24/12 - Maryland Courts

escue squads,” it remained clear that the statute did not extend to members or employees of
for-profit organizations.
In 1976, the Good Samaritan Act was revised in response to advice from the Attorney
General’s Office that an amendment of the Act was necessary to ensure that functions carried
out under the new State Emergency Medical System were covered by the Good Samaritan
Act. See Letter of Assistant Attorney General Paul Walter to R Adams Cowley, M.D.
(October 24, 1974). That advice did not suggest that the Act needed to be extended to
commercial ambulance companies or other for-profit entities.
The 1976 revision encompassed the entire statute, including the provision concerning
members of fire departments and ambulance and rescue squads. In particular, the description
of the individuals covered by immunity in that provision was changed from “[t]he members
of any fire department or volunteer ambulance and rescue squads ...” to “[a] member of any
State, county, municipal, or volunteer fire department, ambulance and rescue squad...”
Chapters 558, 689, Laws of Maryland 1976. The shifting of the adjective “volunteer” within
the introductory phrase, however, did not signify an indirect expansion of the immunity
provision to members of commercial entities. Rather, it simply ensured that the adjective
“volunteer,” together with the adjectives denoting government entities, would apply to fire
departments as well as ambulance and rescue squads. See Tatum v. Gigliotti, 321 Md. 623,
630, 583 A.2d 1062 (1991) (describing the provision as providing immunity for “members
of fire departments and ambulance and rescue squads which may be state, county or
municipal, as well as volunteer”). That conclusion is confirmed by one of the drafters of the
14