Maryland Court Barred Employee Negligence Lawsuit
Assisted living operators should note that accepting workers' compensation awards bars further litigation.
Updated on Oct. 5, 2026 in Human Resources
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The Maryland Appellate Court affirmed summary judgment for Sunrise of Bethesda, ruling that an employee who accepted workers' compensation benefits cannot pursue a separate negligence lawsuit. The court concluded that the employee's choice constituted a binding election of remedies.
Why it matters
This ruling clarifies the scope of the exclusive remedy doctrine in Maryland, shielding employers from civil negligence suits once employees have sought and accepted workers' compensation for their injuries. It provides a clearer legal framework for businesses when handling workplace liability claims.
The ruling centered on Case No. C-15-CV-23-003007, affirming that the receipt of benefits via the state Workers' Compensation Commission acts as a binding election of remedies. The court effectively barred a negligence suit filed by an employee injured in January 2022.
The players
Sunrise of Bethesda
An assisted living facility operator serving seniors that was the defendant in the litigation.
Maryland Appellate Court
The state judicial body responsible for interpreting and enforcing employment and liability law.
Workers' Compensation Commission
The state agency tasked with administering benefit claims and resolving injury disputes for employees.
The details
The employee had previously attended a hearing to add psychological injuries to her existing workers' compensation claim, which resulted in a finalized award. The court determined this process established a legally binding election of remedies, preventing the claimant from seeking additional damages through civil litigation. Operators should understand that once an employee secures and accepts a state-mandated compensation award, the path to further negligence claims is effectively closed under current precedent.
Timeline
January 2022: The employee was assaulted by a resident at the Bethesda facility.
October 2, 2026: The appeals court upheld the decision to bar the negligence lawsuit.
Market Landscape
This decision reinforces the long-standing exclusive remedy doctrine within state labor law. It confirms that once an employee engages with the workers' compensation system, that administrative path becomes the definitive venue for recovery.
Owners and managers should ensure that the process for reporting workplace injuries is documented clearly to demonstrate when benefits are accepted. When facing litigation, consult with qualified counsel on whether previous commission awards can be leveraged as a defense against civil claims.
The takeaway
This ruling highlights the importance of tracking internal injury reporting against state-level claims activity. Operators should monitor their workers' compensation records regularly to verify when claims are finalized and accepted, as these milestones can serve as vital documentation in future legal defense.
Further reading
For broader guidance on managing liability, visit Human Resources.
Source note: This article includes information reported by Business Insurance.
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