Walls Regional Hospital v. Bomar
Nurses Kym Bomar, Laura Cosby, and Cynthia Patterson sued their employer, Walls Regional Hospital, alleging negligence for allowing Dr. George Boyett to sexually harass them and for negligent hiring/credentialing. The Hospital moved for summary judgment, arguing the Workers’ Compensation Act barred the action. The district court granted summary judgment, but the court of appeals reversed, finding fact issues regarding the 'personal animosity' exception. The Supreme Court of Texas disagreed with the court of appeals, holding that the nurses' injuries occurred in the course of their employment and did not fall under the 'personal animosity' exception, as the harassment was workplace-specific and not rooted in personal animosity transported from outside work. Consequently, the Workers’ Compensation Act provides the exclusive remedy, barring the negligence claim. The Court reversed the court of appeals' judgment and rendered judgment for the Hospital.