Parry v. Allstate Insurance Company, 408 Md. 130

Summary

The Maryland Court of Appeals considered whether an insurer could reduce uninsured/underinsured motorist benefits by medical expenses paid by an employer under workers' compensation law, even though the employee's estate did not file a formal workers' compensation claim. The court held that the employer's payment of the medical expenses constituted recovered workers' compensation benefits under Maryland Insurance Article § 19-513(e), requiring reduction of the UM/UIM benefits. Because the payments exceeded the policy's available UM/UIM coverage, Allstate had no liability for additional benefits.

Holdings

1. Yes. Under Maryland Insurance Article § 19-513(e), an employee or representative has recovered workers' compensation benefits when the employer or its insurer pays medical expenses pursuant to workers' compensation law, even if no formal workers' compensation claim was filed.
2. Yes. Maryland Insurance Article § 19-513(e) mandates reduction of UM/UIM benefits by the amount of unreimbursed workers' compensation benefits received for the same circumstances, without regard to whether the payments compensated every element of the claimant's damages.

Questions Presented

1. Whether medical expenses paid by an employer or its workers' compensation insurer may be treated as workers' compensation benefits recovered under Maryland Insurance Article § 19-513(e) when the employee or representative did not file or independently pursue a formal workers' compensation claim.
2. Whether those unreimbursed workers' compensation payments were required to reduce the UM/UIM benefits payable under the Parrys' Allstate policy, resulting in no remaining liability because the payments exceeded the policy limit.

Disposition

affirmed