Idaho Supreme Court allows worker’s lawsuit to proceed over jurisdiction

A default judgment must stand against the employer of an injured worker who argued that his injury fell within an exception to Idaho’s exclusive-remedy rule, the state Supreme Court ruled Thursday.

The ruling in Tyler v. Masterpiece Floors, Inc., which became a matter of jurisdiction, overturned the Idaho Industrial Commission’s later assessment that the injury did not fall outside exclusive remedy.

In September 2019, Cameron Tyler was attempting to cut a piece of wood flooring using a table saw at Masterpiece Floors, which did not provide safety guards. Because of a saw mishap, Mr. Tyler lost a finger. The saw also lacerated or fractured the remaining fingers on the hand.

Since the injury Mr. Tyler had received some workers comp benefits, including medical and disability, although part of his claim is “pending” with the Industrial Commission, according to court records.

In April 2021, Mr. Tyler sued Masterpiece, alleging the company “had implemented the business practice of requiring employees … to operate the table saw without the protective guard in place,” which “constituted an act of willful or unprovoked physical aggression against (Mr. Tyler), serving to satisfy the exception to the exclusive remedy rule.”

After the employer failed to appear and defend against the lawsuit, Mr. Tyler obtained a default judgment. About six months later, Masterpiece sought to set aside that judgment, arguing that the district court lacked subject-matter jurisdiction. Because the workers compensation claim was filed first, the company argued, Mr. Tyler was required to obtain a determination from the Industrial Commission that the allegations qualified as an exception to the exclusive remedy rule before the district court had subject-matter jurisdiction over any civil tort action.

The district court agreed that it may not have had subject-matter jurisdiction and stayed enforcement of the judgment until the commission decided that issue. The commission later concluded that Mr. Tyler’s injury was not the result of the employer’s willful or unprovoked physical aggression, and thus did not meet the criteria to breach exclusive remedy. The district court then granted the employer’s motion to set aside the default judgment on grounds that it did not have jurisdiction.

The Idaho Supreme Court disagreed, reversed the district court and vacated the commission’s findings. In referring to batches of case law, it wrote that the “exception to the exclusive remedy rule” alleged in Tyler is “actually raised and litigated in district courts, not before the Commission.”