Justia Maryland Supreme Court Opinion Summaries

Articles Posted in Labor & Employment Law
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The Supreme Court affirmed the decision of the appellate court affirming the circuit court's grant of summary judgment in favor of Defendant in this action brought under the Maryland Health Care Worker Whistleblower Protection Act (the Act), Md. Code Ann., Health Occ. (HO) 1-501 through 1-506, holding that Plaintiff was not entitled to relief on her allegations of error.Specifically, the Supreme Court held (1) the lower court did not err by requiring Plaintiff to show that the protected conduct was the but-for cause of the challenged personnel action; (2) a plaintiff may avail herself of the burden-shifting framework established by McDonnell Douglas to prove but-for causation; (3) Plaintiff failed to genuinely dispute Defendant's evidence that she was terminated for reasons unrelated to her alleged protected disclosure; and (4) the circuit court did not err by granting judgment to Defendant as a matter of law. View "Romeka v. RadAmerica II, LLC" on Justia Law

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The Supreme Court held that Jacob Bennett was not barred from serving on the Harford County Council because of his employment as a schoolteacher by the Harford County Board of Education, thus reversing the contrary order and declaratory judgment of the circuit court.After Bennett was elected to the Council in the November 2022 general election a dispute arose between Bennett and Harford County concerning whether he was precluded from serving simultaneously as a member of the Council and as an employee of the Board by either section 207 of the Harford County Charter or the common law doctrine of incompatible positions. The circuit court ruled in favor of the County on the basis that the Board should be treated as a County for purposes of Charter 207. The Supreme Court reversed, holding that neither Charter 207 nor the doctrine of incompatible positions barred Bennett from simultaneously serving as a member of the Council and an employee of the Board. View "Bennett v. Harford County" on Justia Law

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The Supreme Court affirmed the judgment of the circuit court granting Defendant's motion to dismiss Petitioner's petition for judicial review of a decision of a hearing examiner with the Fire and Police Employees' Retirement System for the City of Baltimore denying Petitioner's request for line-of-duty disability retirement, holding that the petition was untimely.Petitioner, a police officer, sustained an injury during a car accident that occurred while he was responding to an emergency call. A copy of the hearing examiner's decision denying line-of-duty disability retirement but granting him non-line-of-duty disability retirement. At issue was whether former Chief Judge Mary Ellen Barbera's administrative tolling order issued in response to the COVID-19 pandemic applied to Defendant's case. The circuit court concluded that the extension applied only to deadlines that were tolled during the closure of the clerks' offices between March 16, 2020 and July 20, 2020. The appellate court certified the question of whether the fifteen-day extension applied to all cases whose statute of limitations and deadlines related to initiation expired between those dates. The Supreme Court answered the question in the negative, holding that the fifteen-day extension under the administrative tolling orders applied only to cases with deadlines that were suspended during the closure of the clerks' offices between the relevant dates. View "In re Hosein" on Justia Law

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The Supreme Court answered three questions certified by the United States District Court for the District of Maryland in this suit brought against Catholic Relief Services-United States Conference of Catholic Bishops (CRS), which follows the teaching that marriage is between one man and one woman.The district court ruled (1) CRS violated Title VII of the Civil Rights Act of 1964 by revoking Plaintiff's dependent health insurance because he was a man married to another man; and (2) Plaintiff was entitled to summary judgment on his federal Equal Pay Act claim. The court then ordered the parties to confer and file proposed questions of law with respect to the Maryland Fair Employment Practices Act (MFEPA), Md. Code Ann., State Gov't 20-606, and the Maryland Equal Pay for Equal Work Act (MEPEWA), Md. Code Ann., Lab. & Empl. 3-304. The Supreme Court answered (1) the prohibition against discrimination on the basis of sex in MFEPA does not itself also prohibit sexual orientation discrimination, which is separately covered under MFEPA; (2) MEPEWA does not prohibit sexual orientation discrimination; and (3) MFEPA's religious entity exemption applies with respect to claims by employees who perform duties that directly future the core mission of the religious entity. View "Doe v. Catholic Relief Services" on Justia Law

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The Supreme Court held that the Maryland Tort Claims Act's (MTCA), Md. Code Ann. State Gov't (SG) 12-104(a)(1), waiver of sovereign immunity as to a "tort action" does not extend to federal statutory claims.Plaintiff brought this action against Defendants, her former employer and supervisor, regarding her termination from Morgan State University (MSU). Because Plaintiff included claims of retaliation in violation of the National Defense Authorization Act (NDAA), 41 U.S.C. 4712, and the American Recovery and Reinvestment (ARRA), Pub. L. No. 11-5, 1553 Defendants removed the suit to federal district court. The district court dismissed the action with prejudice. The United States Court of Appeals for the Fourth Circuit vacated the district court's order and remanded the matter with directions to address whether Maryland has waived state sovereign immunity against federal whistleblower claims by enacting the MTCA. The district court answered the question in the negative. The Supreme Court answered an ensuing certified question by holding that "a tort action" under the MTCA does not include federal statutory claims. View "Williams v. Morgan State University" on Justia Law

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The Court of Appeals affirmed the judgment of the court of special appeals affirming the circuit court's judgment affirming the decision of the Maryland Workers' Compensation Commission granting Respondent's request for compensation for his hernia, holding that the court of special appeals did not err.In granting Respondent's request for compensation, the Commission found that Respondent sustained an accidental injury during employment, that his current hernia was the result of the accidental injury, and that, as a result of the hernia, Respondent was totally disabled for several months. The circuit court and court of special appeals affirmed. The Court of Appeals affirmed, holding that the court of special appeals did not err when it (1) held that "definite proof" under L&E 9-504(a)(1) applies to the quality of evidence presented and not the standard of proof a claimant must meet; and (2) concluded that Respondent met his burden of persuasion when producing medical evidence to a preponderance of the evidence standard. View "United Parcel Service v. Strothers" on Justia Law

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The Court of Appeals affirmed the decision of the court of special appeals affirming the circuit court's grant of summary judgment in favor of Montgomery County in this workers' compensation case, holding that there was no error in the proceedings below.In 2007, Petitioner, a firefighter in Montgomery County, experienced a service-related back injury, which led to his retirement three years later. Petitioner subsequently developed a compensable degree of occupational hearing loss related to his employment and sought workers' compensation benefits. Although the Workers' Compensation Commission awarded Petitioner compensation for his hearing loss the Commission determined that the entirety fo the award be offset under Md. Code, Lab. & Empl. (LE) 9-610. The Court of Appeals affirmed, holding that Petitioner's service-connected total disability retirement benefits arising from his back injury were "similar" to his permanent partial disability benefits, and the benefits related to his occupational hearing were offset under LE 9-610. View "Spevak v. Montgomery County" on Justia Law

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The Court of Appeals held that the trial courts in these two labor and employment cases erred in granting summary judgment at the conclusion of the workers' evidence at trial because genuine issues of material fact existed.At issue was whether construction workers were entitled to unpaid wages or overtime wages for the time that they waited and traveled between a parking area where their employers directed them to park and a construction site where they performed physical labor. Specifically at issue was whether the Portal-to Portal Act, 29 U.S.C. 251 to 262, has been adopted or incorporated into Maryland law, in which cases the workers' wait and travel time of approximately two hours would not be compensable. The trial courts granted summary judgment in favor of the employers and dismissed all claims. The court of special appeals affirmed. The Court of Appeals reversed, holding that there was genuine disputes of material fact as to whether the workers were entitled to compensation under Code of Maryland Regulations 09.12.41.10. View "Amaya v. DGS Construction, LLC" on Justia Law

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The Court of Appeals affirmed the judgment of the court of special appeals reversing the judgment of the circuit court denying Respondents' motion to dismiss Petitioner's petition for judicial review of the decision of the Workers' Compensation Commission summarily denying Petitioner's second request for modification of an earlier order, holding that the circuit court erred.The Commission issued an order approving Petitioner's request for four additional weeks of physical therapy for her left shoulder that was injured due to a workplace accident. More than three years later, Petitioner filed a request for modification of the earlier order denying her request for authorization of surgery. The Commission denied the request without a hearing. Petitioner then filed a second request for modification, which the Commission denied without a hearing. The circuit court denied Petitioner's petition for judicial review. The court of special appeals reversed. The Supreme Court affirmed, holding that the Commission's summary denial of Petitioner's request for modification was not subject to judicial review. View "Sanders v. Board of Education of Harford County" on Justia Law

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The Court of Appeals affirmed the judgment of the circuit court ruling that Baltimore City had breached its contract with two out of three sub-classes of police officers and firefighters and finding that Ordinance 10-306 retrospectively divested the members of those sub-classes of benefits they had earned, holding that there were no factual or legal errors in the circuit court's rulings.Baltimore City maintained a Fire and Police Employees' Retirement System (the Plan) to provide pension benefits to members of the City's police and fire departments. In 2010, the City enacted Ordinance 10-306, under which the City changed some of the key terms of the Plan. Plaintiffs commenced a class action lawsuit alleging claims for declaratory relief and breach of contract. The circuit court certified a class of plaintiffs and three sub-classes: a retired sub-class, a retirement-eligible sub-class, and an active sub-class. The circuit court granted judgment for all but the active sub-class, ruling that, as to currently employed members who had not yet reached retirement eligibility, Ordinance 10-306 did not affect vested benefits. The Court of Appeals affirmed, holding that the Ordinance retrospectively divested retired and retirement-eligible members of the benefits they had earned. View "Cherry v. Mayor & City Council of Baltimore" on Justia Law