In Erie Insurance Co. v. Curtis, 330 Md. 160, 623 A.2d 184 (1993), an employee named Curtis was injured, during the course of his employment, in an automobile accident with another driver. The driver of that other vehicle was uninsured. After his employer's workers' compensation carrier, Erie Insurance Company, paid his workers' compensation claim, Curtis brought a breach of contract action against his employer's automobile insurance carrier, Nationwide Mutual Insurance Company, seeking to collect payment under the uninsured motorist provision of his employer's policy. In that action, Erie intervened as a plaintiff, to advance its claim of a lien, under former Article 101, 58 (which, as noted earlier, is the statutory predecessor of LE 9-901 through 9-903) on any amount awarded to Curtis under his employer's uninsured motorist insurance. But, upon Curtis's motion, the circuit court rejected Erie's claim and dismissed Erie Insurance as a party to the suit. The Court of Appeals affirmed, holding that "Erie, as a workers' compensation carrier, had no claim against the proceeds of Curtis's contract action against Nationwide." 330 Md. at 169. It reasoned that Article 101, 58, "refers solely to an action against a third party tort-feasor" and not to contract actions by "'persons covered under insurance policies, against their insurers, for benefits under so-called first party coverages such as PIP or uninsured motorist.'" Id. (quoting Ward v. Nationwide Mut. Auto. Ins. Co., 328 Md. 240, 246, 614 A.2d 85 (1992)).