Justia Maryland Supreme Court Opinion Summaries

Prince George’s County terminated the employment of Marlon Ford, a member of the County Police Civilian Employees Association, after a criminal investigation during which Ford was questioned regarding alleged crimes. The Association filed a grievance on Ford’s behalf. An arbitrator vacated the termination of Ford’s employment, determining that the County had violated a collective bargaining agreement (CBA) between the County and the Association because officers of the county police department failed to advise Ford of his right to have a representative from the Association present during the criminal investigative interview. The Court of Special Appeals vacated the arbitration award. The Court of Appeals affirmed in part and reversed in part, holding (1) under the County’s code, the County lacked the authority to enter into a CBA that requires a Weingarten advisement before a criminal investigative interview of one of the County’s police civilian employees; and (2) therefore, the arbitrator the arbitrator exceeded his authority by basing the arbitration award on the determination that the County violated the CBA because its police officers failed to make a Weingarten advisement. View "Police Civ. Empl. Ass'n. v. Prince George's Co." on Justia Law

While living in Maryland, Petitioner opened a personal line of credit and a credit card account with Respondent. Respondent later filed two complaints against Petitioner in a Maryland district court, one for the outstanding balance on the credit card account and the other for the amount owed on the line of credit. At the time of the filings, Petitioner was living and working in Texas. Respondent was awarded default judgments. Respondent subsequently secured two writs of garnishment in the same actions from the district court. The writs were served on the resident agent of Petitioner’s employer. Petitioner moved to quash the writs, arguing that his wages earned solely for work he performed in Texas were not subject to garnishment in Maryland. The district court denied the motions to quash. The Court of Appeals affirmed, holding that the district court in its continuing and ancillary jurisdiction properly ordered Petitioner’s wages earned in Texas to be subject to garnishment served upon Petitioner’s employer because of the employer’s continuous and systematic business in Maryland. View "Mensah v. MCT Fed. Credit Union" on Justia Law

A local public school superintendent decided to terminate a school nurse, who was a “noncertificated” employee. The school nurse challenged her termination by way of a grievance process set forth in a collective bargaining agreement (CBA) between the school board and a union. The superintendent denied the grievance, asserting that the termination was an illegal subject of collective bargaining. The union, on behalf of the school nurse, made a demand for arbitration. The school board filed a motion for injunctive relief seeking to enjoin the arbitration. The Maryland State Board of Education (State Board) and the Public School Labor Relations Board (PSLRB) both issued opinions in the matter. The circuit court affirmed the decision of the State Board, which concluded that the binding arbitration provision of the CBA was illegal, and reversed the decision of the PSLRB, which came to the opposite conclusion. The court of special appeals reversed, holding that the PSLRB was the entity with the jurisdiction to resolve the dispute. The Supreme Court affirmed, holding that the termination of a noncertificated employee is a proper subject of binding arbitration pursuant to a collective bargaining agreement. View "Bd. of Educ. v. Howard County Educ. Ass'n" on Justia Law

Petitioner was terminated from her position as the Clerk-Treasurer of the Town of Hurlock two and one-half years after she entered into a written employment agreement with the Mayor-elect. Under the employment agreement, Petitioner was to serve a four-year term. Petitioner brought this action against Respondent, the Town, alleging breach of contract and seeking damages and other relief. The circuit court dismissed the complaint, concluding that the four-year term of employment in the agreement was inconsistent with the Town Charter and therefore ineffective. The Court of Special Appeals affirmed. The Court of Appeals affirmed, holding (1) the language of the Town Charter means that an official like the Clerk-Treasurer is an at-will employee; and (2) the Mayor and Council of Hurlock lacked authority under the Town Charter to enter into an agreement conferring a fixed term of employment in this case. View "Clough v. Mayor & Council of Hurlock" on Justia Law

Mark Hranicka filed a workers’ compensation claim as a result of an injury he sustained during a motor vehicle accident. The workers’ compensation claim was withdrawn. Thereafter, Hranicka submitted to the Workers’ Compensation Commission a second claim. The claim was electronically submitted to the Commission before expiration of the two-year statute of limitations but not filed on paper until after the expiration of the two-year period. Respondents contested the claim, arguing that it was time-barred under Md. Code Ann. Lab. & Empl. 9-709(b)(3). The Commissioner determined that the claim was not time-barred. The Supreme Court reversed, holding that electronic submission of a claim does not constitute “filing” pursuant to Code of Maryland Regulations, and therefore, the Commission erred in ruling that the filing date of a claim could be the date of the claim’s electronic submission for purposes of the statute of limitations. View "Hranicka v. Chesapeake Surgical, Ltd." on Justia Law

The Maryland Workers’ Compensation Act creates a presumption that certain disabling medical conditions are occupational diseases suffered in the line of duty and are therefore compensable. The statute caps those benefits, however. The retirement benefits at issue in this case derived in part from an optional retirement program offered by Baltimore County. The program provided that senior employees who opted to remain on the job be compensated with enhanced retirement benefits that could be taken in a lump sum upon retirement or in higher recurring retirement payments. The two retired firefighters in these cases participated in the program and also qualified for workers’ compensation benefits as a result of the special presumption for public safety employees. At issue in these cases was how the lump sum retirement payment was to be included in the formula for capping the retirees’ workers’ compensation benefits. The Court of Appeals rejected the methods proposed both by the retirees and by the County and adopted the approach by the Workers’ Compensation Commission in the Thiergartner case for converting the lump sum portion of the retirement benefits to a weekly figure. View "Baltimore Co. v. Thiergartner" on Justia Law

After voluntarily leaving his job with Employer, Respondent applied for unemployment benefits. The Department of Labor, Licensing, and Regulation (DLLR) denied the claim for benefits, determining that Respondent quit his job without good cause. The hearing examiner upheld the DLLR’s findings. The DLLR Board of Appeals declined to hear Respondent’s appeal, thereby adopting the hearing examiner’s decision as its own decision. Thereafter, Respondent filed a petition for judicial review. Instead of filing an answering memorandum, the DLLR Board requested that the circuit court remand the case back to the Board before the court conducted its review. The circuit court granted the Board’s motion for remand. The Court of Special Appeals dismissed Employer’s appeal, concluding that the remand order was was not a final judgment or otherwise appealable. The Court of Appeals affirmed, holding that the remand order was not a final, appealable judgment. View "Metro Maint. Sys. South, Inc. v. Milburn" on Justia Law

Two security guards employed by SSA Security, Inc. and four of their confederates carried out a conspiracy to set fire to several homes. The resulting fires destroyed ten homes and damaged twelve others. Appellants asserted various civil claims against SSA and the five convicted arsonists, contending that the Maryland Security Guards Act (“Act”) section 19-501 established a basis for SSA’s strict liability for its employees’ intentional torts and civil rights violations. A federal district judge granted summary judgment in SSA’s favor as to the negligence claims and the claims premised on strict liability under section 19-501, concluding (1) section 19-501 was merely a codification of the common law and did not expand the doctrine of respondeat superior; and (2) any intentional acts of SSA’s employees were outside the scope of employment. Appellants appealed, arguing that the Act extends the vicarious liability of security guard agencies beyond the state common law doctrine of respondent superior. The federal appellate court certified a question of law to the Court of Appeals regarding the meaning of section 19-501. The Court answered that section 19-501 has the same meaning as Maryland’s common law doctrine of respondent superior. View "Antonio v. SSA Sec., Inc." on Justia Law

William Lovelace was a member of Amalgamated Transit Union, Local 1300 (Local 1300). For three years, Lovelace and David McClure (together with Local 1300, “the Union”) served together as officers on Local 1300’s executive board. When the men ran for reelection, Lovelace was defeated. Lovelace filed a defamation action against the Union, claiming that his defeat was due to allegedly false and defamatory statements McClure made during the campaign. Lovelace sought both compensatory and punitive damages. The Union filed motions to dismiss, asserting that Lovelace was required to exhaust Local 1300’s internal remedies before filing suit. The circuit court denied the motions. The jury ultimately rendered a verdict in Lovelace’s favor. The Union appealed, challenging the trial court’s denial of their motions to dismiss. The Court of Special Appeals affirmed, concluding that Local 1300’s internal remedies were inadequate because they could not provide the monetary damages that Lovelace sought. The Court of Appeals affirmed, holding that when a union member claims that his union and a fellow union member were liable for defamation and seeks monetary damages and the union's internal remedies do not provide monetary damages, the union’s internal remedies are inadequate and the union member is not required to exhaust them. View "Amalgamated Transit Union v. Lovelace" on Justia Law

Plaintiff, a young lawyer associate, filed a complaint against Defendants, his former Virginia-based law firm employer and its principal, claiming a violation of the Maryland Wage Payment and Collection Law (“MWPCL”) and seeking $1,974 in unpaid wages, treble damages, and attorney’s fees and costs. The trial judge concluded that the employment contract was a “Virginia” contract, and therefore, Plaintiff could not bring a suit in Maryland under the MWPCL. The circuit court reversed the dismissal of Plaintiff’s MWPCL claim. Defendants appealed. The Court of Appeals affirmed, holding that the mere fact that the parties in this case entered into a “Virginia” employment contract did not prohibit maintenance of Plaintiff’s claims under the MWPCL. Remanded. View "Cunningham v. Feinberg" on Justia Law