Williams v. ALPLA, Inc.
2017 Ohio 4217
| Ohio Ct. App. | 2017Background
- Plaintiff Ryan Williams, an ALPLA employee and shift supervisor, suffered a severe right-arm injury on August 24, 2013 while reaching into an SSB160 bottle-manufacturing machine.
- Bottles were falling and accumulating under the machine; Williams opened a sliding plexiglass access door and reached inside while the machine remained running to clear/clean components.
- Williams believed he was wiping a photo-eye sensor (depositions later indicate it may have been a proximity sensor); he admitted he could have shut the machine off but did not.
- Williams sued under Ohio’s employer intentional tort statute (R.C. 2745.01), alleging ALPLA deliberately removed a safety steel plate and otherwise acted with deliberate intent to injure.
- ALPLA moved for summary judgment arguing Williams failed to show the specific intent required by R.C. 2745.01 or that any safety guard was deliberately removed.
- Trial court granted summary judgment for ALPLA; the appellate court affirmed, finding no genuine issue that ALPLA acted with deliberate intent to injure or deliberately removed an equipment safety guard.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether genuine issues of material fact exist to show employer deliberate intent under R.C. 2745.01 | Williams contends training and practices permitted/required reaching into the machine and that facts are disputed | ALPLA says record does not show specific intent; at most shows negligence or inadequate training | No genuine issue: evidence at best shows inadequate training/ negligence, not deliberate intent |
| Whether removing a steel plate or other guard triggers rebuttable presumption of intent under R.C. 2745.01(C) | Williams asserts a steel plate (safety mechanism) was removed and shutdown was inaccessible at that door | ALPLA contends no evidence a safety plate existed/was removed or that a cut-off was at that access point; plaintiff’s emails not before trial court | No: record lacks evidence a guard existed or was deliberately removed; R.C. 2745.01(C) presumption not triggered |
| Whether plaintiff acted in conformity with training at time of injury and relevance | Williams claims he followed training in clearing bottles | ALPLA argues he tried to clean a sensor outside training and that even if trained, inadequate training ≠ deliberate intent | Court deems conformity to training immaterial for proving deliberate intent; inadequate training cannot substitute for specific intent |
| Whether the shutdown mechanism was unavailable at the access Williams used | Williams implies machine could not be shut off at that door | ALPLA points to depositions showing shutoff tied to a different set of doors; no evidence of disabled shutdown at plaintiff’s access | Held that depositions do not establish shutdown was inaccessible at that door; does not create factual dispute on intent or guard removal |
Key Cases Cited
- Houdek v. ThyssenKrupp Materials N.A., Inc., 983 N.E.2d 1253 (Ohio 2012) (describing R.C. 2745.01’s limitation to employer deliberate intent)
- Kaminski v. Metal & Wire Prods. Co., 927 N.E.2d 1066 (Ohio 2010) (interpreting the ‘‘substantially certain’’/deliberate intent standard)
- Hoyle v. DTJ Ents., Inc., 36 N.E.3d 122 (Ohio 2015) (R.C. 2745.01(C) rebuttable presumption when employer deliberately removes equipment safety guard)
- Hewitt v. L.E. Myers Co., 981 N.E.2d 795 (Ohio 2012) (definition of deliberate removal of a guard)
- Murphy v. Reynoldsburg, 604 N.E.2d 138 (Ohio 1992) (summary judgment standard: construe evidence in favor of nonmoving party)