Justia Maryland Supreme Court Opinion Summaries

In this workers’ compensation case, the Court of Appeals clarified an exception to the "going and coming rule" - the special mission or errand doctrine.Employee, who was employed by Montgomery County, was injured in a car accident while driving from her home to a mandatory work training on a Saturday, which was normally her day off. The Workers’ Compensation Commission awarded compensation, finding that Employee’s injury arose out of and in the course of employment. The County sought judicial review, arguing that the going and coming rule prohibited recovery because accidental injuries sustained while going to or coming from work do not ordinarily arise out of and in the course of employment, and none of the exceptions to the rule applied. The circuit court granted summary judgment for the County. The Court of Special Appeals affirmed. The Court of Appeals reversed, holding (1) the going and coming rule, rather than the traveling employee doctrine, controlled Plaintiff’s case; but (2) the undisputed facts permitted a reasonable conclusion that the special mission exception to the going and coming rule applied in this case. View "Calvo v. Montgomery County, Maryland" on Justia Law

At issue was what findings a court must make in order to require attorney’s fees to be paid to an adverse party who was subjected to proceedings that were brought in bad faith or lacked substantial justification and what the appropriate means are for calculating attorney’s fees when a court determines that a party’s complaint includes claims that have substantial justification and claims that lack substantial justification.Respondents prevailed in having the trial judge dispose of Petitioner’s claims after the close of the evidence. The hearing judge found no substantial justification for each of Petitioner’s claims against Respondents and awarded $300,000 in attorney’s fees to Respondents. The court of special appeals vacated the circuit court’s judgment, concluding that there was substantial justification as to some of Petitioner’s claims. The Court of Appeals affirmed, holding that the hearing judge (1) did not commit clear error in finding no substantial justification for the claims brought by Petitioner; but (2) abused his discretion in assessing $300,000 in attorney’s fees against Petitioner without articulating how he calculated his fees. View "Christian v. Maternal-Fetal Medicine Associates of Maryland, LLC" on Justia Law

At issue was what findings a court must make in order to require attorney’s fees to be paid to an adverse party who was subjected to proceedings that were brought in bad faith or lacked substantial justification and what the appropriate means are for calculating attorney’s fees when a court determines that a party’s complaint includes claims that have substantial justification and claims that lack substantial justification.Respondents prevailed in having the trial judge dispose of Petitioner’s claims after the close of the evidence. The hearing judge found no substantial justification for each of Petitioner’s claims against Respondents and awarded $300,000 in attorney’s fees to Respondents. The court of special appeals vacated the circuit court’s judgment, concluding that there was substantial justification as to some of Petitioner’s claims. The Court of Appeals affirmed, holding that the hearing judge (1) did not commit clear error in finding no substantial justification for the claims brought by Petitioner; but (2) abused his discretion in assessing $300,000 in attorney’s fees against Petitioner without articulating how he calculated his fees. View "Christian v. Maternal-Fetal Medicine Associates of Maryland, LLC" on Justia Law

The doctrine of imputed negligence does not apply to deem an owner-passenger of a motor vehicle contributorily negligent based on the negligence of a permissive driver of the owner-passenger’s vehicle and bar the owner-passenger from recovering compensation from a negligent third party.Here, Jeffrey Mintiens struck a car in which Victoria Worsley was seated. Ms. Worsley’s husband had driven the car to the spot where it was hit. Ms. Worsley filed suit alleging that Mr. Mintiens was negligent. Mr Mintiens raised the defense of contributory negligence. The district court concluded that Ms. Worlsey’s husband had been negligent and that his negligence should be imputed to Ms. Worsley under the doctrine of imputed negligence. Accordingly, the district court entered judgment for Mr. Mintiens. The circuit court affirmed. The Court of Appeals vacated the judgment of the circuit court and remanded with instructions to remand the case to the district court for further proceedings, holding that the imputed negligence doctrine did not apply under the circumstances of this case. View "Mintiens v. Worsley" on Justia Law

The Court of Appeals agreed with the lower courts that Petitioners’ arguments seeking to avoid the application of the caps in the Maryland Tort Claims Act (MTCA) and Md. Code Cts. & Jud. Proc. (CJ) 11-108, as well as the doctrine of sovereign immunity, were without merit.Petitioners were the estate and parents of a State prisoner who was murdered by a fellow prisoner. Petitioners brought suit against the State and various State officials and employees. Petitioners obtained a judgment against the State based on the jury’s finding that certain correctional officers were negligent and a judgment against one correctional officer based on the jury’s finding that he was grossly negligent. The circuit court limited the judgment against the correctional officer pursuant to the cap on noneconomic damages in CJ 11-108 and declined to include the State in the judgment against the correctional officer because the waiver of the State’s sovereign immunity in the MTCA does not extend to actions or omissions that are grossly negligent. The Court of Appeals affirmed the judgments of the lower courts, holding that Petitioners were not entitled to relief on their claims. View "Rodriguez v. Cooper" on Justia Law

At issue was when injuries from asbestos exposure “arise” for purposes of the statute of repose, Md. Code Cts. & Jud. Proc. 5-108.James Piper filed a complaint alleging that at the time he worked in connecting a new steam turbine generator to another turbine he was unknowingly exposed to asbestos as a result of installation of insulating material that contained asbestos. The insulation was installed in 1970. Piper was diagnosed with mesothelioma in 2013. In 2014, Piper filed suit against several defendants, including Respondent, which built the major components of the turbine and constructed the turbine. The circuit court granted summary judgment for Respondent. The court of special appeals affirmed, concluding that Piper’s cause of action did not “arise” or “accrue” until 2013, and therefore, the diagnosis of mesothelioma was outside of the twenty-year limitations period set forth in the statute of repose beginning with the operation of the turbine. The Supreme Court reversed, holding (1) for purposes of asbestos-related causes of action, an injury arises at the time of last exposure to the asbestos-laden product; and (2) because the statute of repose was enacted after the date of Piper’s injuries, as a matter of law, the statute did not bar Piper’s causes of action. View "Duffy v. CBS Corp." on Justia Law

At issue in this negligence case was the admission, under Maryland Rule 5-703(b), of Plaintiff’s medical records that a defense expert relied upon in forming his opinions. The circuit court granted a motion for judgment in favor of Plaintiff. Plaintiff sought damages in an amount from $50,000 to $150,000 but the circuit court entered judgment in the amount of $10,576.05. The court of special appeals affirmed. The Supreme Court affirmed, holding that the circuit court did not err or abuse its discretion in admitting Plaintiff’s post-accident medical treatment records into evidence under Maryland Rule 5-703. View "Lamalfa v. Hearn" on Justia Law

The Court of Appeals affirmed the judgment of the court of special appeals, which affirmed the trial court’s judgment on Robert Roman’s negligence count against Sage Title, LLC but reversed the trial court’s grant of judgment notwithstanding the verdict (JNOV) with respect to Roman’s conversion count.Roman sought to hold Sage Title liable under a theory of respondent superior for the action’s of Sage Title’s employee who, along with two other individuals, were purportedly part of a fraud scheme to which Roman fell victim. Roman also sought to hold Sage Title liable under a theory of direct negligence. The trial court granted Sage Title’s motion for a judgment with respect to the negligence count. The jury then returned a verdict in favor of Roman on the conversion count and awarded him $2.42 million in damages. The trial court granted Sage Title’s JNOV motion on the court of appeals. On appeal from the court of special appeals, the Court of Appeals held (1) the conversion claim was properly before the jury, and the jury was correct in entering its verdict on that count in favor of Roman; and (2) the trial court correctly granted Sage Title’s motion for judgment as to the negligence count. View "Sage Title Group, LLC v. Roman" on Justia Law

The Court of Appeals affirmed the finding of the Workers’ Compensation Commission (WCC) that Employer and Insurer (collectively, Respondents) were entitled to offset the ordinary disability benefits already paid to Petitioner against the temporary total disability benefits paid to him by Respondents.Petitioner suffered injuries primarily to his back and neck while working for Employer. Employer received two different sets of disability benefits from Employer and Insurer, each awarded by a different state agency. Specifically, Petitioner was granted temporary total disability benefits by the WCC and ordinary disability benefits by the State Retirement Agency. The WCC found that Respondents were entitled to a credit for the ordinary disability benefits already paid to Petitioner. On judicial review, the circuit court granted summary judgment in favor of the WCC. The Court of Appeals affirmed, holding that because both sets of benefits compensated Petitioner for the same injury, pursuant to Md. Code Ann. Lab. & Empl. 9-610, the statutory offset properly applied to prevent a double recovery for the same injury. View "Reger v. Washington County Board of Education" on Justia Law

Contractually-shortened limitations periods, such as the one at issue in this case, are valid only if there is no statute to the contrary, the provision is not the result of fraud, duress or misrepresentation, and the provision is reasonable in light of all relevant circumstances.Here a residential furnace maintenance agreement offered by Carroll Home Services, LLC (CHS) reduced the period for a consumer to bring a tort or contract claim against CHS from the statutory three years to one year. Petitioners, who had entered into a maintenance agreement with CHS, asserted tort and contract claims against CHS for damage to their residence allegedly caused by the company. Petitioners filed their complaint more than one year after their claims accrued but before the expiration of three years. The circuit court dismissed the complaint on the basis of the shortened limitations provision in the agreement. The Court of Appeals vacated the judgment of the circuit court and remanded the case for assessment as to whether the criteria for enforcement of the provision were met and whether the provision was reasonable. View "Ceccone v. Carroll Home Services, LLC" on Justia Law