Supreme Court of Maryland

Zukowski v. Anne Arundel Cnty.

April 24, 2025

Summary

The Supreme Court of Maryland held that attorney’s fees under the Workers’ Compensation Act must be calculated from the compensation remaining after applying the statutory offset for service-connected disability retirement benefits. In this context, “benefits” and “compensation” are interchangeable, and an attorney’s fee is a lien only on money payable to the claimant. The Court also rejected the constitutional challenge and affirmed the judgment below.