Appiah v. Hall
416 Md. 533
| Md. | 2010Background
- Seagirt Marine Terminal is owned by the Maryland Port Administration (MPA) and operated by P & O Ports of Baltimore, Inc. under contract.
- Marine Repair Services, a contractor on Reefer Row, connected reefers to shore power and monitored temperatures.
- Mr. Appiah, a Marine Repair employee, was fatally injured when a truck driver (Bruce Hall) backed toward a reefer while Appiah was between truck and reefer.
- The circuit court granted summary judgment to MPA and P & O, holding they were not liable as employers for independent-contractor negligence due to lack of control over the contractors’ methods.
- The Court of Special Appeals affirmed, holding Petitioners failed to show the required retention of control over the specific work that caused the injury.
- The Maryland Court of Appeals granted certiorari to address whether summary judgment was proper and whether the Restatement § 414 control-retention standard was misapplied.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether Respondents retained sufficient control under Restatement §414 | Appiah argues MPA/P&O controlled the injury-causing work | Appointing and general safety duties do not prove control over operative details | No genuine dispute on control; summary judgment proper |
| Whether material facts about control were disputed to require a jury | There are disputed facts about safety protocols and investigations indicating control | Disputes are immaterial to control of the specific injurious act | No material factual disputes on control; trial court proper |
| Whether safe-workplace or landowner duties establish liability independent of control over methods | Safe-workplace/landowner duties create liability | These duties do not apply where injury arises from contractor’s operative work | These theories do not establish liability under §414 in this context |
| Whether actual-fault theory supports liability for retained control over the injury's very cause | Retaining control over the precise act causing injury supports liability | No retention of control over the operative detail; no liability under actual fault | Not proven; Respondents entitled to judgment as a matter of law |
Key Cases Cited
- Gallagher's Estate v. Battle, 209 Md. 592 (1956) (employer liable only if controls operative details of work)
- Rowley v. Baltimore, 305 Md. 456 (1986) (safe workplace doctrine; liability for land possessors depends on injury from condition, not contractor work)
- Wajer v. Baltimore Gas & Electric Co., 157 Md.App. 228 (2004) (retention of control requires control over the very thing that caused the injury)
- Inner Harbor Warehouse, Inc. v. Myers, 321 Md. 363 (1990) (independent-contractor definition and control principles in Maryland)
- Beatty v. Trailmaster Prods., Inc., 330 Md. 726 (1993) (summary judgment standard guiding disputes on material facts)
- O'Connor v. Balt. County, 382 Md. 102 (2004) (summary judgment standard and material-fact inquiry)
- Mr. Appiah v. Hall, 7 A.3d 536 (2010) 416 Md. 533 (Md. Ct. App. 2010) (lead opinion establishing retention-of-control framework and affirming judgment)