On March 18, 2016, the Alabama Supreme Court dismissed tort claims filed by an employee who was injured in an on-the-job explosion. Rock Wool Mfg. Co. v. Miller, No. 1141252, 2016 WL 1077268 (Ala. Mar. 18, 2016). The employee claimed that his employer, Rock Wool, intentionally removed safety equipment called “explosion doors” prior to the accident. Because of that alleged intentional conduct, the employee argued that his claims should not be limited to the remedies provided by the Alabama Workers’ Compensation Act. Instead, he wanted to sue for damages under tort law. Nevertheless, the Supreme Court found that claims against an employer, even for intentional acts, are barred by the Workers’ Compensation Act, so long as those claims arise within the bounds of the working relationship. As a result, the Supreme Court issued an order dismissing the tort claims.
Despite the holding of Rock Wool, employers should remain cautious regarding claims of intentional injury. While the employing entity itself is protected by the exclusive-remedy provisions of the Alabama Workers’ Compensation Act, individual employees are not entitled to the same protections. For example, in the Rock Wool case, there is still a possibility that the individual employees who made the decision to remove the “explosion doors” could be liable for intentionally or recklessly injuring the employee.
