Justia Maryland Supreme Court Opinion Summaries

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

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

The Supreme Court reversed the decision of the appellate court affirming the order of the circuit court granting summary judgment in favor of Defendants and dismissing Plaintiff's negligence claim, holding that the circuit court abused its discretion in granting Defendants' motion to preclude the opinions and testimony of Dr. Steven Elliot Caplan, Plaintiff's designated expert in the area of pediatric medicine.Plaintiff alleged that Defendants, who owned and managed property in which Plaintiff lived as a child, were liable for injuries she sustained as a result of exposure to lead-based paint at the property. After Plaintiff designated Dr. Caplan as her expert Defendants moved to preclude his opinions and testimony. The circuit court granted the motion and then entered summary judgment for Defendants, finding that Dr. Caplan lacked a sufficient factual basis for his opinions and that, without his testimony as to causation, Plaintiff was unable to establish a prima facie case of negligence. The Supreme Court reversed, holding (1) in ruling on the motion to preclude, the circuit court erroneously resolved genuine disputes of material fact; (2) therefore, the circuit court erred in granting summary judgment; and (3) Plaintiff presented sufficient evidence to establish a prima facie case of negligence. View "Oglesby v. Baltimore School Associates" on Justia Law

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

In this appeal centering on the existence of a valid arbitration agreement the Court of Appeals affirmed the decision of the court of appeals reversing the judgment of the circuit court, holding that the circuit court erred in compelling arbitration of the question of whether the arbitration clause in the agreements at issue was valid.The arbitration clause in this case stemmed from transactions between lead paint tort plaintiffs who received structured settlements and affiliated factoring companies that specialize in purchasing structured settlement rights. Defendants filed motions to compel arbitration and stay the case, but Plaintiffs challenged the existence of a valid agreement to arbitrate. The trial court granted the motion to compel arbitration, finding that the arbitrator was to determine the issue of arbitrability. The Court of Special Appeals reversed. The Court of Appeals affirmed, holding that the circuit court erroneously compelled arbitration and that the issue of whether a valid arbitration agreement exists is an issue for the court to determine. View "Access Funding, LLC v. Linton" on Justia Law

The Court of Appeals affirmed the decision of the court of special appeals affirming the judgment of the circuit court granting Defendants' respective motions to dismiss the underlying survivorship and wrongful death action in which Plaintiffs sought damages arising from the death of Kyle Hancock, holding that there was no error or abuse of discretion.Hancock was working for R.F. Warder when he was buried alive at an excavation site. Warder was an independent contractor hired by the City of Baltimore to perform the excavation work. Because Plaintiffs were barred from bringing negligence claims against Warder, Plaintiffs named as defendants the City and Keith Sutton, who was on site at the time of the accident. The circuit court granted Defendants' motions to dismiss. The court of special appeals affirmed. The Court of Appeals affirmed, holding (1) one who hires an independent contractor is not liable to the contractor's employee for injuries caused by the contractor’s negligence in performing the work for which it was hired; and (2) the duty of a contractor or subcontractor on a construction job to exercise due care to provide for the safety of the employees of other contractors or subcontractors is owed with respect to conditions that the contractor or subcontractor creates or over which it exercises control. View "Hancock v. Mayor & City Council of Baltimore" on Justia Law

The Court of Appeals affirmed the decision of the circuit court granting the motion for judgment notwithstanding the verdict filed by Prince George's Hospital Center of Dimensions Health Corporation (Hospital) after the jury returned a verdict finding that the Hospital was vicariously liable for a surgeon's negligence, holding that there was ample evidence supporting the jury's finding that the surgeon was the apparent agent of the Hospital.Plaintiff was treated by a surgeon after motor vehicle crash who inflicted further injuries by failing to exercise the standard of care expected of trauma surgeons. The jury returned a verdict finding that the surgeon was negligent and directly liable. The jury then found that the surgeon was an agent of the Hospital and that the Hospital was vicariously liable for the surgeon's negligence. The circuit court granted the Hospital's judgment notwithstanding the verdict, concluding that there was insufficient evidence to show that the surgeon was an agent of the Hospital. The court of special appeals affirmed. The Court of Appeals reversed, holding that there was ample evidence that supported the jury's finding that the surgeon was the apparent agent of the Hospital. View "Williams v. Dimensions Health Corp." on Justia Law

The Court of Appeals affirmed the decision of the court of special appeals affirming the judgment of the circuit court granting summary judgment in favor of Defendants in this wrongful death action, holding that the lower courts correctly decided Plaintiff's claim because he pleaded a loss of chance case, which is not recognized in Maryland.After Stephanie Wadsworth died of breast cancer, Plaintiff, her husband, brought this survival action and wrongful death action against several healthcare providers, including Defendants. Defendants moved for summary judgment, asserting that the legal theory upon which Plaintiff's lawsuit was based - the loss of chance doctrine - was not recognized in Maryland. The trial court granted the motion. The Court of Appeals affirmed, holding that the circuit court correctly determined that Plaintiff's case was a loss of chance case, which is not recognized in Maryland. View "Wadsworth v. Sharma" on Justia Law

The Court of Appeals affirmed the judgment of the court of special appeals reversing the trial court's grant of summary judgment in favor of Irwin Industrial Tool Company in this wrongful death and product liability action brought by the Estate of Richard Pifer, holding that the grant of summary judgment based on the determination that there was not admissible evidence on which to challenge Irwin's request for summary judgment was erroneous.The Estate brought this action alleging that Irwin sold Strait-Line marking chalk that contained asbestos and caused Pifer's death from mesothelioma. Irwin filed a pretrial motion in limine to exclude evidence regarding an analysis of Strait-Line chalk by the Estate's expert that had results in a finding of asbestos. The circuit court granted the motion as to some of the evidence and then entered summary judgment for the Estate. The court of special appeals reversed. The Supreme Court affirmed, holding (1) the evidence at issue was properly authenticated, and therefore, the circuit court abused its discretion in granting the Estate's motion in limine; and (2) the grant of summary judgment was erroneous. View "Irwin Industrial Tool v. Pifer" on Justia Law

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