Trayco Insurance v. Williams
61 A.3d 50
Md.2013Background
- TravCo insured Williams under UM and PIP; district court certified questions about § 19-513(e) interpretation and subrogation mechanics.
- Statute § 19-513(e) requires reductions to UM/PIP when WR benefits are recovered without reimbursement to the WC provider.
- Williams may reimburse the DC WC provider in the future; the WC provider has not been reimbursed.
- Write-downs of medical bills in WC context may be treated as WC benefits depending on state law.
- DC WC administrator asserts subrogation rights; no funds currently available for reimbursement by Williams.
- Court reformulated questions to focus on Maryland law interpretation and, if applicable, treatment of write-downs under § 19-513(e).
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Does § 19-513(e) require UM/PIP reduction when the WC provider is unreimbursed and reimbursement has not occurred? | Williams: unreimbursed WC benefits trigger reduction; avoid windfall | TravCo: plain language requires reduction when recipient has recovered WC benefits | Yes; reduction applies when unreimbursed WC benefits have been recovered. |
| What is the proper method to resolve disputes about a WC provider’s subrogation right? | Williams: court should defer to negotiated resolution; not necessary given statute | TravCo: dispute resolution is needed to protect subrogation rights | Unnecessary to determine; plain statutory language controls; not resolved here. |
| Do WC write-downs (medical bill discounts) count as WC benefits and reduce UM/PIP under § 19-513(e) if unreimbursed? | Williams: write-downs may be treated as WC benefits; reduce UM/PIP only if unreimbursed | TravCo: write-downs may not be relevant to PIP/UM reductions | Yes; if write-downs are WC benefits and unreimbursed, they reduce UM/PIP. |
Key Cases Cited
- State Farm Mut. Auto. Ins. Co. v. Ins. Comm’r, 283 Md. 663 (Md. 1978) (plain, unambiguous language requires offset for recovered WC benefits)
- Parry v. Allstate Ins. Co., 408 Md. 130 (Md. 2009) (amendment preserves offset for unreimbursed recovered WC benefits)
- Gable v. Colonial Ins. Co., 313 Md. 701 (Md. 1988) (offset only for actually received WC benefits; not future benefits)
- Smelser v. Criterion Ins. Co., 293 Md. 384 (Md. 1982) (statute remains unambiguous; offsets tied to actual WC recovery)
- Blackburn v. Erie Ins. Grp., 185 Md. App. 504 (Md. Ct. Spec. App. 2009) (2001 amendment limits reductions to unreimbursed WC benefits)