Christopher Lea Williams v. John Buraczynski
E2016-01605-COA-R3-CV
| Tenn. Ct. App. | Jul 19, 2017Background
- On January 12, 2015, co-workers Christopher Lea Williams and John Buraczynski, both employed by Progression Electric, carpooled to work; they were in Buraczynski’s vehicle when it was involved in a collision that injured Williams.
- Williams applied for and received workers’ compensation benefits from Progression (no dispute employer paid and that the injury was compensable).
- Williams then sued Buraczynski (and initially Progression) in circuit court alleging negligence by Buraczynski; Williams nonsuited Progression, leaving the claim against the co-employee.
- Buraczynski moved to amend his answer to plead estoppel defenses and later moved for summary judgment, arguing Williams’s exclusive remedy is workers’ compensation and that Williams is estopped from asserting inconsistent positions.
- The trial court granted summary judgment for Buraczynski, finding Williams had represented he was acting in the course and scope of employment by obtaining workers’ compensation and thus could not pursue a tort claim against a co-employee for the same incident.
- Williams appealed; the Court of Appeals affirmed, holding Williams is limited to workers’ compensation and may not maintain the negligence action against his co-worker.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether summary judgment should be granted because workers’ compensation is Williams’s exclusive remedy | Williams: undisputed facts do not establish he was in course and scope of employment at accident; therefore exclusive-remedy does not apply | Buraczynski: Williams sought and received workers’ comp and admitted employment facts; exclusive remedy (or estoppel) bars the tort claim | Held: Affirmed — exclusive remedy/estoppel bars the negligence claim against co-employee |
| Whether Williams is judicially or equitably estopped from asserting an inconsistent position | Williams: may pursue tort while having received workers’ comp (can have both positions) | Buraczynski: Williams made representations to employer and received benefits; those sworn/administrative statements negate essential element of tort claim | Held: Williams may not assert inconsistent positions; estoppel (or exclusive-remedy application) prevents suit against co-employee |
Key Cases Cited
- Rye v. Women’s Care Cntr. of Memphis, MPLLC, 477 S.W.3d 235 (Tenn. 2015) (summary-judgment standards and burdens on movant/nonmovant)
- Cracker Barrel Old Country Store, Inc. v. Epperson, 284 S.W.3d 303 (Tenn. 2009) (distinguishing judicial estoppel from equitable estoppel; elements of equitable estoppel)
- Bain v. Wells, 936 S.W.2d 618 (Tenn. 1997) (standard of review for summary judgment)
- Matsushita Elec. Indus. Co. v. Zenith Radio Corp., 475 U.S. 574 (U.S. 1986) (nonmovant must do more than show metaphysical doubt to defeat summary judgment)
- Curtis v. G.E. Capital Modular Space, 155 S.W.3d 877 (Tenn. 2005) (workers’ compensation as a trade-off: quick recovery for immunity from tort liability)