On August 26, 2026, a Maryland appeals court ruled an umpire's mistaken signature on a $130,663 figure created no binding award.
A burst pipe damaged a homeowner's house and belongings, prompting a claim under her State Farm homeowners' policy. When she and the insurer could not agree on the size of the loss, she invoked the policy's appraisal clause.
Under that clause, each side picked an appraiser. If the two appraisers disagreed, they would send their differences to an "umpire," whose decision would bind both sides. The appraisers could not agree, so they turned to an umpire.
The homeowner's appraiser then sent the umpire a one-page "Declaration of Appraisers." It had a line for the umpire to sign and accept the appointment. It also carried a section labeled "Award," which said the panel had "carefully examined the premises and remains of the property" and set the "Actual Cash Value Loss" at $130,663. The umpire signed in both places.
The homeowner's public adjuster forwarded the signed document to State Farm and demanded payment. State Farm paid nothing.
State Farm's appraiser said he had never taken part in the appraisal process with the umpire. The umpire said the same, and added that he had signed the "Award" section "by mistake." He had signed online without printing or carefully reading the document, done no work, received no materials from State Farm's appraiser, and formed no opinion on the loss. He said he signed only to identify himself as the umpire, and that the document was not his "official determination of damages."
In March 2023, the homeowner asked a Maryland court to confirm the document as an arbitration award, later adding a request for a declaratory judgment.
Her argument turned on timing. Under Maryland's arbitration law, a party that wants to modify, correct, or vacate an award must act within tight deadlines. State Farm never filed such a motion, so, she argued, the court had to confirm the award.
The Appellate Court of Maryland disagreed. A party that says no award ever existed does not have to move to vacate one, it held. It can instead wait and challenge whether an award exists when the other side moves to confirm. Because the undisputed evidence showed the umpire had done no work and issued no decision, there was no award to confirm.
The court affirmed the denial of the homeowner's petition. On one point it sided with her: it vacated the dismissal of her separate request for a declaratory judgment and sent the case back so the lower court could formally declare the parties' rights.
