Layne Kay and Emily Kay v. Barnes Bullets

Summary

The Utah Supreme Court vacated and remanded a district court order denying Barnes Bullets' motion for summary judgment in an employee's lawsuit alleging intentional lead poisoning. The court held that the district court must first determine whether the employee's condition is an accidental injury under the Workers' Compensation Act or an occupational disease under the Occupational Disease Act. If the condition is an occupational disease, the district court must also consider whether the intentional-injury exception applies.

Holdings

1. The court could not properly decide the intentional-injury and summary-judgment issues before determining whether Kay's lead poisoning was an accidental injury under the Workers' Compensation Act or an occupational disease under the Occupational Disease Act.
2. The court had not extended, and in this case did not extend, the Workers' Compensation Act's intentional-injury exception to claims governed by the Occupational Disease Act.
3. The district court's denial of Barnes Bullets' motion for summary judgment was vacated, and the case was remanded for further determinations concerning the statutory classification of Kay's lead poisoning and the potential application of the intentional-injury exception.

Questions Presented

1. Whether Kay's lead poisoning was an accidental injury governed by the Workers' Compensation Act or an occupational disease governed by the Occupational Disease Act.
2. Whether the Workers' Compensation Act's intentional-injury exception extends to claims governed by the Occupational Disease Act.
3. Whether the district court properly denied Barnes Bullets' motion for summary judgment based on the evidence of intentional injury.

Disposition

vacated