Muhammad v. Bd. of Education, 228 A.3d 1170

Muhammad (appellant) signed a provisional teacher contract with Prince George’s County Board of Education on July 27, 2016 (contract effective Aug. 15, 2016) and attended mandatory pre‑school training and professional development in August 2016.
On August 18, 2016, before the school year began, the Board notified Muhammad he would not work for PGCPS for 2016–2017; Muhammad sued for breach of the employment contract seeking damages.
At ADR on April 3, 2018 the parties agreed to settle for $33,500; they later executed a detailed Settlement Agreement and Release that specified payment of $33,500 “less applicable required State and Federal tax withholding,” and included a confidentiality clause and a forum/interpretation clause vesting Maryland courts with jurisdiction.
The Board issued a check for $20,569 after withholding state and federal taxes; Muhammad refused the check and moved to vacate or enforce the settlement and to alter or amend when the court denied relief.
The circuit court found Muhammad was an employee of the Board at the time of termination and that the settlement language permitted tax withholding; the court denied Muhammad’s motions and the Court of Special Appeals affirmed.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether Muhammad was an employee such that the Board could withhold payroll taxes from the settlement	Muhammad: He was never permitted to work as a teacher (contract terminated before teaching began), so he was not an employee and taxes should not have been withheld	Board: Parties had an employment contract, Muhammad attended pre‑school training, Board had power to hire, pay and discharge—an employer‑employee relationship existed, so withholding was required	Court: Muhammad was an employee under Mackall factors (selection, payment, discharge, control, regular business); withholding was proper
Whether the circuit court erred by reviewing a confidential settlement agreement	Muhammad: Confidentiality clause barred disclosure and court review; without seeing the agreement the court would have enforced the ADR order alone	Board: The settlement expressly allowed the court to resolve disputes (jurisdiction clause) and the court, as fact‑finder/referee, may consider the agreement and compartmentalize confidential information	Court: Reviewing the settlement was permissible—Paragraph 7 vests Maryland courts with jurisdiction; Paragraph 6 makes the written settlement the entire agreement; court properly considered its terms

Mackall v. Zayre Corp., 293 Md. 221 (1982) (establishes multi‑factor test for employer‑employee relationship)
Uninsured Employers’ Fund v. Tyson Farms, Inc., 243 Md. App. 406 (2019) (applies Mackall factors; control is key)
Newhouse v. McCormick & Co., Inc., 157 F.3d 582 (8th Cir. 1998) (distinguished—held claimant was not an employee for withholding where he was a rejected applicant)
Credible Behavioral Health, Inc. v. Johnson, 466 Md. 380 (2019) (objective theory of contract interpretation governs intent)
Tomran, Inc. v. Passano, 391 Md. 1 (2006) (cardinal rule: give effect to parties’ intentions in contract interpretation)
Dumbarton Improvement Ass’n, Inc. v. Druid Ridge Cemetery Co., 434 Md. 37 (2013) (contracts construed to give effect to each clause)