Zukowski v. Anne Arundel Cnty.

Summary

The Supreme Court of Maryland held that the statutory offset for governmental disability-retirement benefits must be applied before calculating attorney's fees under the Workers' Compensation Act. Because attorney's fees are a lien on compensation actually payable to the claimant, fees may be calculated only from the amount remaining after the offset. The Court also rejected the constitutional challenge to that fee structure and affirmed the judgment below.