Maryland Supreme Court Clarifies Jurisdiction in Underinsured Motorist Claims

Bowens v. State Farm Mutual Automobile Insurance Co.
Opinion Date: November 25, 2025
Areas of Law: Personal Injury, Auto Accidents, Insurance Law, Contracts, Civil Procedure

The Supreme Court of Maryland recently issued an important decision affecting underinsured motorist (UIM) claims and where those claims can be filed. In Bowens v. State Farm Mutual Automobile Insurance Co., the Court clarified how district court jurisdiction is determined when an injured driver seeks UIM benefits after settling with the at‑fault driver’s insurer.

This ruling provides meaningful guidance for accident victims pursuing valid insurance claims—and limits procedural defenses insurers may use to avoid payment.

Background: Auto Accident and Insurance Coverage

George Bowens was injured in a motor vehicle accident caused by another driver, Lisa Daniels. Ms. Daniels’ auto insurance policy provided $30,000 in liability coverage, which was insufficient to fully compensate Mr. Bowens for his injuries.

Mr. Bowens also carried his own insurance policy with State Farm, which included underinsured motorist (UIM) coverage with limits of $50,000.

After Ms. Daniels’ insurer offered its $30,000 policy limits, Mr. Bowens properly notified State Farm as required by statute. State Farm consented to the settlement and waived its subrogation rights, allowing Mr. Bowens to accept the $30,000 payment.

State Farm Denies the UIM Claim

Once the underlying settlement was completed, Mr. Bowens sought to recover the remaining $20,000 available under his UIM policy. Despite previously consenting to the settlement, State Farm denied the claim.

As a result, Mr. Bowens filed a breach of contract action against State Farm in the District Court for Prince George’s County, seeking $20,000 in UIM benefits.

Lower Courts Dismiss the Case for Lack of Jurisdiction

State Farm moved to dismiss the case, arguing that:

To prevail, Mr. Bowens would need to prove total damages of $50,000, and
That amount exceeded the District Court’s $30,000 jurisdictional limit.

The District Court agreed and dismissed the case. The Circuit Court for Prince George’s County affirmed the dismissal, reasoning that because total damages exceeded $30,000, the District Court lacked subject‑matter jurisdiction.

Supreme Court of Maryland: Jurisdiction Depends on the Amount Sought

The Supreme Court of Maryland reversed.

Key Holding:

A court’s jurisdiction is determined by the amount the plaintiff seeks from the defendant in the pending action, not by the plaintiff’s total damages or prior settlements received from other insurers.

Because Mr. Bowens sought $20,000 from State Farm, the District Court did have jurisdiction, even though his total damages exceeded $30,000.

The Court reversed the Circuit Court’s judgment and remanded the case to the District Court for further proceedings.

Why This Decision Matters

This ruling is significant for Maryland accident victims and insurance disputes because it:

Prevents insurers from using jurisdictional technicalities to avoid paying valid UIM claims
Confirms that prior settlements do not control jurisdiction in UIM breach‑of‑contract cases
Makes it easier for injured drivers to pursue smaller UIM claims without being forced into higher courts

In short, insurers cannot block claims simply because total damages exceed the district court limit when the amount actually sought is within that limit.

Injured in an Auto Accident? We Can Help.

Insurance companies often look for procedural defenses to deny or delay valid claims—especially in underinsured motorist cases.

If you were injured in a car accident and are facing resistance from an insurance company, you need an attorney who understands both insurance law and litigation strategy.

Contact Gritz, Hanifin & Shih, LLC today for a free consultation.
We fight to ensure insurance companies honor their obligations.

Frequently Asked Questions (FAQ)

What is an underinsured motorist (UIM) claim?

A UIM claim allows an injured driver to recover additional compensation from their own insurance policy when the at‑fault driver’s insurance is insufficient to cover the damages.

Does accepting a settlement from the at‑fault driver prevent a UIM claim?

No. As long as the insured follows statutory notice requirements and obtains the insurer’s consent, a UIM claim may still be pursued.

How is court jurisdiction determined in a UIM case?

According to the Supreme Court of Maryland, jurisdiction is based on the amount sought from the defendant in the lawsuit, not the plaintiff’s total damages or earlier settlements.

Can a district court hear a UIM claim if total damages exceed $30,000?

Yes. If the plaintiff only seeks $30,000 or less from the insurer, the District Court has jurisdiction.

Why did State Farm argue the case should be dismissed?

State Farm argued that proving damages above $30,000 exceeded the District Court’s authority. The Supreme Court rejected that argument.

What should I do if my insurer denies a valid UIM claim?

You should speak with an experienced attorney immediately. Insurance denials often rely on technical defenses that can be challenged in court.