Ex parte Nicholas Shane Carlton

Summary

The Alabama Supreme Court held that an employee injured by a negligent co-employee while acting within the scope of employment was not legally entitled to recover uninsured-motorist benefits under a family automobile insurance policy because the Workers’ Compensation Act barred recovery against the co-employee. The court relied on the plain language of Alabama Code § 32-7-23 and overruled State Farm Automobile Insurance Co. v. Baldwin, State Farm Mutual Automobile Insurance Co. v. Jeffers, and Hogan v. State Farm Mutual Automobile Insurance Co. to the extent they authorized recovery despite the statutory requirement. The court affirmed the Alabama Court of Civil Appeals’ judgment denying benefits.

Holdings

1. Carlton was not entitled to uninsured-motorist benefits because the Workers' Compensation Act barred him from recovering damages from his co-employee, and therefore he was not legally entitled to recover damages from the owner or operator as required by Ala. Code § 32-7-23 and the State Farm policy.
2. State Farm Automobile Insurance Co. v. Baldwin, State Farm Mutual Automobile Insurance Co. v. Jeffers, and Hogan v. State Farm Mutual Automobile Insurance Co. were overruled to the extent they authorized uninsured-motorist recovery when the insured was not legally entitled to recover damages from the owner or operator of an uninsured vehicle.

Questions Presented

1. Whether an employee injured in a work-related motor-vehicle accident who is barred by the Alabama Workers' Compensation Act from suing a negligent co-employee is legally entitled to recover uninsured-motorist benefits under a family automobile liability policy.
2. Whether Alabama's prior decisions allowing uninsured-motorist recovery despite immunity or other legal bars to a tort action should be overruled to the extent they conflict with the plain language of Ala. Code § 32-7-23.

Disposition

affirmed