Michael C. Traffanstedt had a 2006 settlement agreement with his employer, Dover Corporation, regarding workers' compensation, leaving future medical benefits open. In 2011, a settlement agreement about these benefits was not approved by the trial court. By 2013, another agreement was sought. However, Traffanstedt died a day before the scheduled hearing. Liberty Mutual, the insurance carrier for the employer, had issued a check for the 2013 agreement, which was dependent on court approval. After Traffanstedt's death, they refused to honor it. Consequently, Pat Tate, the administrator of Traffanstedt's estate, sued both Liberty Mutual and Heil (Dover Corporation), claiming breach of contract and asserting the companies were bound by the 2013 agreement.
Both Heil and Liberty Mutual counter-argued that the exclusivity provisions of the Alabama Workers' Compensation Act barred Tate's claims and that without court approval before Traffanstedt's death, they weren't bound by the 2013 agreement. The trial court ruled in favor of Liberty Mutual and Heil. Tate appealed. On appeal, Tate argued that the 2013 settlement agreement should be treated like any other contract and hence was binding despite not being approved by the trial court before Traffanstedt's death. Heil and Liberty Mutual contended that the Act's specific nature does not allow settlements like other agreements. The court's decision focused on whether a workers' compensation settlement requires the same kind of treatment as other settlement agreements and whether the lack of court approval invalidated the 2013 agreement.
Because the exclusivity provisions of the Act preclude other causes of action seeking to enforce rights under the Act, the declaratory-judgment and breach-of-contract action instituted by Tate was barred by §§ 25-5-52 and 25-5-53.
"Special Employee" Status Shields Midsouth from Negligence Claims: Court Validates Exclusive-Remedy Provisions
Court Sides with Defendant in Workplace Injury Case, Granting Immunity Under Workers' Compensation Act
Court Upholds Dismissal of Plaintiff's Claims against Employer on Grounds of Expiry and Lack of Evidence
Defendant's Petition for Dismissal of Plaintiff's Claims Denied by Court
Court Reverses Ruling on Defendant's Status as Employer's Agent in Plaintiff's Accident Case
Interpretation of "Employer" under the Workers' Compensation Act Challenges Defendant's Claim to Immunity
Defendant's Mandamus Petition Denied: Alleged Post-Accident Negligence Not Covered by Workers' Compensation Exclusivity Provisions
Court Upholds City of Muscle Shoals' Claim to Immunity Over Gattman Park Injury
Tenax Granted Immunity in Worker's Injury Lawsuit due to Alabama Workers' Compensation Act
Court Reverses Denial of Summary Judgment, Finds Uninstalled Safety Saw Does Not Equate to Removal of a Safety Guard
Rock Wool Asserts Worker's Injury Claims Barred by Workers' Compensation Act, Countering Casons' Suit under Employer's Liability Ac
Court Rules on Dismissal and Jury Trial Issues in Workplace Assault Case
TDY Employee's Injury Lawsuit Faces Jurisdiction Challenge on Appeal After Key Counts Dismissed by Trial Court.
Exposure to Hazardous Chemicals Limited to Workers' Compensation Remedies
Plaintiff Appealed a Summary Judgment in Favor of APCo on Claims of Negligence and Wantonness
Tort Claims Against Special Employer are Barred by Exclusive-Remedy Provision of the Act
No Evidence of Toxicity Exposure or Work-Related Disease
Procedural Dispute of Proper Court to review Exclusivity Provisions
Administrative Rule deemed Willful Conduct: Claim Allowed under Exclusive Remedy Provisions
Release of Claims Under Workers' Compensation Act does not include Claims Based on Willful Removal of Safety Devicee
Alabama Court Reverses Dismissal of Wal-Mart Worker's Claim, Citing Due Process Concerns.
Court Affirms Overturning Dismissal for Lack of Prosecution