Maryland Accident Law Blog
When an injury claim settles, most people assume the case is closed. However, what happens if critical information is withheld during negotiations? A recent Maryland case sheds light on this issue. In the case, Edward Sniadach v. Two Farms, two individuals who suffered slip-and-fall injuries and later accused an insurance company and its claims administrator of fraudulently inducing them into accepting lower settlements. This case raises important questions about fair dealing in settlement negotiations and highlights the importance of having an experienced Prince George’s County personal injury lawyer on your side.
The Accident and the Initial Claims
Both individuals were injured in separate slip-and-fall accidents on the property of a business. Like many premises liability claims, they sought compensation for their injuries through the business’s insurance provider. The company’s insurance carrier, Zurich America Insurance Co., handled the claims, while Gallagher Bassett Services, Inc. acted as the claims administrator.
A key issue in these claims involved Medical Payments (Med-Pay) coverage, a type of insurance that pays medical bills for injuries occurring on insured property, regardless of fault. One claimant actively asked about Med-Pay multiple times before settling, while the other settled before even learning of its availability.
One claimant settled for $16,385, with $6,385 explicitly marked as Med-Pay funds. The other claimant settled for $15,000 without being informed about Med-Pay coverage. He later learned—after signing the release—that Med-Pay was available.
The plaintiffs later alleged that the insurance companies had deliberately withheld information about Med-Pay to push them toward lower settlements.
The Class Action Lawsuit and Legal Challenges
Believing that this was a widespread issue, the claimants filed a class action lawsuit against the insurer and claims administrator, alleging:
Fraudulent inducement – Claiming the insurance company misled them into settling for less than they were entitled to.
Intentional misrepresentation – Arguing that the insurer and its administrator knowingly withheld Med-Pay information.
Breach of contract – Alleging that the failure to disclose Med-Pay amounted to a violation of their agreements.
Insurance bad faith – Contending that the insurers acted unfairly in handling their claims.
The lawsuit sought to represent all injured individuals in Maryland who had Med-Pay available but were not informed about it before settling their claims.
Why the Court Denied Class Certification
The plaintiffs asked the court to certify their case as a class action, meaning they could pursue claims on behalf of other similarly affected individuals. However, the court denied class certification, citing several reasons:
Numerosity: The plaintiffs failed to present enough evidence to show that a large number of people were affected.
Typicality: The court found that their claims were not necessarily typical of others, since one plaintiff was aware of Med-Pay before settling, while the other was not.
Adequacy of Representation: The plaintiffs did not provide sufficient proof that they or their attorneys could adequately represent an entire class.
Predominance: The court noted that determining whether each individual had relied on misinformation would require extensive case-by-case analysis, making a class action inefficient.
The Summary Judgment Ruling
After class certification was denied, the plaintiffs took an unusual step: they asked the court to grant summary judgment against them so they could immediately appeal the class action ruling. The court agreed, but it also reviewed the merits of their fraud claims before issuing its decision.
The court found that the plaintiffs did not present sufficient evidence of fraudulent inducement because one claimant was informed of Med-Pay and accepted it as part of the settlement—meaning there was no deception. The other claimant settled without knowing about Med-Pay, but also without relying on any direct misrepresentation—meaning he could not prove that the insurer’s actions caused him to accept a lower amount. And, according to the court, neither claimant provided enough verified evidence to prove they would have negotiated differently if they had been properly informed.
Because Maryland law requires clear proof of reliance on fraudulent information to establish a claim, the court ruled in favor of the insurance company and dismissed the case.
What This Case Means for Injury Victims
This case is a reminder that settlement agreements are legally binding, even if important information is later discovered. It also highlights how challenging it can be to prove fraudulent inducement in Maryland courts.
If you’ve been injured and are negotiating a settlement, here are a few things to keep in mind:
Ask detailed questions about all available coverage—especially Med-Pay, which is designed to cover medical bills regardless of fault.
Get everything in writing—if an insurer is unresponsive about a specific type of coverage, keep records of your inquiries.
Consult an experienced attorney before signing a settlement agreement—once you sign, your ability to challenge the terms later is extremely limited.
Speak with an Experienced Maryland Personal Injury Attorney About Your Case Today
If you were injured in a slip and fall accident and believe an insurance company withheld critical information from you during settlement negotiations, you may still have legal options. The experienced personal injury attorneys at Lebowitz & Mzhen understand the complexities of Maryland’s laws and are committed to fighting for fair compensation. Call us today at 800-654-1949 or reach out through our online contact form for a free consultation. We proudly represent clients in Baltimore, Prince George’s County, and across Maryland.