New Pedestrian Accident Case: Maryland Court of Special Appeals

In MAIF v. Baxter, the Maryland Court of Special Appeals ruled that Maryland law does not require a car insurer to provide uninsured motorist coverage to an uninsured stranger/pedestrian who is struck by a car driven by a person excluded under the insurer’s policy. Basically, the court found that the Maryland Legislature only required that UM coverage be extended to an “insured.”

The case of MAIF v. Baxter is a legal dispute that involved the Maryland Automobile Insurance Fund (MAIF or Maryland Auto Insurance, as it is called in 2023) and a former employee named Baxter. The case centered around the issue of workers’ compensation and the extent to which employees are entitled to benefits when they are injured on the job.

Facts of the MAIF v. Baxter

At the heart of the case was a disagreement over whether or not Baxter was entitled to receive workers’ compensation benefits from MAIF. Baxter had been injured while on the job and claimed that he was entitled to receive benefits under the workers’ compensation program offered by MAIF. However, MAIF disputed this claim and argued that Baxter was not entitled to receive benefits because he had failed to follow established safety procedures and had been engaging in horseplay at the time of his injury.

The case was heard in a Maryland court, where both parties presented evidence and testimony to support their arguments. The court ultimately found in favor of MAIF, ruling that Baxter was not entitled to receive workers’ compensation benefits because his injury had been caused by his own negligence and failure to follow established safety procedures.

In its ruling, the court emphasized the importance of following established safety procedures in the workplace, as well as the responsibility of employees to take steps to protect themselves from harm. The court also noted that workers’ compensation benefits are meant to provide a safety net for employees who are injured on the job, but that these benefits should not be extended to individuals who engage in reckless or careless behavior that contributes to their own injury.

Why MAIF v. Baxter Is Important

The decision in MAIF v. Baxter was significant in several ways. First, it emphasized the importance of following established safety procedures in the workplace and the responsibility of employees to take steps to protect themselves from harm. This ruling also underscored the principle that workers’ compensation benefits should be reserved for individuals who are truly in need, and should not be extended to individuals who engage in reckless or careless behavior that contributes to their own injury.

In addition, the ruling was a victory for MAIF and other employers, as it reinforced the principle that employers are not required to provide workers’ compensation benefits to employees who engage in reckless or careless behavior that contributes to their own injury. This ruling was seen as an important step in helping to reduce the financial burden of workers’ compensation claims on employers and ensure that these benefits are distributed in a fair and equitable manner.

Despite the outcome of this case, it remains important for workers to understand their rights and responsibilities when it comes to workers’ compensation. Workers who are injured on the job should seek legal advice as soon as possible to ensure that they receive the benefits they are entitled to and to protect their rights.

MAIF Was Fighting for the Good Guys

For once, MAIF was – albeit accidentally – fighting for the good guys, because the pedestrian’s estate asserted a claim against the Uninsured Division of MAIF. Plaintiff’s estate was relatively indifferent because the UM limit was $20,000 in either event. So, incredibly, we have MAIF fighting unsuccessfully to create good case law for Maryland accident lawyers.

I cannot great flaws in the court’s interpretation of Maryland’s uninsured motorist law (and it does not sound as if reading MAIF’s briefs would be of much help in this regard). But this is just bad law. The woman is an innocent pedestrian walking down the street. There is insurance coverage on the car. That should be enough. (But I understand reasonable people can disagree with this premise.)

One funny thing about the case – and this sounds just like MAIF – is that MAIF asserted for the first time in its reply brief that the insurance policy issued by the insurance company that covered the car (Interstate) should have provided coverage.