Fernando Morales v. Martin Resources, Inc., Martin Operating Partnership, L.P., and Select Professional Staffing
Fernando Morales, a temporary employee, sued Martin Resources, Inc., Martin Operating Partnership, L.P., and Select Professional Staffing for negligence after sustaining a hand injury at Martin Resources' Odessa facility. The trial court initially granted summary judgment to the defendants, citing the exclusive remedy provision of the Texas Workers' Compensation Act (TWCA). On appeal, the Eleventh Court of Appeals reviewed whether the defendants had sufficiently proven their workers' compensation insurance coverage, a necessary condition for the exclusive remedy provision to apply. The court found that neither Select Professional Staffing nor Martin Resources, Inc. provided adequate evidence of explicit workers' compensation coverage for themselves. Consequently, the appellate court reversed the trial court's summary judgment and remanded the case for further proceedings, emphasizing the burden of proof for establishing affirmative defenses like the exclusive remedy provision.