Maryland High Court Upholds Employer Immunity in Ledford v. Jenway Contracting
On July 1, 2025, the Supreme Court of Maryland issued a closely watched decision in Summer Ledford v. Jenway Contracting, Inc. (No. 3, Sept. Term 2024), reaffirming a bedrock principle of workers’ compensation law: the exclusive-remedy rule under the Workers’ Compensation Act shields employers from civil liability in wrongful death lawsuits arising out of workplace accidents.
John Ledford, an employee of Jenway Contracting, tragically died from a work-related fall in 2021. His minor child and wife, who were financially dependent upon him, sought and received benefits under the Workers’ Compensation Act. His adult daughter, Summer Ledford, was not considered an eligible dependent and instead filed a wrongful death lawsuit against Jenway Contracting, seeking damages outside of the workers’ compensation system.
Jenway Contracting argued that the Workers’ Compensation Act barred the wrongful death lawsuit. The trial court agreed, granting the employer’s Motion to Dismiss, and the Appellate Court of Maryland upheld the dismissal. Maryland’s high court has now affirmed those rulings.
In a 4-3 decision, the Supreme Court of Maryland held that the Workers’ Compensation Act is the exclusive remedy for workplace injuries and deaths, applying equally to dependent and non-dependent survivors. Meaning, employers who comply with the Act cannot be exposed to duplicative wrongful death suits from non-dependent family members. In situations where an employee has no dependents, the legislature has already provided for limited benefits, such as funeral and medical expense reimbursement.
Justice Eaves, writing for the majority, emphasized §9-509’s plain language and the General Assembly’s design to limit employer liability to benefits under the Act. This makes workers’ compensation the sole avenue for recovery, protecting both employees and employers by keeping workplace claims within a uniform framework.
This ruling is significant for employers across Maryland, as it prevents double liability and upholds legislative intent to ensure that job-related injuries and fatalities will remain addressed exclusively within the workers’ compensation system. Additionally, it reinforces exposure predictability for businesses in terms of planning insurance and safety programs. The Court’s decision sends a clear message: as long as employers fully comply with Maryland’s Workers’ Compensation Act, they remain protected from outside wrongful death litigation.
Written by Stephanie M. O’Neill, Esq.
