Schauder v. Brager

McAULIFFE, Judge,

dissenting.

I dissent, as I am unable to conclude that the term “legal services” means or embraces medical fees for evaluation or testimony by a physician.

The operative portion of Maryland Code (1957, 1979 Repl. Vol.) Art. 101, § 57 provides:

No person shall charge or collect any compensation for legal services in connection with any claims arising under this article, or for services or treatment rendered or supplies furnished pursuant to § 37 of this article, unless the same be approved by the Commission.

As the majority concedes, the second clause of this disjunctive sentence cannot apply to the fees of non-treating physicians because § 37 deals only with medical services required for treatment of injury or disease. Therefore, in order to conclude that the legislature has granted to the Workmen’s Compensation Commission exclusive original jurisdiction to regulate fees to be paid by claimants to non-treating physicians it is necessary to interpret “legal services” to include the charges of such physicians. I find nothing in the legislative history of § 57 that would support this strained construction, and indeed I read the legislative history developed by the majority to refer only to legal fees, without any reference to physician’s fees.

*150I think it much more likely the legislature was concerned with protecting claimants from excessive attorney’s fees, whether kept by attorneys or shared with others.1

I find the phrase “compensation for legal services” as used in § 57 to be unambiguous, and to be synonymous with the term “lawyer’s fees.” That is consistent with the use of the term in the Code of Professional Responsibility. See, e.g., DR 2-106 entitled “Fees for Legal Services” and setting forth factors to be considered in establishing reasonable fees. See also DR 2-107(A) prohibiting a lawyer from dividing “a fee for legal services” with another lawyer except under specified conditions.

The majority places considerable emphasis on the existing practice of the Commission to consider the payment of medical bills of non-treating physicians as a part of the petition for attorney’s fees. The genesis of that practice is unclear. Conceivably, it may represent nothing more than a convenient consolidation of two separate procedures—the petition for attorney’s fees and the petition for a lump sum payment. The petition for attorney’s fees is normally filed within a short time after the entry of an award of compensation. At the same time, an attorney wishing to obtain a lump sum payment on behalf of the claimant may file a petition pursuant to Art. 101, § 49.2 This may have been a common practice among those attorneys who had advanced examining physician’s fees, and quite likely was otherwise widely utilized by prudent attorneys who wished to ensure *151the prompt payment of experts’ fees. I believe it a fair inference that as a matter of convenience attorneys began to include both petitions in a single pleading, and that the form currently approved by the Commission may have evolved from that practice. The rules of the Workmen’s Compensation Commission3 are silent as to any procedure for consideration of petitions for payment of non-treating physician’s fees, and with respect to petitions for payment of attorney’s fees provide in pertinent part as follows:

A. Petitions. All petitions for attorney’s fees in connection with any claims arising under Article 101, Annotated Code of Maryland, shall be submitted to the Commission for approval in proper form and with the original and four copies.
B. Fee Schedule. The Commission, from time to time, will review matters pertaining to attorney’s fees and will issue appropriate guidelines which shall be followed by Commissioners approving fees unless cause to the contrary is shown.
C. Contents. The petition for attorney’s fee shall set forth in clear, concise terms the services which have been rendered to the claimant, the amount of the fee requested to be approved, and a statement on the petition signed by the claimant indicating the claimant’s acknowledgment of the fact that the attorney is making application for allowance of an attorney’s fee for the specific services rendred and the amount of the fee.
E. Consent. The consent of the claimant to the petition for a fee for legal services is not binding upon the Commission in determining the reasonable value of the services rendered.
*152G. Approval. The Commissioner issuing an award of compensation shall also approve petitions for attorney’s fees in each case.
COMAR 14.09.01.21

The Commission has from time to time published a Guide of Medical and Surgical Fees, with the most recent publication bearing an effective date of January 1, 1978.4 Although this guide contains more than 300 pages, I am unable to find any specific reference to fees to be allowed physicians who are not involved in the treatment of the claimant. Guideline fees established for consultation and report are clearly related to physicians involved in the direct treatment of the claimant, or specifically employed for consultation in connection with that treatment. A separate statement of policy for the approval of attorney’s fees, entered by the Commission on October 20, 1970, similarly contains no reference to evaluating physician’s fees. If, as the majority insists, the Commission has long held the view that it must approve every evaluating physician’s fee, it is difficult to understand why the Commission’s guidelines contain no specific reference to those fees.

If the current practice of the Commission actually consists of nothing more than the concurrent consideration of a petition for attorney’s fees and a petition for allowance of a lump sum payment, the Commission should not adjust the physician’s fees, for the authority to allow payment of compensation in a lump sum does not carry with it the authority to adjust the bills proposed to be paid from that sum. If, as the majority contends, the current practice flows from a belief on the part of the Commission that the term “legal services” encompasses physician’s fees, the result should be no different, because the interpretation is too strained. In Comptroller v. John C. Louis Co., 285 Md. 527, 543, 404 A.2d 1045 (1979), quoting in part from *153Baltimore Gas & Elec. v. Department, 284 Md. 216, 220, 395 A.2d 1174 (1979), we said:

[E]ven an administrative interpretation ordinarily entitled to “great weight” may be given no weight at all where, for example, statutory language “is plain and unambiguous,” because “judicial construction cannot be controlled by extraneous considerations, since no custom however venerable, can nullify the plain meaning and purpose of a statute.”

The Commission unquestionably has the authority to permit a lump sum payment from the last weeks of compensation for the purpose of paying the fees of non-treating physicians, and in most cases this will provide a source for the claimant to obtain the expert assistance that may be needed. Whether it is necessary or desirable to grant to the Commission additional authority to completely regulate the amount a non-treating physician may charge a claimant is a question which should be debated before the legislature, and answered by that deliberative body.

I would affirm the decision of the Circuit Court for Baltimore City.

Judge ORTH has authorized me to state that he concurs with the views here expressed.

. In Brotherhood of Railroad Trainmen v. Virginia, 377 U.S. 1, 84 S.Ct. 1113, 12 L.Ed.2d 89 (1964) the Supreme Court discussed a past railroad union practice of requiring attorneys representing injured trainmen to pay a portion of their fees to the union. Justice Clark, writing for the dissent at 377 U.S. at 9, 84 S.Ct. at 1118, notes the practice was prevalent from 1930 to at least 1959, when it was enjoined by the Supreme Court of Illinois.

. To permit a claimant to receive funds required for payment of existing bills, or for other legitimate purposes, the Commission may approve immediate payment of all or a portion of awarded benefits. To avoid interruption of current weekly payments the lump sum payment is deducted from the last weeks of prospective compensation.

. COMAR 14.09.01.01 et seq., revised effective July 1, 1983.

. The Guide establishes a unit value for various procedures. This unit value is multiplied by a conversion factor that is periodically changed by the Commission to update the fee schedule.