Wal Mart Stores, Inc. v. Holmes, 416 Md. 346 (2010).
Case Summary:
Following his wife’s death, Plaintiff sought to receive his wife’s Workers’ Compensation benefits under the Maryland Workers’ Compensation Act, Md. Code §9-632, which states that a spouse may receive benefits when the deceased had a “legal obligation to support” the surviving spouse. Plaintiff’s Maryland workers’ compensation lawyer argued that marriage is, in itself, a legal obligation. The court rejected this argument and held that the legislature’s intent was merely to award benefits to those dependent upon the income of the deceased. The court held that Plaintiff was not owed benefits under the language of the Maryland Workers’ Compensation Act, Md. Code §9-632.
Parties:
Plaintiff: Larry Holmes
Defendant: Walmart Stores, Inc. (Plaintiff’s wife was getting Walmart workers’ compensation benefits.)
Procedural History:
1. Mrs. Holmes’s comp attorney filed post-mortem issues with the Workers’ Compensation Commission seeking permanent disability benefits to pass to Plaintiff.
2. On September 19, 2007, Workers’ Compensation Commission determined that Plaintiff was not dependent.
3. On October 3, 2007, Commission found Plaintiff presented insufficient evidence of a “legal obligation to support” him as per §9-632 of the Maryland Workers’ Compensation Act.
4. Plaintiff filed Petition for Judicial Review; trial court granted Defendant’s motion for summary judgment and affirmed Commission order.
5. Plaintiff filed timely appeal to the Court of Special Appeals, which reversed trial court judgment on September 2, 2009.
6. Court of Appeals granted certiorari.
Relevant Facts:
1. Mrs. Holmes suffered compensable injury on November 3, 1999 during employment with Wal Mart.
2. Mrs. Holmes was granted temporary total disability benefits following her claim; those benefits ended on November 28, 2006.
3. Mrs. Holmes’s death on December 4, 2006 prevented her from appealing the end of her Worker’s Compensation.
Issue:
Does §9-632 include the marriage bond as a legal obligation to support, even in the absence of any legal ruling or order to pay support?
Arguments:
Plaintiff: The marriage bond is a legal obligation to support until either given up by a spouse or by law.
Defendant: Marriage alone does not create a legal obligation.
Decision:
Court of Special Appeals judgment reversed and case remanded. Plaintiff is not owed spouse’s Workers’ Compensation benefits from WalMart because he is not a dependent or owed legal obligation.
Rule:
Marital tie is not enough to create a legal obligation as included in §9-632’s language.
Rationale:
1. Including the marital tie as a legal obligation would overreach General Assembly’s intent.
2. The legislature had a trend of providing benefits to those who depended on employee’s earnings, as evidenced by its elimination of personal representatives as beneficiaries.
3. Prior to the Equal Rights Amendment, there was a legal obligation by marital tie, for a husband to support his wife, but even then, marriage was not the only consideration.
4. An obligation that cannot be enforced is not legal.
Other Notes/Dicta:
1. Phrase “legal obligation to support” is ambiguous.
2. Ruling in Cruickshank-Wallace that stated a spouse will not willfully fail to provide support is not the same as an obligation to provide it.
3. Had obligation existed, Plaintiff is correct that the obligation is gender neutral.
Dissent:
This is not a matter of the relationship between Plaintiff and spouse for support but instead a duty to prevent a spouse from becoming dependent upon the state for support.
