Saarinen v. Hall

Supreme Court of Alabama

Franklin County | 249 So. 3d 1104 | Sept. 1, 2017


Court Reverses Denial of Summary Judgment, Finds Uninstalled Safety Saw Does Not Equate to Removal of a Safety Guard

Bobby Saarinen and Chris Williams, supervisory employees at Williams Manufacturing, Inc., sought an appeal after the Franklin Circuit Court denied their motion for a summary judgment regarding a personal-injury action filed against them by Louis Hall. In 2014, Hall was injured while using a power saw at Williams Manufacturing. He originally sued the company and its supervisory employees for negligence, willfulness, and recklessness. Williams Manufacturing was dismissed from the suit, claiming that the Alabama Workers' Compensation Act covered Hall's injury.

Hall then alleged that the supervisors had removed a safety guard from the saw, which led to his injury. Saarinen and Williams, in their defense, invoked a section of the Alabama Code which stated that co-employees could only be liable for willful conduct causing injury. The main contention arose around whether the failure to replace an older saw with a newer, safer saw (which was already present on the premises but not in operation) equaled the removal of a safety guard.

Past case law had interpreted "removal" liberally, equating "failure to install" or "bypassing" a safety device to its removal. However, the Court found no such negligence by the co-employees in this case and ruled that simply not installing a safer saw present on the premises did not equate to willful conduct as per the Alabama Code. Therefore, the trial court's judgment was reversed, and the case was remanded.

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