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contractjurisdictionstatuteappealworkers' compensationcase lawoverruledlegislative intent
contractjurisdictionstatuteappealworkers' compensation

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Pro-Football, Inc. v. Tupa, 428 Md. 198, 51 A.3d 544

Facts

Thomas Tupa, a professional football player, filed a claim for temporary partial disability benefits with the Maryland Workers' Compensation Commission after sustaining a back injury during a pre-game warm-up. The Commission awarded him benefits, but his employer, Pro-Football, Inc., appealed, arguing that a forum selection clause in Tupa's employment contract required claims to be filed in Virginia. The Circuit Court upheld the Commission's decision, affirming that Tupa's injury was compensable under Maryland law. The case was subsequently appealed to the Court of Special Appeals, which also affirmed the decision.

Issue

Whether the Maryland Workers' Compensation Commission had jurisdiction over Tupa's claim despite a forum selection clause in his employment contract requiring claims to be filed in Virginia, and whether Tupa's injury constituted a compensable 'accidental' injury under Maryland law.

Whether Maryland has jurisdiction over the Claimant's workers' compensation claim when the Claimant signed an employment contract agreeing to bring all workers' compensation claims in the Commonwealth of Virginia.

Rule

Analysis

The court determined that the forum selection clause in Tupa's employment contract did not limit the jurisdiction of the Maryland Workers' Compensation Commission, as the statute explicitly prohibits such waivers. Furthermore, Tupa's injury occurred during a routine activity related to his employment, which meets the criteria for an 'accidental' injury under the law. The court overruled previous case law that required an unusual occurrence for an injury to be compensable, aligning with the legislative intent to protect workers.

The petitioners' principal argument is that the Maryland Workers' Compensation Commission had no jurisdiction over Tupa's claim and that the Maryland Workers' Compensation Act had no application to the claim because 'the Claimant was contractually bound to bring his claim for workers' compensation benefits in the Commonwealth of Virginia.' None of this Court's opinions relied upon by the petitioners, however, involved a workers' compensation claim. More specifically, none of these opinions involved a statute which voided a provision in an employment contract waiving the rights of a covered employee under the Maryland Workers' Compensation Act.

Conclusion

The Court of Appeals affirmed the lower court's ruling, holding that the Maryland Workers' Compensation Commission had jurisdiction over Tupa's claim and that his injury was compensable under Maryland law.

Judgment of the Court of Special Appeals AFFIRMED. PETITIONERS TO PAY COSTS IN THE COURT OF SPECIAL APPEALS AND IN THIS COURT.

Who won?

Thomas Tupa prevailed in this case as the court upheld the Workers' Compensation Commission's decision to award him benefits. The court found that the forum selection clause in his employment contract was ineffective, allowing the Commission to exercise jurisdiction over his claim. Additionally, the court recognized that Tupa's injury was compensable under Maryland law, thus affirming his right to receive temporary partial disability benefits.

Tupa was awarded temporary partial disability benefits and the petitioners were ordered to pay the related medical expenses.

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