Brethren Mutual Insurance v. Buckley, 437 Md. 332

Buckley, Buckley’s UM insurer Brethren, and Betts/geico involved in a motor vehicle accident (Mar. 18, 2007).
GEICO offered $100,000 to settle Buckley’s claim against Betts; Buckley sought UM coverage for excess medical expenses.
Buckley notified Brethren of GEICO’s offer per Md. Ins. Art. §19-511; Brethren indicated it would waive subrogation against Betts.
Buckley signed a broad general release in favor of Betts and GEICO on Dec. 6, 2007, after receiving Brethren’s waiver of subrogation.
Buckley then sought UM benefits from Brethren; Brethren refused; circuit court granted Brethren summary judgment.
Court of Special Appeals held the release did not prejudice Buckley’s UM claim; Maryland Court of Appeals granted certiorari.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Scope of release under §19-511(e) post-settlement	Buckley argues §19-511(e) permits a broad release with no prejudice to UM claim	Brethren argues the release’s plain language encompasses all claims against all parties	Release read to limit prejudice to Buckley’s UM claim to GEICO/Betts, not Brethren

Bernstein v. Kapneck, 290 Md. 452 (Md. 1981) (general releases may extinguish broader claims absent policy barriers)
Pemrock, Inc. v. Essco Co., 252 Md. 374 (Md. 1969) (general release language can extinguish other liable parties)
Peters v. Butler, 253 Md. 7 (Md. 1969) (release of ‘all other persons’ may release others liable)
Federal Insurance Co. v. Allstate Ins. Co., 275 Md. 460 (Md. 1975) (statutory context may be read into contracts to define scope of coverage)
Prince George’s Country Club, Inc. v. Edward R. Carr, Inc., 235 Md. 591 (Md. 1964) (subsisting laws read into contracts; knowledge of statute by professionals)
Erie Ins. Exch. v. Heffernan, 399 Md. 598 (Md. 2007) (uninsured motorist protections liberal interpretation to protect victims)
Keeney v. Allstate Ins. Co., 130 Md. App. 396 (Md. App. 2000) (statutory purpose to facilitate settlement of underinsured/motorist claims)