Hand Construction v. Stringer

Court of Civil Appeals of Alabama

Mobile County | 227 So. 3d 535 | Jan. 13, 2017

Dispute Over Jurisdiction and Applicability of Alabama Workers' Compensation Act to Out-of-State Injury

The case primarily revolves around the question of whether an Alabama trial court had jurisdiction concerning an out-of-state work-related accident. The plaintiff, Stringer, who lives in Mobile, Alabama, was offered employment by Hand, a construction company with its main office in Louisiana. Although Hand was registered to do business in Alabama, they had not conducted business in the state for the past decade. The employment offer took place over a phone call while Stringer was in Alabama, and Bayless, Hand's superintendent, was in Mississippi. The actual hiring was conducted in Shreveport, Louisiana.

Most of Stringer's job assignment was in North Dakota. However, he did work from his home in Alabama occasionally, using company-issued equipment. Despite this, both Dodd, the project manager, and Hubble, Hand's CFO, stated in affidavits that Stringer did not work for Hand while in Alabama.

The central event was an accident that occurred in Arkansas while Stringer was transporting equipment back to Alabama. The trial court had ruled that it had jurisdiction, relying on § 25-5-35(d)(2), Ala. Code 1975, which pertains to injuries sustained outside Alabama under certain employment conditions. It also determined that, when the accident happened, Stringer was under a new employment contract with Hand.

However, on appeal, the evidence highlighted that Stringer's primary work location was North Dakota, thus making the trial court's ruling inconsistent with the Alabama statute that requires a worker's employment not to be "principally localized" in any one state for Alabama law to apply.