Gomez v. Crookham

Summary

The Idaho Supreme Court reviews a wrongful-death and product-liability action arising from an employee’s fatal injury while cleaning a seed-sorting machine. The court holds that Idaho’s workers’ compensation exclusive-remedy rule generally bars civil claims against the employer, including death claims, but reverses in part because the trial court failed to consider whether the employer’s conduct constituted unprovoked physical aggression under Idaho Code section 72-209(3). The court also addresses the scope of the Industrial Commission’s jurisdiction and the employer’s status for product-liability purposes.

Holdings

1. Idaho Code sections 72-209(1) and 72-211 must be read in pari materia and together comprise Idaho's exclusive-remedy rule. When an employee is entitled to and receives workers' compensation benefits for a work-related death, the Industrial Commission generally has exclusive jurisdiction over the death claim and civil remedies against the employer are barred unless an exception applies.
2. The district court erred by failing to determine whether Crookham consciously disregarded knowledge of a serious risk to employees working at or under the unguarded, non-lockout-tagged picking table. Evidence including Crookham's prior related OSHA violations created a genuine issue requiring further consideration under the unprovoked-physical-aggression exception.
3. Crookham was not a manufacturer of the picking table because the table was neither a product nor a component part of a product under Idaho Code section 6-1402.
4. The plaintiffs were not entitled to attorney fees because both sides prevailed in part on appeal.

Questions Presented

1. Whether Idaho Code sections 72-209(1) and 72-211 together establish an exclusive-remedy rule that bars civil death claims against an employer covered by workers' compensation.
2. Whether the exception in Idaho Code section 72-209(3) for injury or death proximately caused by wilful or unprovoked physical aggression could apply based on evidence that Crookham consciously disregarded knowledge of a serious risk to employees.
3. Whether the district court erred by granting summary judgment without applying the consciously-disregarded-knowledge standard under Marek v. Hecla, Ltd.
4. Whether Crookham was a manufacturer of the picking table under the Idaho Product Liability Reform Act.
5. Whether the plaintiffs were entitled to attorney fees on appeal.

Disposition

reversed_and_remanded