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Access over workers' compensation decisions, including En Banc, Significant Panel Decisions, and writ-denied cases.

Case No. MISSING
Regular Panel Decision

Jean-Louis v. Hilton Hotels Corp.

The court properly dismissed the plaintiff's second cause of action, which alleged negligent training, management, and supervision of employees. The plaintiff claimed she was confined to an office for an hour and denied a union representative during a discussion regarding work distribution based on her ethnicity and religious beliefs. The court ruled that this claim is barred by the exclusive remedy provisions of the Workers’ Compensation Law. It further stated that the cause of action did not provide sufficient facts to invoke the intentional tort exception to the Workers’ Compensation Law, specifically lacking allegations that the defendants had knowledge of or acquiesced in their employees' tortious conduct.

negligent trainingnegligent supervisionworkers' compensation lawexclusive remedyintentional tort exceptionemployment lawdismissalunion representationethnicity discriminationreligious discrimination
References
2
Case No. 03-21-00120-CV
Regular Panel Decision
Feb 24, 2022

Brian Manley, Chief of Austin Police Department Brian Manley, Individually Commander Mark Spangler, Austin Police Department Lt. Jerry Bauzon, Austin Police Department Officer Benjamin Bloodworth, Austin Police Department Officer Collin Fallon, Austin Police Department Sgt. Eric Kilcollins, Training Coordinator, Austin Police Academy And Officer Shand, Lead Instructor, Stress Reaction Training, Austin Police Academy v. Christopher Wise

Christopher Wise, a former Austin Police Academy cadet, sued Brian Manley (APD Chief) and six other APD officers after sustaining severe injuries, including heat exhaustion and stroke, during a stress reaction training in October 2018. Wise alleged that officers intentionally discouraged cadets from hydrating despite high temperatures and failed to provide timely medical aid. The defendants sought dismissal under the Texas Tort Claims Act's election-of-remedies provisions. The district court dismissed claims against the City of Austin and APD but not against the individual officers. The appellate court reversed the district court's decision, ruling that Wise's claims against the individual officers were based on conduct within the scope of their employment and could have been brought under the TTCA, thus mandating their dismissal.

Texas Tort Claims ActGovernmental ImmunityElection of RemediesScope of EmploymentPolice MisconductCadet InjuryHeat IllnessSupervisor NegligenceAppellate CourtReversal
References
25
Case No. MISSING
Regular Panel Decision

American Train Dispatchers Ass'n v. Metro-North Commuter Railroad

Plaintiff American Train Dispatchers Association (ATDA) accused defendant Metro-North Commuter Railroad Company of violating the Railway Labor Act (RLA) by unilaterally implementing changes to work rules and conditions without prior union consultation. The changes concerned sick leave, vacation days, training time, work attire, and drug/alcohol testing. The court classified these disputes as either 'major' or 'minor' under the RLA. It found that the automatic requirement for doctor's certificates for sick days not contiguous to rest days, holidays, or vacation, and the new work attire policy constituted 'major disputes', and thus granted a permanent injunction to restore the status quo. However, the court deemed disputes over training time, single vacation days, and sick days contiguous to rest days/holidays/vacation as 'minor disputes', denying injunctive relief for these. The court also denied injunctive relief for random drug testing due to insufficient evidence, noting that the issue of drug testing as part of regular medical examinations was being addressed in a separate ruling.

Railway Labor ActMajor DisputeMinor DisputeInjunctive ReliefWork RulesSick Leave PolicyVacation PolicyTraining TimeDress CodeDrug Testing
References
14
Case No. MISSING
Regular Panel Decision

O'Neil v. Roman Catholic Diocese

A student worker at St. Ephrem’s Church (the plaintiff) experienced sexual harassment from a visiting priest. After a particularly egregious incident, she informed other parish priests who promptly referred her to law enforcement. The plaintiff subsequently sued the Roman Catholic Diocese of Brooklyn and St. Ephrem’s Church for sexual harassment, negligence, negligent hiring, and negligent supervision, arguing they should have known of the priest's propensity. The Supreme Court, Kings County, granted summary judgment to the Diocese defendants, dismissing the plaintiff's claims, finding they lacked actual or constructive knowledge. The appellate court affirmed this decision, concluding that the defendants met their burden in demonstrating no prior knowledge of the visiting priest's conduct and acted diligently once informed.

Sexual HarassmentHostile Work EnvironmentNegligenceNegligent HiringNegligent SupervisionSummary JudgmentEmployer LiabilityConstructive KnowledgeDiscriminationNew York City Human Rights Law
References
8
Case No. MISSING
Regular Panel Decision

Health Acquisition Corp. v. Program Risk Management Inc.

The plaintiffs, home health care companies (Health Acquisition Corp., Bestcare, Inc., and Aides at Home, Inc.), sued various defendants, including accounting firm DeChants, Fuglein & Johnson, LLP (DFJ) and actuarial firm SGRisk, LLC, for professional negligence and negligent misrepresentation. The suit arose after the self-insurance trust they were members of became insolvent, leading to significant assessments from the Workers' Compensation Board. Plaintiffs alleged defendants concealed the trust's true financial state and their liability risks. The Supreme Court initially dismissed claims against DFJ and SGRisk. However, the appellate court reversed this decision, finding the complaint adequately alleged "near-privity" and negligence against both firms, even clarifying that actuaries could be held liable for common-law negligence despite not being licensed professionals for malpractice claims. A partial appeal concerning leave to amend the complaint was dismissed.

professional negligencenegligent misrepresentationCPLR 3211 (a)motion to dismissgroup self-insurance trustWorkers' Compensation Law § 50joint and several liabilityactuariesaccountantsnear-privity
References
15
Case No. MISSING
Regular Panel Decision
Aug 04, 1993

Joint Apprenticeship & Training Council of Local 363 v. New York State Department of Labor

The plaintiff, Joint Apprenticeship and Training Council of Local 363 (JATC), sought a preliminary injunction to prevent the New York State Department of Labor (NYSDOL) from deactivating its status as a registered apprenticeship training program. JATC argued that deactivation procedures should mirror deregistration, requiring a hearing, and that the Fitzgerald Act provided a private right of action. The court denied the motion, finding no federal requirement for a hearing for deactivation and distinguishing it from deregistration, which has more severe consequences. Furthermore, the court concluded that the Fitzgerald Act does not create a private right of action for program sponsors. The court also found no irreparable harm to the plaintiff or its apprentices, as apprentices could transfer to other programs without losing credit, and the JATC program could re-register or continue unregistered.

Preliminary InjunctionApprenticeship ProgramDeactivationDeregistrationNew York State Department of LaborFitzgerald ActPrivate Right of ActionIrreparable HarmFederal RegulationsState Regulations
References
11
Case No. 2020 NY Slip Op 08017 [192 AD3d 91]
Regular Panel Decision
Dec 29, 2020

Sandoval v. Leake & Watts Servs., Inc.

Eduardo Sandoval, a nonverbal autistic resident, suffered burns from a heated potato masher at a residential facility operated by Leake and Watts Services, Inc. (L&W). His co-guardians sued L&W, its employees Asialone Edwards and Wendell Chavies, alleging battery, negligence, and negligent hiring, retention, supervision, and training. The Supreme Court denied L&W's and Edwards' motions for summary judgment. The Appellate Division modified this decision, dismissing claims against L&W based on respondeat superior, but affirmed the denial of summary judgment for negligent hiring, retention, supervision, and training claims, and for Edwards' individual claims. The court highlighted L&W's failure to adequately check employee references and that the potential for abuse was foreseeable based on L&W's own training materials.

Negligent hiringNegligent retentionNegligent supervisionNegligent trainingRespondeat superiorSummary judgmentAutismResidential facilityEmployee misconductPropensity to commit injury
References
15
Case No. 14-14-00332-CV
Regular Panel Decision
Aug 20, 2015

Ramiro Najera v. Recana Solutions, LLC

Ramiro Najera, an employee of Recana Solutions, LLC, a staffing company, was assaulted by a co-worker, James Prodoehl, at a plant operated by American Rice, Inc. Najera sued Recana, alleging respondeat superior, negligence in hiring and retaining Prodoehl due to a lack of criminal background check, and negligent supervision and training. The trial court granted a take-nothing summary judgment for Recana. On appeal, the Fourteenth Court of Appeals affirmed the summary judgment, concluding that Recana had no general duty to perform a criminal background check for the laborer position, and Najera failed to show reliance or increased harm for a negligent undertaking claim. The court also found no evidence that Recana breached its duty to supervise or train Prodoehl, and Najera did not raise a fact issue on the respondeat superior claim or challenge the summary judgment on gross negligence.

Negligent HiringNegligent SupervisionNegligent TrainingRespondeat SuperiorSummary JudgmentWorkplace AssaultEmployee InjuryCriminal Background CheckEmployer DutyForeseeability of Harm
References
48
Case No. MISSING
Regular Panel Decision

Lewis v. State

A prisoner, Clarence Eugene Lewis, working in a prison workshop, suffered a severe hand injury while operating a punch press without safety guards. He filed a claim with the Tennessee Claims Commission, alleging negligence by his supervisors for inadequate training and unsafe equipment. The Claims Commissioner dismissed his claim, finding Mr. Lewis at least 50% responsible for his injuries due to comparative negligence, as he intentionally placed his hand under the press while his foot was on the pedal. This court affirms the Commissioner's decision, agreeing that while the supervisors were negligent in maintaining a safe workplace and providing training, Mr. Lewis's own actions constituted at least 50% of the fault, precluding recovery under Tennessee's comparative fault principles.

Prisoner injuryIndustrial accidentPunch pressNegligence claimComparative faultWorkplace safetyInadequate trainingSafety guardsTennessee Claims CommissionDepartment of Correction
References
9
Case No. 09-21-00247-CV
Regular Panel Decision
Dec 22, 2022

Sharon Appleton v. Consolidated Crane and Rigging, LLC

Sharon Appleton appealed the trial court's summary judgment in favor of Consolidated Crane & Rigging, LLC (CCR) after her husband, Alfred Appleton, died from injuries sustained in a fall. Alfred fell from a boom truck being used by CCR employee Melvin Mixon for a personal task at his home, subsequent to Mixon completing an authorized charitable task for CCR. Appleton sued CCR for wrongful death, negligence, respondeat superior, and negligent hiring, training, and supervision. The Court of Appeals affirmed the summary judgment, ruling that Mixon was not acting within the course and scope of his employment during the incident and that CCR did not owe a duty under the negligent hiring, training, or supervision claims due to lack of foreseeability and the burden on the employer.

Summary judgmentRespondeat superiorNegligent hiringNegligent trainingNegligent supervisionCourse and scope of employmentForeseeabilityDuty of careEmployer liabilityBoom truck accident
References
35
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