24/12 - Maryland Courts

whether either the Good Samaritan Act or the Fire and Rescue Act relieves a commercial
ambulance company of civil liability for the alleged negligence of an employee committed
when an emergency arises during a transfer of a patient between medical facilities. 10
Standard of Review
Whether summary judgment was properly granted is a question of law; we review the
Circuit Court’s decision to determine whether it was legally correct. Walk v. Hartford Cas.
Ins. Co., 382 Md. 1, 14, 852 A.2d 98 (2004). Like the Circuit Court, we view the record in
the light most favorable to the non-moving party to ascertain whether there is a dispute of
material fact and, if not, whether the moving party is entitled to judgment as a matter of law.
Jurgensen v. New Phx. Atl. Condo. Council of Unit Owners, 380 Md. 106, 114, 843 A.2d 865
(2004).
Analysis
In order to assess TransCare’s claims of immunity, we must construe two statutes –
the Good Samaritan Act and the Fire and Rescue Act. This Court has frequently reiterated
the principles that guide statutory interpretation, which we summarize as follows:
• give effect to legislative intent
• look first to the “ordinary, plain meaning” of the language
• do not add or delete language
• do not apply forced or subtle interpretations
10 The Court of Special Appeals also affirmed the decision to transfer the case from
Baltimore City to Talbot County. 203 Md. App. at 187-97. That ruling is not before us.
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