Daniel Barufaldi had an employment contract with the Ocean City Chamber of Commerce. He resigned when the chamber refused to pay him incentive-based compensation.
Barufaldi sued the Chamber for breach of contract and unpaid wages under the Maryland Wage Payment and Collection Law (“MWPCL”), and the Chamber counterclaimed for breach of contract. The jury found that the Chamber had breached the employment contract and violated the MWPCL by failing to pay Barufaldi $60,000 in unpaid wages, and that the Chamber’s failure to pay was not the result of a bona fide dispute. The court, however, did not grant Barufaldi’s motion for attorneys’ fees.
On appeal the Court of Special Appeals vacated and remanded the trial court’s order denying Barufaldi’s motion for attorneys’ fees under the MWPCL. The Court stated that the MWPCL is a fee-shifting statute that requires courts to “liberally” exercise discretion to award attorneys’ fees where there is no bona fide dispute. Because the trial court did not set forth circumstances militating against any award of fees, and, in fact, had not offered any explanation at all of its reasoning in denying the fee request, the court vacated and remanded the issue of attorneys’ fees to the trial court.