SIGNIFICANT CASE SUMMARY

Maryland Case Summary

Murphy et al v. GEICO
Maryland Supreme Court
No. 55, September Term, 2025

Decided: July 13, 2026

Maryland’s Supreme Court reaffirms that insurance policies are interpreted the same way as other contracts, giving the words their customary and normal meaning.

Background

On August 19, 2021, GEICO’s insured was driving a vehicle with her husband as a passenger. The insured’s negligent driving caused an accident, resulting in her husband’s death. Thereafter, the decedent’s four adult children (Plaintiffs) made claims on the subject policy under Maryland’s Wrongful Death statute. Under the policy, the liability limits for bodily injury were $300,000 per person. However, the liability limits were subject to a household exclusion. Specifically, liability limits were capped at the minimum requirement under Maryland law ($30,000) if the claimed bodily injury was to an insured or any relative of the insured residing in the same household.

GEICO argued that the household exclusion applied, reducing liability limits under the policy from $300,000 to $30,000 per person, because the Plaintiffs claim for damages was based on the bodily injury to the decedent passenger, as an insured.

Plaintiffs filed suit in the Circuit Court for Montgomery County seeking a declaratory judgment that their claims were not subject to the household exclusion. The circuit court entered a declaratory judgment in favor of GEICO, holding that the Plaintiffs’ claims derived from their father’s bodily injury, and because he was an insured, the household exclusion applied. The Appellate Court of Maryland affirmed. The Supreme Court of Maryland granted Plaintiffs’ writ of certiorari.

Holding

The Maryland Supreme Court explained that the policy’s definition of bodily injury (“bodily injury to a person, including resulting sickness, disease or death”), does not describe the scope or type of damages available to the Plaintiffs, but rather serves as a triggering event for the carrier’s legal obligation to pay. Simply put, under the policy, an insured becomes legally obligated to pay because of a bodily injury sustained to a person arising out of the ownership, maintenance, or use of an owed auto.

Here, the Plaintiffs did not, themselves, sustain bodily injury as a result of the car accident. Rather, their suit was based on injuries and losses suffered from their father’s death. Meaning, without the Wrongful Death Statute, the Plaintiffs have no injury to trigger the legal obligation to pay. Because their claim is triggered only by the “bodily injury” (including death) to their father, and their father was an insured and/or relative residing in the same house as an insured, the household exclusion applied.

The Supreme Court reaffirmed the lower courts’ decisions, holding that the household exclusion applied to the Plaintiffs’ claims under the Wrongful Death Statute because the provisions of the policy operate together to define the scope of coverage and limits of liability.

Questions about this case can be directed to Alex Mitchell at (443) 641-0563, or amitchell@tthlaw.com.