Appellant because LE 9-640 capped the survival of benefits at $45,000, and Appellees had already paid more than this amount to the decedent at the time of his death. The circuit court affirmed the Commission’s ruling. The Court of Appeals affirmed, holding that LE 9-640, rather than LE 9-632, applied in this case. View "Hollingsworth v. Severstal Sparrows Point, LLC" on Justia Law

Under the Workers’ Compensation Act (Act), the amount of compensation due to a “covered employee” - which may include a sole proprietor - who has a “permanent total disability resulting from an accidental personal injury” is based on the employee’s “average weekly wage” (AWW). At issue in this case was how to calculate the AWW of a sole proprietor who elects coverage for an accident personal injury under the Act. Petitioner, a self-employed sole proprietor who elected to obtain workers’ compensation coverage as a covered employee, was injured while working as a subcontractor. The Workers’ Compensation Commission issued an award of compensation, but the parties disputed the amount of compensation due. The Commission ultimately calculated Petitioner’s AWW based on his net profit rather than his gross receipts. The circuit court and Court of Special Appeals affirmed. The Court of Appeals affirmed, holding that the AWW of a sole proprietor who elects coverage under the Act is calculated based on the sole proprietorship’s net profit, not on the sole proprietorship’s gross receipts or gross income. View "Long v. Injured Workers' Ins. Fund" on Justia Law

Adkins started working at PRMC in 2005, delivering and organizing supplies. In April 2011, Adkins went to PRMC’s emergency room after experiencing pain. Adkins was diagnosed with a tear in the joint of her hip and a deformation in her hip socket. She scheduled surgery and completed paperwork under the Family and Medical Leave Act, 29 U.S.C. 2612, stating that she would return to work in October 2011. PRMC approved Adkins’s leave, explaining that her 12-week FMLA leave would expire on November 17, 2011, After surgery, Adkins’s pain intensified. Doctors advised that recovery could take up to a year. On November 7, 2011, Adkins returned to work, stating that she was still in pain and would be unable to fulfill her job responsibilities that day. An “Employee Charting Note” states that “[a]ll parties” agreed that Adkins could not return to work; that Adkins had “been educated on FMLA and to start looking at job postings,” and that Adkins reported having applied for a position. PRMC granted a 14-week extension, after which Adkins was terminated. Adkins unsuccessfully applied to positions. The trial court rejected her suit under the Maryland Fair Employment Practices Act, Code 20-601 on summary judgment. The Court of Appeals reversed, finding disputes of material fact with respect to whether: Adkins was qualified to perform the essential functions of a specific job with or without a reasonable accommodation, and whether Adkins was terminated because of her disability. View "Peninsula Regional Med. Ctr. v. Adkins" on Justia Law