Rose Williams McMillan was an employee of Providence Hospital who suffered an injury related to her employment entitling her to future medical benefits under Alabama's Workers' Compensation Act. After agreeing to settle her future claim for $75,000, McMillan passed away before the necessary court approval could be obtained. Following McMillan's death, Providence Hospital and Sedgwick Claims Management Services refused to honor the settlement agreement, prompting McMillan's estate administrator, Sheila W. Austin, to initiate a breach-of-contract suit.
However, the trial court granted a summary judgment in favor of Providence and Sedgwick, reasoning that the contract was not legally valid as no court approval was attained before McMillan's death. Austin appealed the ruling, but the Court of Civil Appeals upheld the summary judgment. It explained that the breach-of-contract action was barred by the "exclusivity provisions" of the Workers' Compensation Act and, further, the settlement agreement was not valid due to lack of court approval and the death of the employee.
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