Renell Williams v. Starr Indemnity & Liability Co. et al.

Summary

The United States District Court for the Eastern District of Louisiana granted Venture Global Plaquemines LNG, LLC’s motion for summary judgment in a workplace-injury action brought by Renell Williams. The court held that Venture Global was Williams’s statutory employer under the Louisiana Workers’ Compensation Law because the parties’ master service agreement recognized the relationship and the security services were integral and essential to Venture Global’s business, including during facility construction. Williams’s tort claims were dismissed with prejudice because workers’ compensation was her exclusive remedy.

Holdings

1. A written contract recognizing a statutory-employer relationship creates a rebuttable presumption that the principal is the contractor's employees' statutory employer under Louisiana Revised Statutes § 23:1061(A)(3). Because the Master Service Agreement expressly recognized Venture Global as Stratigos employees' statutory employer, the presumption applied to Williams.
2. Security services provided at Venture Global's LNG facility during construction were integral to and essential for Venture Global's business. The facility's construction status did not distinguish the case from decisions treating security services and construction-related work as integral to industrial operations.
3. Williams was not entitled to deferment or additional discovery because she provided neither the required affidavit or declaration nor specific facts showing that additional discovery would create a genuine issue of material fact.
4. Because Venture Global was Williams's statutory employer, the Louisiana Workers' Compensation Law made workers' compensation her exclusive remedy and immunized Venture Global from her tort claims.

Questions Presented

1. Whether Venture Global qualified as Williams's statutory employer under Louisiana Revised Statutes § 23:1061.
2. Whether the security services provided during construction of Venture Global's LNG facility were integral to or essential for Venture Global's business, thereby sustaining the statutory-employer presumption.
3. Whether Williams showed under Federal Rule of Civil Procedure 56(d) that additional discovery was necessary before deciding the summary-judgment motion.
4. Whether statutory-employer status made workers' compensation Williams's exclusive remedy and barred her negligence claims against Venture Global.

Disposition

other