Maryland Sound Industries, Inc. v. Simmons, et al
28 FLW D904
The issue in this case is whether non-economic damages (pain and suffering) should be excluded from the total amounts payable to an injured worker in determining the amount of the workers' compensation lien.
Court determined that Maryland law did not specifically address whether an insurance company or employer could base its lien on the entire amount an employee recovers from a third party suit or whether the award for pain and suffering should be subtracted from the total award prior to calculating the lien. Court determined that the amount of the lien should be calculated using the total award or settlement and the amounts received for pain and suffering should not be deducted. This is consistent with Florida law.