SIGNIFICANT CASE SUMMARY

Maryland Case Summary

Bowens v. State Farm Mut. Auto. Ins. Co.
Maryland Supreme Court
No. 10, Sept. Term 2025

Decided: November 24, 2025

The “debts or damages claimed” in a UIM lawsuit to establish District Court jurisdiction are defined as the amount recoverable from the UIM carrier after the at-fault tortfeasor’s policy has been exhausted.

Background

This case arose out of a February 2023 automobile accident in Prince George’s County, Maryland, between Petitioner and an underinsured motorist (“the tortfeasor”). The at-fault tortfeasor offered Petitioner policy limits ($30,000) to settle his claim. Petitioner then placed his own insurer, State Farm Mutual Automobile Insurance Company, on notice of a UIM claim. State Farm consented to the settlement with the tortfeasor and waived its subrogation rights against the tortfeasor. Petitioner accepted the settlement from the tortfeasor and then sought payment of his $50,000 UIM policy limits, less the $30,000 he already recovered from the tortfeasor (i.e. $20,000). The UIM carrier denied that claim. Petitioner then filed a breach of contract suit in District Court to recover the $20,000.

Petitioner’s UIM carrier moved to dismiss the lawsuit. It argued that because Petitioner would first have to prove total tort damages of $50,000, the lawsuit was beyond the District Court’s jurisdictional threshold of $30,000, pursuant to CJP § 4-401(1). The District Court granted the UIM carrier’s Motion to dismiss and the Circuit Court affirmed. A further appeal followed.

Holding

The Supreme Court of Maryland held that under CJP § 4-401(1), the District Court has exclusive original jurisdiction over contract or tort actions “if the debt or damages claimed do not exceed $30,000[.]” The Maryland Insurance Code permits an insured to receive UIM coverage, minus any sums paid to the insured by the tortfeasor. The statute also permits the insured to recover settlement sums from the tortfeasor without waiving any subsequent claims to recover underinsured/uninsured benefits from the underinsured motorist carrier. The Supreme Court of Maryland defined “debts or damages claimed” as the amount recoverable from the underinsured motorist carrier, after the at-fault tortfeasor’s policy has been exhausted. Thus, the Supreme Court held that Petitioner filed a District Court Complaint for $20,000, i.e., the balance recoverable from his UIM carrier after the tortfeasor’s $30,000 had been exhausted. The District Court had subject matter jurisdiction to hear the UIM breach of contract case because the residual claim for $20,000 was within the District Court’s jurisdictional limit. Accordingly, the Supreme Court of Maryland reversed the Circuit Court’s decision and remanded the matter to the Lower Court.

Questions about this case can be directed to Alex Mitchell at .443.641.0563 or amitchell@tthlaw.com.