Bowens v. State Farm Mut. Auto. Ins. Opinion Date: November 25, 2025

Areas of Law: Personal Injury, Auto Accident, Civil Procedure, Contracts, Insurance Law

George Bowens sustained injuries from an automobile accident that was caused by Lisa Daniels.  Ms. Daniels insurance policy only covered up to $30,000, but Mr. Bowens’ Insurance policy covered damages up to $50,000.  Ms. Daniels insurance company offered their $30,000 and Mr. Bowens sought the remaining $20,000 available under his underinsured motorist (UIM) policy with State Farm.  Mr. Bowens followed proper statutory procedures and notified State Farm of this offer.  State Farm consented and waived subrogation rights against Ms. Daniels, allowing Mr. Bowens to accept the $30,000 from Ms. Daniel’s insurance company.  When Mr. Bowens then sought to recover the remaining $20,000 available under his UIM policy from State Farm, they denied his claim.

Bowens filed a breach of contract action in the District Court for Prince George’s County, seeking $20,000. State Farm moved to dismiss, arguing that the District Court lacked subject matter jurisdiction because Bowens would have to prove total damages of $50,000—exceeding the court’s $30,000 jurisdictional cap. The District Court agreed and dismissed the case. Bowens appealed to the Circuit Court for Prince George’s County, which affirmed the dismissal, reasoning that the District Court would need to find damages over $30,000 and thus could not grant relief.

The Supreme Court of Maryland reviewed the case and held that the District Court’s jurisdiction is determined by the amount the plaintiff seeks from the defendant in the pending action, not by the total underlying damages or prior settlements received from the tortfeasor’s insurer. Since Bowens’ claim against State Farm was for $20,000, the District Court had jurisdiction to hear and decide the case. The Supreme Court of Maryland reversed the judgment of the circuit court and ordered the case remanded to the District Court for further proceedings.

If you are involved in an automobile collision, you need an experienced attorney who understands how insurance companies work to deny paying valid claims.  Contact Gritz, Hanifin & Shih, LLC for a free consultation.

Reference:
https://law.justia.com/cases/maryland/court-of-appeals/2025/10-25-0.html