Understanding Workers’ Compensation Claims in Maryland

“Maryland's Workers' Compensation Act (the Act), which has been in existence for over eighty years, is intended to protect workers and their families from the various hardships that result from employment-related injuries.” (See Queen v. Agger (1980) 287 Md. 342, 343, 412 A.2d 733, 734; Martin v. Beverage Capital Corporation (1999) 353 Md. 388, 398.)

“The fundamental purpose of the Workers' Compensation Act is not simply to reimburse injured employees for medical expenses. Instead, the Workers' Compensation Act is designed to provide workers with compensation for loss of earning capacity resulting from accidental injury, disease or death arising out of and in the course of employment, to provide vocational rehabilitation, and to provide adequate medical services.” (See Hundt v. Baltimore (1997) 345 Md. 105, 118; Queen v. Agger (1980) 287 Md. 342, 343, 412 A.2d 733, 734; Bethlehem-Sparrows Shipyard v. Damasiewicz (1947) 187 Md. 474, 480, 50 A.2d 799, 802 [The general purpose of the [Workers'] Compensation Act is to provide compensation for loss of earning capacity resulting from accidental injuries sustained in industrial employment].)

“[T]he worker's compensation statutory scheme was designed to protect workers and their families from hardships inflicted by work-related injuries.” (See In re Zukowski, No. 1121-2022, at *10 (Md. Ct. Spec. App. Jan. 31, 2024).)

“More particularly, it is designed to provide workers with compensation for loss of earning capacity resulting from accidental injury, disease or death arising out of and in the course of employment, to provide vocational rehabilitation, and to provide adequate medical services.” (See id.)

Maryland Rules for Workers’ Compensation

Title 9 of the Code of Maryland under Labor and Employment governs Workers’ Compensation.

“Except as otherwise provided, each employer of a covered employee shall provide compensation in accordance with this title to:

1. the covered employee for an accidental personal injury sustained by the covered employee; or
2. the dependents of the covered employee for death of the covered employee:(i) resulting from an accidental personal injury sustained by the covered employee; and(ii) occurring within 7 years after the date of the accidental personal injury.”

(See Md. Code, Lab. & Empl. § 9-501(a).)

“An employer is liable to provide compensation in accordance with subsection (a) of this section, regardless of fault as to a cause of the accidental personal injury.” (See Md. Code, Lab. & Empl. § 9-501(b).)

Prima Facie Case for Workers’ Compensation Claim

“To be compensable, an accidental injury arising out of employment must also arise in the course of that employment.” (See Montgomery Cnty. v. Maloney (2020) 226 A.3d 824, 837; Lab. & Empl. § 9-101(b).)

“This depends on the time, place, and circumstances of [the] injury relative to [the] employment.” (See id; Calvo v. Montgomery Cnty. (2018) 459 Md. 315, 329.)

“Our cases have often explained that to meet this second requirement for compensability, injuries must occur:

1. during the period of employment,
2. at a place where the employee reasonably may be in performance of his or her duties, and
3. while fulfilling those duties or engaged in something incident thereto.”

(See Montgomery Cnty. v. Maloney (2020) 226 A.3d 824, 837; Schwan Food Co. v. Frederick (2019) 241 Md. App. 628, 653; Montgomery County v. Wade (1997) 345 Md. 1, 11.)

“This formulation is not a precise rubric, however. These are factors to be considered, not essential elements, and the absence of one of these factors will not necessarily be dispositive. Rather, deciding whether an injury arose in the course of employment is a fact-specific inquiry.” (See Montgomery Cnty. v. Maloney (2020) 226 A.3d 824, 837; State v. Okafor (2015) 225 Md. App. 279, 286, 123 A.3d 698.)

“It requires the fact-finder to consider the entire sphere and period of employment ... and also whether the employee has placed himself outside his employment, and, if so, how far. To arise in the course of employment, injuries need not result from actual manipulation of the tools of work or be sustained during the exact hours of work. They need only arise within the time and space boundaries of the employment, and in the course of an activity whose purpose is related to the employment.” (See Montgomery Cnty. v. Maloney (2020) 226 A.3d 824, 837; Prince George's Cnty. v. Proctor (2016) 228 Md. App. 579, 588; Livering v. Richardson's Restaurant (2003) 374 Md. 566, 577; Montgomery County v. Wade (1997) 345 Md. 1, 11.)

Standard of Review/Burden of Proof for Workers’ Compensation Claims

“When the trial court holds an essential trial de novo under [Lab. & Empl.] § 9-745(d) to resolve a question of fact, the trial court has acted as trier of fact, and, as a result, we review the decision of the trial court as we would in any other bench trial.” (See Montgomery Cnty. v. Maloney (2020) 226 A.3d 824, 833; McLaughlin v. Gill Simpson Electric (2012) 206 Md. App. 242, 253, 47 A.3d 1074.)

“We give due regard to the trial court's role as fact-finder and will not set aside factual findings unless they are clearly erroneous. The appellate court must consider evidence produced at the trial in a light most favorable to the prevailing party and if substantial evidence was presented to support the trial court's determination, it is not clearly erroneous and cannot be disturbed.” (See id.)

“Questions of law, however, require our non-deferential review. When the trial court's decision involves an interpretation and application of Maryland statutory and case law, our Court must determine whether the [trial] courts conclusions are legally correct. Where a case involves both issues of fact and questions of law, this Court will apply the appropriate standard to each issue.” (See id.)

“[T]he question of whether an injury arises out of and in the course of employment is a factual one—or a mixed question of law and fact—as long as there are facts in dispute or if opposing inferences can reasonably be drawn from undisputed facts. Accordingly, when the circuit court concludes after an "essentially" de novo trial that an injury arose out of or in the course of employment, we review that conclusion only for clear error.” (See Montgomery Cnty. v. Maloney (2020) 226 A.3d 824, 833-34; Board of Education v. Spradlin (2005) 161 Md. App. 155, 216 [The circuit court was affirmatively persuaded that the claimant had suffered an injury in the course of her employment, and the evidence amply supported that decision. The judge's ultimate de novo decision, therefore, was not clearly erroneous]; see also Abell v. Albert F. Goetze, Inc. (1967) 245 Md. 433, 439, 226 A.2d 253 [We certainly cannot say [the judge's] finding, that the appellant did not receive an injury ... in the course of his employment, was clearly in error]; Turner v. State, Office of the Public Defender (1985) 61 Md. App. 393, 405, 486 A.2d 804 [concluding that circuit judge's factual findings that claimant's injury did not arise out of or in the course of his employment were not erroneous at all, much less clearly erroneous].)

“So long as there is competent or material evidence in the record to support the court's conclusion[s] we will affirm.” (See id; Board of Education v. Spradlin (2005) 161 Md. App. 155, 166.)

Legal Precedents and Case Law on Workers’ Compensation Claims

It is well settled that “an injury arises out of employment when there is a causal connection between the employment and the injury such that the injury results from some obligation, condition, or incident of employment.” (See Prince George's Cnty. v. Proctor (2016) 228 Md. App. 579, 588; Livering v. Richardson's Rest. (2003) 374 Md. 566, 574, 823 A.2d 687 (citing Montgomery County v. Wade (1997) 345 Md. 1, 9, 690 A.2d 990.)

“An incapacity to work in one set of conditions applicable to a particular job does not necessarily indicate or equate with an incapacity to perform the work in an occupation. Whether a disablement suffices to be occupational in scope would depend, at least in part, upon how the occupation is defined and how much of the range of activity fairly included within the occupation is in fact foreclosed to the claimant. If, indeed, the claimant is able to continue to perform reasonably analogous work within the same occupational classification[,] . . . he is not incapacitated `from performing his work in the last occupation.'” (See Smith v. Howard (2007) 177 Md. App. 327, 334; Helinski v. C P Telephone Co. (1996) 108 Md.App. 461, 472, 672 A.2d 155.)

Current as of April 01, 2024 | Updated by Trellis Law Content Team

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