Martin v. Austal USA

Court of Civil Appeals of Alabama

Mobile County | 195 So. 3d 980 | Oct. 16, 2015


Employee's Workers' Compensation Claim Denied on Basis of Statute of Limitations

On September 3, 2014, an employee launched a complaint against her employer, asserting that she had suffered an occupational disease due to her job, leaving her disabled. She contended that this happened around September 3, 2012, during her employment period. The employer, in their defense, claimed that the employee's appeal was late due to the applicable statute of limitations, emphasizing that her last working day was on July 29, 2012. The employee, however, argued that the statute of limitations was paused as the employer had compensated her during her leave under the Family and Medical Leave Act (FMLA).

Despite her claims of being exposed to harmful substances during work, leading to health complications, the court found no direct evidence that the employer had recognized her condition as a work-related occupational disease. Past legal precedents, like Fowler v. City of Huntsville and Belser v. American Cast Iron Pipe Co., were referenced to clarify when compensations could toll the statute of limitations. The trial court deemed the employee's complaint as time-barred and upheld the employer's summary judgment. The employee appealed this decision, but the trial court's judgment was affirmed.

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