Baltimore, Maryland’s September 2025 Employment & Labor Law Cases

Summary of September 2025 Labor Law Updates for Baltimore, Maryland

Brought to you by HKM Employment Attorneys, our Maryland team presents this roundup of the most noteworthy labor and employment developments in September 2025. These updates are relevant for employees, employers, HR professionals, and compliance officers navigating Maryland’s evolving legal landscape.

September 2025 saw a mix of judicial rulings and ongoing implementation activity in Maryland’s labor and employment space. Key trends include carefully limited individual liability for corporate officers in wrongful termination claims, reinforcement of the de minimis doctrine in wage litigation, and renewed attention to statutory scheduling (especially FAMLI delay). Employers should start auditing policies now to prepare for the October 1 statutory changes and the later launch of paid leave. If you’d like a deeper dive into any of these developments or want help updating your Maryland policies, feel free to reach out to HKM Employment Attorneys at https://hkm.com.

Divided Appeals Court Dismisses States’ Challenge to Probationary Federal Employee Firings — Court Ruling

Date: September 9, 2025

Summary:
A divided panel of the U.S. Court of Appeals dismissed a challenge by 19 states—including Maryland—to federal actions that terminated probationary federal employees without 60 days’ notice. The states had argued that such firings harmed their interests (e.g. lost tax revenue, increased unemployment burdens). The appellate court held that the states lacked standing to bring the suit.

Implications for Maryland:
Because this case involves federal personnel, its direct effect on Maryland private-sector employers is limited. However, it does highlight legal friction around federal reductions in force and may influence how states assess their indirect harm in litigation. Maryland agencies and contractors should observe the reasoning about standing and injury-in-fact in future disputes involving state interests.

Wilkins v. [Unnamed] — Partial Grant/Deny in Maryland District Court (Wrongful Termination Claim) — Court Ruling

Date: September 5, 2025

Summary:
In a decision filed September 5, 2025, the U.S. District Court for Maryland considered a claim asserting personal liability of corporate officers under Maryland’s wrongful termination or tort theories. The court engaged in detailed analysis of Maryland precedent (e.g., Moniodis v. Cook and Bleich v. Florence Crittenton) and granted in part and denied in part motions at the pleading stage.

Implications for Maryland Employers and Executives:
This case underscores that corporate executives may face personal exposure in wrongful discharge or related tort claims under Maryland law—but such exposure is not guaranteed. Employers should ensure that termination decisions are well documented, defensible, and aligned with state law to reduce risk. Executive officers should examine whether indemnification or insurance is available to cover potential liability.

Herkert v. Bisignano — Fourth Circuit Reaffirmation of Reassignment as Adverse Action — Court Ruling

Date: August 14, 2025 (discussed in recent coverage)

Summary:
Although not a Maryland-specific case, the Fourth Circuit’s decision in Herkert v. Bisignano (No. 24-1420) may have strong influence in Maryland courts. The appellate court recognized that in certain circumstances, a job reassignment—even without pay reduction—can qualify as an “adverse employment action” under federal anti-discrimination law under the Muldrow standard.

Implications for Maryland Employers and HR:
Maryland employers subject to federal anti-discrimination statutes (e.g. Title VII, ADA) should reevaluate reassignment practices. Employers must ensure that reassignments are justified objectively and documented, and that they do not inadvertently become the basis for claims, particularly if the reassignment materially affects working conditions.

Estefany Martinez v. Amazon.com Services LLC — Maryland Supreme Court Clarifies De Minimis Doctrine Under State Wage Laws — Court Ruling

Date: July 3, 2025 (but published and gaining attention in September)

Summary:
In Estefany Martinez v. Amazon.com Services LLC, the Maryland Supreme Court held that the doctrine of de minimis non curat lex (“the law does not concern itself with trifles”) applies to claims brought under the Maryland Wage and Hour Law (LE § 3-401 et seq.) and the Maryland Wage Payment and Collection Law (LE § 3-501 et seq.).

Implications for Maryland Employers:
This ruling gives employers some breathing room for trivial or insubstantial time discrepancies (e.g. a few seconds) in wage and hour claims under Maryland law. Nonetheless, employers should not become complacent — repeated or systemic small discrepancies may still aggregate into material violations. Accurate timekeeping remains critical to compliance and litigation risk mitigation.

New Employment / Labor Statutes Effective October 1, 2025 (Announced in September) — Legislation

Date: Laws taking effect October 1, 2025, announced late September

Summary:
In late September, several Maryland employment-related statutes were highlighted as going into effect October 1, 2025. Key among them:

  • SB 785 / Parental Leave Modifications: The law excludes an employer from Maryland’s unpaid parental leave requirement if the employer is already covered by the federal FMLA.
  • Worker Cooperative Associations: HB 15 / SB 144 authorizes worker cooperative associations and establishes regulatory rules for their formation and operation.

A package of other statutes passed in the 2025 General Assembly (hundreds of new laws) also takes effect on October 1.

Implications for Maryland Employers:

Starting October 1, employers must account for the changed parental leave eligibility and review whether their operations may trigger or benefit from the new cooperative model. HR and legal departments should conduct a compliance audit of policies to ensure adherence to newly effective statutes.

Conclusion: Looking Back on Maryland Labor Law Updates from September 2025

As Maryland courts issue critical rulings on wage disputes, wrongful termination, and federal-employee protections, your next step shouldn’t just be reading the news—it should be knowing your rights. At HKM Employment Attorneys in Baltimore, our experienced team specializes in advocating for employees across the state on issues from contract violations and unpaid wages to retaliation and whistleblowing claims. Whether you’re a federal worker navigating MSPB appeals or confronting workplace unfairness under Maryland law, we offer strategic legal guidance backed by attentive client care. If recent case outcomes have raised concerns for your job or benefits, contact our Baltimore office to discuss how we can help you protect your workplace rights.

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Daniel Kalish

A graduate of Harvard College and Yale Law School, Mr. Kalish is an experienced trial lawyer who has tried more than thirty trials to jury verdict. Mr. Kalish’s practice focuses on complex trial work, and he represents employees in all aspects of employment litigation.

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