Casey v. Alcoa Corporation

CourtDistrict Court, W.D. Washington
DecidedMarch 16, 2020
Docket2:18-cv-01358
StatusUnknown

This text of Casey v. Alcoa Corporation (Casey v. Alcoa Corporation) is published on Counsel Stack Legal Research, covering District Court, W.D. Washington primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Casey v. Alcoa Corporation, (W.D. Wash. 2020).

Opinion

1 2

3 4 5 UNITED STATES DISTRICT COURT WESTERN DISTRICT OF WASHINGTON 6 AT SEATTLE 7 CLINTON E. CASEY, 8 Plaintiff, C18-1358 TSZ 9 v. ORDER 10 ALCOA CORPORATION, et al., 11 Defendants. 12 THIS MATTER comes before the Court on Defendant Alcoa’s1 Motion for 13 Summary Judgment, docket no. 75. Having reviewed all papers filed in support of and in 14 opposition to the motion, the Court enters the following order. 15 Background 16 Plaintiff Clinton E. Casey worked at Alcoa Wenatchee Works, an aluminum 17 manufacturing facility from 1973 until his retirement in 2005. Olson Decl., docket 18 no. 85, Ex. 2 at ¶¶ 2-3. Throughout his tenure at the facility, Casey worked as a utility 19 20

21 1 Alcoa, Inc. changed its name to Arconic, Inc. in 2016. Although Alcoa, Inc. and Arconic, Inc. are named as individual defendants in this action, the names refer to the same entity. For the purposes of this 22 Order, the Court refers to this defendant as “Alcoa.” 1 laborer and pot tender. Id. As a pot tender, Casey was present while workers dug out 2 pots containing asbestos insulation with jackhammers and shovels. Id. at ¶¶ 3, 7.

3 Digging out the pots created dust, which caused employees to cough and cover their faces 4 with bandanas. Id. On October 11, 2017, Casey was diagnosed with asbestosis, which 5 he attributed to his exposure to asbestos at the Alcoa facility. Olson Decl., docket no. 85, 6 Ex. 3. On February 8, 2020, Casey passed away. Olson Decl., docket no. 97, Ex. 2. 7 Alcoa’s industrial hygienist stated that Alcoa was aware that asbestos “could be” a 8 hazardous substance as early as the late 1940’s. Olson Decl., docket no. 85, Ex. 19 at

9 30:20-24. From the mid 1960’s to the late 1970’s, Alcoa became “increasingly 10 concerned about asbestos” as it began to learn more about the risks associated with 11 exposure. Id. at 165:19-22. Alcoa was aware that, given sufficient exposure to asbestos, 12 workers could contract asbestosis. Id. at 270:8-22. 13 Casey contends that Alcoa was aware that the asbestos dust levels in its facilities

14 exceeded the recommended threshold limit and that its efforts to protect workers exposed 15 to asbestos dust were insufficient. Olson Decl., docket no. 85, Exs. 23 & 32. Casey cites 16 internal memoranda in which Alcoa industrial hygienists acknowledge the risk associated 17 with asbestos exposure. In one memorandum, Alcoa’s chief industrial hygienist stated 18 that “[a]sbestosis, a disease resulting only from breathing asbestos dust, is now

19 recognized as being a significant industrial exposure hazard. Even intermittent exposures 20 to high concentrations, over long periods of time, can result in varying degrees of 21 asbestosis . . . . There have been reports of an increase incidence of lung cancer in 22 persons with asbestosis.” Olson Decl., docket no. 85, Ex. 27 at 2. Despite this 1 acknowledgment, Casey contends that Alcoa management never enforced safety rules or 2 remediation methods and that management downplayed the health risk associated with

3 asbestos exposure.2 Olson Decl., docket no. 85, Ex. 1 (Casey Dep.) at 181:17-21, 4 182:19-23, 183:24-184:14, 185:10-15, 188:14-189:1. 5 Casey also presents records of Alcoa employees who worked at the Wenatchee 6 facility before and during the same period as Casey. These employees presented with 7 possible signs of asbestos disease, such as pleural thickening, pleural plaques, and pleural 8 calcifications, which they attributed to asbestos exposure during their work at Alcoa

9 facilities. Olson Decl., docket no. 85, Exs. 9, 12, & 13. 10 Casey now alleges that Alcoa intentionally injured him by exposing him to 11 asbestos during his work at the Alcoa Wenatchee facility. Amended Complaint, docket 12 no. 41, ¶ 5.2. Alcoa moves for summary judgment on the basis that Casey’s claims are 13 barred by the Washington Industrial Insurance Act (WIIA). Alcoa contends that Casey’s

14 claims are barred because he failed to show that Alcoa intended to cause his injuries—a 15 narrow exception to the WIIA’s exclusive remedy provision. Specifically, Alcoa 16 contends that Casey failed to provide evidence that (1) Alcoa had actual knowledge 17 Casey was certain to develop asbestosis and (2) it willfully disregarded that knowledge. 18

19 2 Alcoa disputes this contention. Alcoa provides support for its assertion that it implemented extensive 20 remedial measures to protect employees and that it adopted stricter asbestos exposure standards than the existing industry and government standards even before Casey began to work at the facility. Craig Decl., docket no. 76, Exs. 6S-V, Ex. 7 at 15 & Ex. 8. Alcoa also states that it sought out non-asbestos 21 substitutes for materials when they were available, provided special work safety equipment for pot room employees, showers to wash off dust, lockers for separating dirty clothes, and a laundry service. Craig 22 Decl., docket no. 76, Ex. 5 (Casey Dep.) at 53:7-54:10 and Exs. 11-19. 1 Discussion 2 The Court shall grant summary judgment if no genuine issue of material fact exists

3 and the moving party is entitled to judgment as a matter of law. Fed. R. Civ. P. 56(a). 4 The moving party bears the initial burden of demonstrating the absence of a genuine issue 5 of material fact. Celotex Corp. v. Catrett, 477 U.S. 317, 323 (1986). A fact is material if 6 it might affect the outcome of the suit under the governing law. Anderson v. Liberty 7 Lobby, Inc., 477 U.S. 242, 248 (1986). To survive a motion for summary judgment, the 8 adverse party must present affirmative evidence, which “is to be believed” and from

9 which all “justifiable inferences” are to be favorably drawn. Id. at 255, 257. When the 10 record, however, taken as a whole, could not lead a rational trier of fact to find for the 11 non-moving party, summary judgment is warranted. See Beard v. Banks, 548 U.S. 521, 12 529 (2006) (“Rule 56(c) ‘mandates the entry of summary judgment, after adequate time 13 for discovery and upon motion, against a party who fails to make a showing sufficient to

14 establish the existence of an element essential to that party’s case, and on which that 15 party will bear the burden of proof at trial.’” (quoting Celotex, 477 U.S. at 322)). 16 I. Washington Industrial Insurance Act 17 The Washington Industrial Insurance Act (WIIA) established a compensation 18 system for workplace related injuries and gave employers immunity from civil suits by

19 workers. The Act carved out an exception to the exclusive remedy provision: employers 20 who deliberately injure their employees are not immune from suit. RCW 51.24.020. 21 22 1 II. Deliberate injury under Birklid & Walston 2 In 1995, the Washington Supreme Court analyzed the deliberate injury exception

3 set forth in RCW 51.24.020 in Birklid v. Boeing, 127 Wn.2d 853 (1995). Prior to Birklid, 4 courts interpreted the deliberate injury exception in RCW 51.24.020 as providing an 5 exception only in cases of an employer’s assault and battery against the employee. Id. at 6 862-63. In Birklid, Boeing observed employees becoming ill from exposure to chemical 7 fumes but did nothing. Id. at 856.

Free access — add to your briefcase to read the full text and ask questions with AI

Related

Anderson v. Liberty Lobby, Inc.
477 U.S. 242 (Supreme Court, 1986)
Beard v. Banks
548 U.S. 521 (Supreme Court, 2006)
Birklid v. Boeing Co.
904 P.2d 278 (Washington Supreme Court, 1995)
Vallandigham v. Clover Park School District No. 400
154 Wash. 2d 16 (Washington Supreme Court, 2005)
Walston v. Boeing Co.
334 P.3d 519 (Washington Supreme Court, 2014)
Shellenbarger v. Longview Fibre Co.
103 P.3d 807 (Court of Appeals of Washington, 2004)
Walston v. Boeing Co.
294 P.3d 759 (Court of Appeals of Washington, 2013)

Cite This Page — Counsel Stack

Bluebook (online)
Casey v. Alcoa Corporation, Counsel Stack Legal Research, https://law.counselstack.com/opinion/casey-v-alcoa-corporation-wawd-2020.