392 P.3d 919
Utah Ct. App.2017Background
- In January 2012, Brown was injured walking in the IRS parking lot on the way to work at the Ogden, Utah IRS facility.
- The parking lot and building were protected by a fence and accessible only through security, with employee badges required for access.
- Brown was struck by a vehicle driven by another IRS employee, Nelson, within IRS premises.
- Nelson died after the filing; Williams, as Nelson’s personal representative, substituted as defendant.
- Brown’s federal workers’ compensation claim was denied; Brown then filed a state-law negligence action, which Williams moved to dismiss under the exclusive remedy provision of Utah’s Act.
- The district court granted summary judgment in favor of Williams, holding that Brown’s injury fell within workers’ compensation as the accident occurred on IRS premises, making WC her exclusive remedy.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether WC law applies instead of tort law | Brown argues course-of-employment rules apply under tort law, not WC. | Williams argues the Act applies and precludes negligence because the accident occurred on IRS premises. | WC law applies; exclusive remedy applies. |
| Whether summary judgment was proper | Brown contends disputes of material fact exist precluding summary judgment. | Williams argues no genuine material fact remains and the premises rule supports WC coverage. | Summary judgment proper; no genuine issue of material fact. |
Key Cases Cited
- Hope v. Berrett, 756 P.2d 102 (Utah Ct. App. 1988) (applies premises rule to federal employee on way to work; liberal construction in favor of employment relation)
- Stamper v. Johnson, 232 P.3d 514 (Utah 2010) (employee benefits under Act imply injury occurred in course of employment)
- Salt Lake City Corp. v. Labor Comm’n, 153 P.3d 179 (Utah 2007) (coming-and-going rule; exceptions like premises rule)
- Soldier Creek Coal Co. v. Bailey, 709 P.2d 1165 (Utah 1985) (premises rule; injury on employer’s premises constitutes course of employment)
- Hope v. Berrett, 756 P.2d 102 (Utah Ct. App. 1988) (premises rule applied to parking lot/building on same property)
- Ahlstrom v. Salt Lake City Corp., 2003 UT 4, 73 P.3d 315 (Utah 2003) (liberal construction of employee status under WC Act)
- Clover v. Snowbird Ski Resort, 808 P.2d 1037 (Utah 1991) (tort-based premises-related considerations in resort-employer context)
- Birkner v. Salt Lake County, 771 P.2d 1053 (Utah 1989) (tort-focused analysis; distinguishes from WC premises rule on employee injuries)