Justia Maryland Supreme Court Opinion Summaries

Petitioner was a paid firefighter employed by Respondent, Montgomery County. Petitioner filed a claim pursuant to the Maryland Workers’ Compensation Act, claiming that he sustained injuries in an accident that occurred when he was traveling to work on his motorcycle after leaving physical training. The Maryland Workers’ Compensation Commission disallowed Petitioner’s claim, finding that Petitioner did not sustain an injury arising out of and in the course of employment. The circuit court upheld the Commission’s decision, ruling that Petitioner was not entitled to workers’ compensation because the injury occurred while “he was coming and going” to work. The court of special appeals affirmed. The Court of Appeals vacated the judgment of the court of special appeals, holding that Petitioner’s injury arose out of and in the course of his employment and was covered by the Workers’ Compensation Act because (1) Petitioner’s travel was incidental to his employment, which travel cannot be excluded from coverage by application of the going and coming rule; and (2) “but for” his travel between work-related sites Petitioner would not have been injured. View "Roberts v. Montgomery County" on Justia Law

Plaintiffs were employees of a State psychiatric hospital who had been laid off and were not rehired in order of seniority when the hospital later filled vacancies for positions comparable to those previously occupied by Plaintiffs. An administrative law judge denied Plaintiffs’ grievance, concluding that Plaintiffs were not entitled to be rehired under a reinstatement process. The circuit court affirmed. The court of special appeals remanded the case for further factfinding, concluding (1) there is no statutory preference for reinstatement, as opposed to recruitment, in the State Personnel Management System, but if an agency decides to fill vacancies through recruitment, it must follow statutory procedures, including public notice and transparency as to the selection criteria; and (2) it was not clear whether the agency in this case complied with those criteria. The Court of Appeals affirmed by adopting the opinion of the court of special appeals and adding an endorsement to the court of special appeal’s opinion to remove any doubt as to the standing of that decision as the law of the State. View "Sturdivant v. Dep’t of Health & Mental Hygiene" on Justia Law

Respondents filed a complaint for accounting against Petitioner, their employer, after a dispute over the terms of their employment agreement. In response, Petitioner filed a petition to compel arbitration, asserting that, because Respondents’ claims arose out of their employment agreements, the circuit court was required to compel arbitration under an arbitration clause contained in the employment agreement. The circuit court denied Petitioner’s petition. The intermediate appellate court dismissed Petitioner's appeal, concluding that the denial of Petitioner’s motion to compel arbitration did not constitute a final judgment. The Supreme Court affirmed, holding that an order denying a request to compel arbitration filed in an existing action is not a final judgment because the denial of the petition does not put the parties out of court or otherwise terminate the proceedings and does not deny the party requesting arbitration the means of further prosecuting or defending rights and interests in the subject matter of the proceeding. View "Am. Bank Holdings, Inc. v. Kavanaugh" on Justia Law

Plaintiffs here were employees who had been laid off from their jobs at a State psychiatric hospital and, when the hospital filled vacancies for positions comparable to those previously occupied by the laid-off employees, were not rehired in order of seniority. An administrative law judge denied Plaintiffs' grievance, concluding that they did not have a right to be rehired under a reinstatement process. The circuit court affirmed. The court of special appeals remanded the case for further factfinding, concluding (1) there is no statutory preference for reinstatement, as opposed to recruitment, in the State Personnel Management System; but (2) if an agency elects to fill vacancies through recruitment, it must follow statutory procedure that includes public notice and transparency as to the selection criteria. The Court of Appeals affirmed, holding (1) the lower court correctly analyzed the legal issue concerning the interpretation of State personnel law; and (2) because the record did not definitely answer the question whether the agency in this case was filling vacancies by a reinstatement process, rather than recruitment, remand for further factfinding was appropriate. View "Sturdivant v. Dep't of Health & Mental Hygiene" on Justia Law

After Respondent resigned as executive director of the Chamber of Commerce, he filed a complaint against the Chamber, alleging violations of the Wage Payment and Collection Law, among other claims. After a jury trial, the court entered judgment against the Chamber. Respondent subsequently filed a motion for an award of attorneys' fees under the Wage Payment and Collection Law. The circuit court denied Respondent's motion on remand after applying a fee-shifting analysis from ERISA cases. The court of special appeals reversed the denial of the motion, holding that the circuit court erred in applying the ERISA factors. The Court of Appeals affirmed, holding that because ERISA and the Wage Payment and Collection Law serve distinct purposes and because their fee-shifting provisions are based on different principles, a trial court should not employ the ERISA fee-shifting test in deciding whether to award attorneys' fees. View "Ocean City Chamber of Commerce v. Barufaldi" 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

Plaintiff worked for the Association of Maryland Pilots as a launch boat operator. Plaintiff was later promoted to assistant station manager. In 2008, Plaintiff was diagnosed with silicosis. Plaintiff sued the Association pursuant to the Jones Act, alleging negligence in regard to injuries he suffered from exposure to free silica during his employment. Whether Plaintiff's claim was properly made under the Jones Act depended on whether Plaintiff was a "seaman" at the time of the alleged negligence. To distinguish seamen from land-based workers, the U.S. Supreme Court has held that a seaman must ordinarily have spent at least thirty percent of work time in service of a vessel in navigation. The lower courts concluded Plaintiff was not a seaman at the time of his injury and therefore granted summary judgment for the Association. The Court of Appeals affirmed, holding that Plaintiff did not spend at least thirty percent of his work time performing sea-based duties, and therefore, Plaintiff was not a seaman for purposes of the Jones Act. View "Dize v. Ass'n of Md. Pilots" on Justia Law

Petitioner was appointed the Police Commissioner of Baltimore City by the Mayor. Petitioner and the Mayor entered into a memorandum of understanding (MOU) that addressed the terms and conditions of Petitioner's employment, including his removal as Commissioner. The Mayor and City Council (Respondents) later relieved Petitioner of his command. Petitioner filed an amended complaint against Respondents seeking reinstatement and money damages. The circuit court granted summary judgment to Respondents. The intermediate appellate court reversed, holding that the Mayor did not have the authority to remove a Police Commissioner pursuant to a contract providing for removal without cause, and therefore, the removal provisions of the MOU were invalid. The Court of Appeals affirmed. Petitioner subsequently filed a motion for writ of mandamus or motion for injunction or reinstatement. The circuit court denied the motion and granted summary judgment to Respondents. The court of special appeals affirmed. The Court of Appeals affirmed, holding (1) because this Court did not decide the merits of Petitioner's claims for reinstatement and monetary damages, Petitioner was not entitled to reinstatement or judgment as a matter of law; and (2) the court of special appeals did not err in granting Respondents' summary judgment motion and denying Petitioner's motion for partial summary judgment. View "Clark v. O'Malley" 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

The Maryland Transit Administration (MTA) fired Plaintiff, a bus operator that suffered from a heart condition. MTA terminated Plaintiff's employment for failing to meet the standard adopted by the State establishing that an individual is not qualified to drive a commercial motor vehicle if that individual suffers from certain cardiovascular diseases. The standard had previously been adopted by the United States Department of Transportation (DOT). Plaintiff brought this action in the circuit court, alleging that the MTA violated his rights under the Americans with Disabilities Act (ADA). After a jury trial, MTA was found guilty of discrimination. The court of special appeals reversed, holding that Plaintiff's inability, because of his heart condition, to meet the DOT standards rendered him unqualified as a matter of law for an MTA bus operator position. The Supreme Court affirmed, holding (1) as a matter of law, the MTA's use of the federally-created qualification standard governing drivers suffering from cardiovascular disease satisfied the ADA's requirements of being "job-related" and of "business necessity" and that "performance cannot be accomplished by reasonable accommodation"; and (2) because Plaintiff failed to meet this properly imposed qualification standard, he was not a "qualified individual" under the ADA. View "Zei v. Md. Transit Admin." on Justia Law