Copelin v. Reed Tool Co.
This is an appeal from a summary judgment against an appellant who sought damages for loss of consortium after her husband, George Copelin, was injured at work in 1979. The appellee, his employer and a workers' compensation subscriber, argued that the appellant's derivative claim was barred because the husband's negligence action was precluded by the Workers' Compensation Act. The court held that if the injury was intentionally inflicted, the cause of action would not be barred, and thus the question of intentional misconduct was a material issue of fact. Additionally, the court determined that the appellant's claim for loss of consortium is her separate property and cannot be forfeited by her husband's workers' compensation agreement. Consequently, the trial court's summary judgment was reversed, and the case was remanded for further proceedings.