Justia Maryland Supreme Court Opinion Summaries

An Employer appealed from a decision of the Workers’ Compensation Commission (Commission) ordering Employer to pay additional temporary total disability benefits to Employee, who was injured during his employment. After a jury trial, the trial court granted Employee’s motion for judgment and affirmed the award, concluding that the Commission decision was a piece of evidence that needed to be considered by the jury and that Employer was required to introduce the Commission decision into evidence. The court of special appeals reversed, concluding that Appellant was not required to move the award into evidence. The Court of Appeals affirmed, holding that, in a de novo workers’ compensation jury trial, the appellant is not required to move the Commission decision into evidence. View "Gales v. Sunoco & Amer. Zurich Ins." on Justia Law

After Respondent’s employment with a corporation was terminated, she sued the corporation and her sibling business partner, alleging that she was terminated without cause in violation of her employment agreement. The written agreement contained a for-cause provision but no definite term of employment. The trial judge found a breach of the employment agreement, concluding that the agreement transformed what had previously been an “at-will relationship” to a “lifetime contract,” and therefore, Respondent could only be terminated for cause, death, or disability. The court of special appeals affirmed in part and reversed in part, holding that the contract was a for-cause contract of continuous duration rather than a lifetime contract, obviating the need for “special consideration.” The corporation appealed. The Court of Appeals affirmed, holding that the employment agreement was not at-will employment nor an oral lifetime employment contract that has been consistently rejected by Maryland courts, but this type of contract was “continuous for-cause” employment. View "Spacesaver Sys., Inc. v. Adam" on Justia Law

At issue in this case were two of Maryland’s wage enforcement laws: the Wage and Hour Law (WHL) and the Wage Payment and Collection Law (WPCL). Following her departure from her place of employment Plaintiff sued her Employer claiming that her Employer wrongfully withheld her overtime wages. On remand, Plaintiff filed an unopposed memorandum asserting a claim under the WHL and the WPCL, requesting unpaid overtime and treble damages under the WPCL. The circuit court awarded Plaintiff $6,201 in unpaid overtime wages but denied her request for enhanced damages. The Supreme Court vacated the judgment of the circuit court and remanded, holding that the trial court erred when it failed to make an explicit finding regarding whether Employer withheld overtime wages as a result of a bona fide dispute, and the evidence did not support a finding that Employer withheld Plaintiff’s wages pursuant to a bona fide dispute. View "Peters v. Early Healthcare Giver, Inc." on Justia Law

The Fraternal Order of Police, Lodge No. 4 (the FOP), the bargaining agent for covered Baltimore County police employees, submitted to the Baltimore County’s Director of Human Resources (Director) an unfair labor practice complaint based on a unilateral change made by the County to a policy included in the County’s personnel manual but which was not part of the memorandum of understanding between the County and the FOP and was not subject to collective bargaining negotiation. The Director refused to designate an independent third party agency to consider the FOP’s unfair labor practice complaint. The FOP sought a writ of mandamus, claiming that the Director had a ministerial duty pursuant to section 4-5-204(a)(1)(i) of the Employee Relations Act (Act) of the Baltimore County Code (BCC) to designate a third party agency to investigate and determine whether an unfair labor practice charge had been committed. The circuit granted the writ compelling the Director to designate an independent third party to investigate the FOP’s unfair labor practice complaint. The Court of Appeals reversed, holding that nothing in the Act or the BCC imposes an undisputable, non-discretionary duty on the Director to refer every unfair labor practice complaint to an independent third party agency. View "Baltimore County v. Fraternal Order of Police Lodge No. 4" on Justia Law

The question before the Court of Appeals in these three consolidated cases was the appropriate method for crediting payments made under a workers’ compensation award when that award is increased on appeal. At issue was whether the credits should be computed on the basis of the number of weeks paid or the amount of money expended. The Court of Appeals resolved the issue in favor of the workers in each case by relying on legislation passed specifically to supersede earlier decisions of the Court, holding that, when crediting an employer/insurer for payments made under a workers’ compensation award that is subsequently amended, credit should be given for the total amount of dollars paid under the initial award. View "W.R. Grace & Co. v. Swedo" on Justia Law

After Elms Construction Company, owned by Richard Elms (Elms), began installing windows and doors for Renewal by Anderson (Renewal), Elms fell from a ladder and injured his right foot. Elms filed a workers’ compensation claim with the Workers’ Compensation Commission, alleging that he was Renewal’s common law employee at the time of the injury. The Commission concluded that Elms was an independent contractor, rather than a common law employee of Renewal, and was therefore not entitled to collect workers’ compensation benefits. The circuit court reversed, concluding that Elms was Renewal’s common law employee. The court of special appeals vacated the circuit court’s opinion and remanded. The Supreme Court vacated the court of appeals’ opinion and remanded with directions to affirm the circuit court’s judgment, holding (1) the Commission misconstrued the law as applied to the facts when it concluded that Elms was an independent contractor and not an employee of Renewal; (2) the court of special appeals erred when it held that a statutory employment analysis under section 9-508 of the Workers’ Compensation Act must precede a common law employment analysis; and (3) by application of the common law to the facts of this case, Elms was Renewal’s employee at the time of the accident. View "Elms v. Renewal by Anderson" on Justia Law

Joy Friolo was hired by Douglas Frankel, a physician, to handle his billing and collections. After Friolo was discharged, she filed a complaint against Frankel and his practice, claiming that Frankel did not pay her for certain overtime and bonuses. A jury entered a verdict in favor of Friolo. The parties then began a protracted dispute over attorney fees. Ultimately, on the third appeal, the court of special appeals awarded fees for the trial stage of the litigation and for appellate work for a total of $45,041. In coming up with this figure, the court used an unprecedented mathematical formula for determining how attorneys’ fees in this case only should be calculated based on the arithmetic relationship among the amount of the claim, settlement demands and offers, and ultimate judgment. The Court of Appeals vacated the judgment of the court of special appeals, holding that the lower appellate court erred in its approach. Remanded. View "Friolo v. Frankel" on Justia Law

Respondents each suffered on-the-job accidents, resulting in permanent partial disability. In both cases, at least one of the Respondent's injuries was a "scheduled injury" and the other was an "unscheduled injury." The Workers' Compensation Commission awarded Respondents benefits at the "second tier" rate. In making the awards pursuant to Md. Stat. Ann. Lab. & Empl. 9-629, the Commission combined, in each case, the awards for the scheduled and unscheduled injuries. Both Robinson's and Anderson's employers appealed. The circuit court reversed the Commission's awards. The court of special appeals reversed the circuit court's judgments, holding that the Commission could combine awards for scheduled injuries with awards for other cases to determine whether the second tier compensation rate was applicable. The Court of Appeals affirmed, holding that it is permissible under the Workers' Compensation Act to combine compensation awards in order to determine which of the three levels of compensation prescribed by Md. Stat. Ann. Lab. & Empl. 9-628 through 9-630 is appropriate. View "Montgomery County v. Robinson" on Justia Law

In 2011, the Montgomery County Council adopted Resolution No. 17-149 (Resolution), which “changed” three contract provisions for fiscal year 2012 in the pre-existing collectively-bargained agreement (CBA) with members of the County’s police force. Specifically, the Resolution changed certain employment benefits of the CBA. The Fraternal Order of the Police, Montgomery County Lodge 35 filed suit against the County and the Council, challenging the legality of the Council’s actions in adopting the Resolution and the actions of the Council and the County in implementing the changes in the resolution. The circuit court declared that the Council’s actions were permissible under the Police Labor Relations Act (PLRA), the Maryland Declaration of Rights, and the CBA. The court of special appeals affirmed. The Court of Appeals affirmed, holding that the Council acted within its authority under the PLRA in deciding not to fund fully - and thereby, to change - certain benefits in the CBA, where the changes were fiscal in nature and the County Executive and the FOP did not submit a re-negotiated agreement to the Council. View "Fraternal Order of Police Lodge 35 v. Montgomery County" on Justia Law

Plaintiff was an hourly employee of Safeway, Inc. In 2010, in response to two writs of garnishment issued by the district court, Safeway deducted an excess of $29.64 from Plaintiff’s wages. Plaintiff subsequently filed a lawsuit against Safeway on behalf of herself and all other persons similarly situated, arguing that Safeway’s garnishment practice resulted in wrongfully excessive deductions. Ten days after the class action suit was filed, Safeway changed its payroll garnishment system to conform with the correct garnishment exemptions standards and tendered to Plaintiff the amounts that would have been paid to her had those standards been applied at the time. The circuit declined to certify the class and entered judgment in favor of Safeway. The court of special appeals affirmed. The Court of Appeals affirmed, holding (1) employees have a right of direct private action against their employer under Md. Code Ann. Lab. & Empl. 3-507.2 for deducting from the employee’s wage more than is lawfully allowed; and (2) the circuit court did not abuse its discretion under the circumstances of this case in denying class certification and in entering judgment for Safeway. View "Marshall v. Safeway, Inc." on Justia Law