In the Matter of Bernard L. Collins, 228 A.3d 760

Background

Bernard L. Collins, a paid firefighter, filed a workers’ compensation claim for work-related heart disease/hypertension; the Commission found the disease compensable and fixed his average weekly wage.
In May 2015 Collins and his employer/insurers executed a Commission‑approved settlement in which Collins purported to release “dependents” and others from "any and all" present and future claims arising from his disability; Peggy Collins (his wife) was not a party and received no consideration.
Collins died in June 2017 of cardiac causes his widow says arose from the compensable occupational disease; Peggy Collins filed a new dependent’s claim for death benefits.
The Commission and the Calvert County circuit court denied/affirmed denial of the widow’s claim, relying on the prior release; the Court of Special Appeals reversed and ordered further proceedings.
The Court of Appeals affirmed the intermediate court: (1) an employee cannot unilaterally release a dependent’s independent death‑benefits claim; (2) Commission approval of a settlement does not bind non‑party dependents; and (3) an employee’s settlement of disability claims does not extinguish a dependent’s independent death‑benefits claim.

Issues

Issue	Plaintiff's Argument (Collins)	Defendant's Argument (Employers/Insurers)	Held
Whether an employee’s settlement/release bars a surviving dependent’s death‑benefits claim	Mr. Collins’ release (which referenced "dependents") was intended to bar the widow’s claim	The broad release and Commission approval extinguished the widow’s death‑benefits claim	Release unenforceable against non‑party dependent; dependent’s death claim is independent and survives employee settlement
Whether dependents may settle future death‑benefits claims while the employee is alive	Dependents may only settle after they file a claim post‑death; §9‑722(a) should be read to require a dependent’s filed claim	§9‑722(a) allows settlement of current or future claims and Commission approval makes such releases effective	Dependents may settle current or future death claims while employee is alive; statute permits dependents to be parties to such settlements
Whether an employee can release a dependent’s independent death‑benefits claim	N/A (Collins argued she did not agree to release)	Employee can waive/unite in releases that include dependents; Commission approval makes it binding	An employee lacks power to unilaterally release a dependent's independent death claim; only the dependent can release it by being a party
Whether Commission approval makes a settlement binding on non‑parties	N/A	Commission approval validates and binds the settlement as to all, regardless of party status	§9‑722(d)(1) binds only parties; Commission cannot bind non‑parties to an approved settlement

Key Cases Cited

Sea Gull Specialty Co. v. Snyder, 151 Md. 78 (1926) (establishes that a dependent’s death‑benefits claim is independent of the employee’s compensation claim)
B. Frank Joy Co. v. Isaac, 333 Md. 628 (1994) (discusses Commission authority to approve settlements and the legislature’s intent on Commission discretion)
DeBusk v. Johns Hopkins Hosp., 342 Md. 432 (1996) (explains workers’ compensation as a statutory remedial scheme replacing tort claims)
EEOC v. Waffle House, Inc., 534 U.S. 279 (2002) (contract law baseline: contracts do not bind non‑parties)
Kibble v. Weeks Dredging & Constr. Co., 735 A.2d 1142 (N.J. 1999) (survey and holding that dependents’ death claims are typically unaffected by employee lump‑sum settlements)
Buchanan v. Kerr‑McGee Corp., 908 P.2d 242 (N.M. Ct. App. 1995) (holds unilateral settlement by worker does not bar surviving dependent’s death claim)
Spangler v. McQuitty, 449 Md. 33 (2016) (discusses wrongful death as a separate cause of action and limits of precedent like Melitch)
State ex rel. Melitch v. United Rys. & Elec. Co. of Baltimore, 121 Md. 457 (1913) (historical wrongful‑death precedent discussed and distinguished)