Brown v. 1301 K Street Ltd. Partnership

Summary

The District of Columbia Court of Appeals held that an employee’s disclaimer releasing the employer’s customers from liability for workplace injuries was valid and enforceable. The court affirmed summary judgment for the building owner and property manager, concluding that the disclaimer covered negligence and statutory-duty claims and applied to both appellees as customers of the security company.

Holdings

1. The disclaimer did not waive or limit Brown's right to compensation under the District of Columbia Workers' Compensation Act; it waived only tort claims against the employer's customers for injuries covered by workers' compensation.
2. The disclaimer was facially unambiguous and enforceable according to its plain language because it clearly released claims against Allied Security's customers and their employees for covered workplace injuries.
3. Enforcement of the disclaimer did not violate public policy because it released liability for ordinary workplace negligence in exchange for the employer's provision of workers' compensation, and the record did not place the disclaimer within the narrow category of releases contrary to public policy.
4. The disclaimer could apply to Brown's OSHA and District of Columbia Industrial Safety Act claims because those statutes establish standards or duties of care rather than imposing strict liability, and Brown did not allege gross negligence, willfulness, or fraud.
5. The disclaimer applied to both Hines and 1301 K Street because both were customers of Allied Barton, either jointly or independently, regardless of whether Hines and 1301 K Street were legally the same entity.

Questions Presented

1. Whether the disclaimer was invalid under the District of Columbia Workers' Compensation Act because it waived Brown's right to compensation.
2. Whether the disclaimer was unenforceable as a general release or on public-policy grounds.
3. Whether the disclaimer could release claims based on OSHA and District of Columbia Industrial Safety Act duties.
4. Whether the disclaimer applied to 1301 K Street and Hines as customers of Allied Barton.
5. Whether disputed issues of material fact precluded summary judgment.

Disposition

affirmed