Arias v. Geisinger
126 Conn. App. 860
Conn. App. Ct.2011Background
- Plaintiff Juan Arias was seriously injured June 6, 2005, while a trailer (container plus chassis) being moved by defendant's yard truck struck a wooden canopy beam overhead.
- Both the plaintiff and the defendant were acting within the scope of employment at Meridian Operations, a tire recycling company in Plainfield.
- The rear doors of the container were open; the trailer was being towed away from the loading dock when the injury occurred.
- The trial court treated the container and chassis as a single trailer unit and found liability for negligent movement of the trailer.
- The defendant asserted § 31-293a as an exclusive remedy bar, contending the incident did not involve negligent operation of a motor vehicle under the statute.
- The court awarded the plaintiff $1.2 million, and the defendant appealed challenging the § 31-293a applicability.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether the trailer constitutes a motor vehicle under § 31-293a and § 14-1 | Trailer is a motor vehicle, drawn by nonmuscular power, suitable for highway use. | Trailer may not fit the motor vehicle definition; rely on Surprenant distinction and off-road equipment ideas. | Trailer qualifies as a motor vehicle under § 31-293a. |
| Whether the defendant operated a motor vehicle at the time of the injury | Defendant controlled and directed the trailer's movement when towing it away from the dock. | Movement by the yard truck was not equivalent to operating the motor vehicle defining the exception. | Yes, the defendant operated the motor vehicle (the trailer) at the time. |
| Whether § 31-293a’s exclusive remedy bar precludes the plaintiff’s action | The negligence fell within the motor-vehicle exception to exclusivity; suit allowed unless willful/malicious. | The act’s exclusivity should bar the suit absent willful/malicious conduct or motor-vehicle negligence under the exception. | The exception applies; judgment affirmed. |
Key Cases Cited
- Colangelo v. Heckelman, 279 Conn. 177 (2006) (defines motor vehicle scope under § 31-293a and § 14-1)
- Jaiguay v. Vasquez, 287 Conn. 323 (2008) (explains exclusivity and motor-vehicle exception under § 31-293a)
- Surprenant v. Burlingham, 64 Conn.App. 409 (2001) (operation of a motor vehicle involves control/direction by operator)
- Cruz v. Montanez, 294 Conn. 357 (2009) (statutory interpretation framework; text and relationship to other statutes)
- Pinheiro v. Board of Education, 30 Conn.App. 263 (1993) (highway suitability analysis for vehicle design)