DEBORAH SIMMONS v. SOLO CUP OPERATING CORPORATION

CourtCourt of Appeals of Georgia
DecidedOctober 7, 2024
DocketA24A0623
StatusPublished

This text of DEBORAH SIMMONS v. SOLO CUP OPERATING CORPORATION (DEBORAH SIMMONS v. SOLO CUP OPERATING CORPORATION) is published on Counsel Stack Legal Research, covering Court of Appeals of Georgia primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
DEBORAH SIMMONS v. SOLO CUP OPERATING CORPORATION, (Ga. Ct. App. 2024).

Opinion

FOURTH DIVISION DILLARD, P. J., BROWN and PADGETT, JJ.

NOTICE: Motions for reconsideration must be physically received in our clerk’s office within ten days of the date of decision to be deemed timely filed. https://www.gaappeals.us/rules

October 7, 2024

In the Court of Appeals of Georgia A24A0623. SIMMONS et al. v. SOLO CUP OPERATING CORPORATION.

DILLARD, Presiding Judge.

The trial court granted Solo Cup Operating Corporation’s motion to dismiss

this wrongful-death action,1 holding that it was barred by the Georgia Workers’

Compensation Act. For the following reasons, we reverse.2

The undisputed facts show that Solo manufactures single-use products for food

and beverage packaging at a plant in Conyers—e.g., the ubiquitous red Solo cup. On

1 We review a trial court’s grant of a motion to dismiss de novo. See Dennis v. City of Atlanta, 324 Ga. App. 659, 659 (751 SE2d 469) (2013); accord Norman v. Xytex Corp., 310 Ga. 127, 130 (2) (848 SE2d 835) (2020). 2 Oral argument was held on April 10, 2024, and is archived on the Court’s website. See Court of Appeals of the State of Georgia, Oral Argument, Case No. A24A0623 (Apr. 10, 2024), available at https://vimeo.com/934571504. December 13, 2019, the decedent—Taurus Andrews, who worked at the

plant—discovered a small bag containing several identification cards in a men’s

restroom. Andrews turned the bag over his supervisor, who then took it to another

supervisor. That supervisor returned the bag to Camron Golden, who also worked at

the factory. Prior to that day, Andrews and Golden were not acquainted with one

another.

Once the bag was returned to him, Golden discovered that $400 was missing.

He asked who recovered the bag, and a supervisor told him it was Andrews. Golden

then confronted Andrews, who denied taking the money. But Golden was

unconvinced by this denial, and he told other employees he believed Andrews had

stolen his money. Golden then retrieved a handgun and shot Andrews at the plant,

tragically killing him.3

Deborah Simmons—Andrews’s mother and legal heir—filed a wrongful-death

action against Solo and other defendants, alleging that Solo negligently hired and

retained Golden and negligently failed to keep its premises safe. Solo filed a motion

3 Golden was later indicted for murder and other crimes, and he ultimately pleaded guilty to killing Andrews. 2 to dismiss,4 arguing the trial court lacked subject-matter jurisdiction because the

action was barred by the exclusivity provision of the Workers’ Compensation Act

(“WCA”). Following extensive briefing, a period of limited discovery, and a motion

hearing, the trial court granted Solo’s motion to dismiss. The court then directed the

entry of final judgment as to Solo.5 This appeal follows.

1. Simmons first contends the trial court erred in concluding that the WCA’s

exclusivity bar is a question of subject-matter jurisdiction. This claim is not properly

before us.

As a general principle, the WCA is the exclusive remedy for a worker or next

of kin who sustains an “injury” arising out of and in the course of employment.6

4 See OCGA § 9-11-12 (b) (1). 5 See OCGA § 9-11-54 (b). 6 See OCGA §§ 34-9-11 (a) (“The rights and the remedies granted to an employee by this chapter shall exclude and be in place of all other rights and remedies of such employee, his or her personal representative, parents, dependents, or next of kin, and all other civil liabilities whatsoever at common law or otherwise, on account of such injury, loss of service, or death[.]”); 34-9-1 (4) (defining an injury or personal injury for purposes of the WCA as an “injury by accident arising out of and in the course of employment”); Smith v. Camarena, 352 Ga. App. 797, 798 (2) (835 SE2d 712) (2019) (explaining that plaintiffs may not pursue a tort action when a worker’s death is compensable under the WCA). 3 Beginning with Kellogg Co. v. Pinkston,7 this Court has held that the exclusivity bar is

an issue of subject-matter jurisdiction.8 Simmons asserts this Court’s decisions in

Kellogg and its progeny are wrongly decided, contrary to other decisions from this

Court9 and the Supreme Court of Georgia,10 and should be disapproved or overruled.

In Solo’s original motion to dismiss (filed in March 2022), Solo argued the trial

court lacked subject-matter jurisdiction because Simmons’s claims were barred by the

WCA. Over the next 18 months, despite filing several different responses, Simmons

never claimed the exclusivity bar was not an issue of subject-matter jurisdiction or that

Kellogg and its progeny were wrongly decided. Rather, Simmons consistently

7 253 Ga. App. 190 (558 SE2d 423) (2001). 8 See id. at 191-92 (1) (558 SE2d 423) (2001) (holding the trial court was under a duty to dismiss plaintiff’s complaint for lack of subject-matter jurisdiction when WCA was plaintiff’s exclusive remedy); see also T & R S. Sanitation v. Lowe, 365 Ga. App. 220, 221 (1) (878 SE2d 77) (2022) (considering for the first time on appeal employer’s claim that the trial court lacked subject-matter jurisdiction because plaintiff’s claims fell within the exclusive jurisdiction of the WCA); Savannah Hosp. Servs., LLC v. Scriven, 350 Ga. App. 195, 199, n.4 (828 SE2d 423) (2019) (citing Kellogg, supra, for the proposition that “the application of the exclusivity bar is akin to an issue of the trial court’s subject[-]matter jurisdiction”). 9 Utz v. Powell, 160 Ga. App. 888 (288 SE2d 601) (1982). 10 Smith v. Ellis, 291 Ga. 566 (731 SE2d 731) (2012); Johnson v. Hensel Phelps Const. Co., 250 Ga. 83 (295 SE2d 841) (1982). 4 maintained the trial court had subject-matter jurisdiction because her claims fell

outside of the WCA.11

Suffice it to say, this Court may refuse to review issues not raised in the trial

court;12 and for good reason—fairness to the trial court and parties “demands that

legal issues be asserted in the trial court.”13 So, because this issue was not raised

11 A party may raise at any time a challenge to the trial court’s subject-matter jurisdiction, see Abushmais v. Erby, 282 Ga. 619, 622 (3) (652 SE2d 549) (2007) (“The court’s lack of subject-matter jurisdiction cannot be waived and may be raised at any time either in the trial court, in a collateral attack on a judgment, or in an appeal.” (citation and punctuation omitted)), but Simmons does not contend the trial court lacked subject-matter jurisdiction over this case. 12 See Pfeiffer v. Ga. Dep’t of Transp., 275 Ga. 827, 829 (2) (573 SE2d 389) (2002) (“[A]bsent special circumstances, an appellate court need not consider arguments raised for the first time on appeal.” (footnote omitted)); Santana v. Ga. Power Co., 269 Ga. 127, 129 (6) (498 SE2d 521) (1998) (holding that because a certain argument was not raised and ruled on by the trial court, the Supreme Court of Georgia would not address it on appeal); Ga. Dep’t of Natural Res. v. Coweta Cnty., 261 Ga. 484, 485 (405 SE2d 470) (1991) (“Issues which have not been ruled on by the trial court may not be raised on appeal.”); Pneumo Abex, LLC v. Long, 357 Ga. App. 17, 29 (2) (849 SE2d 746) (2020) (“As we have repeatedly explained, this is a Court for the correction of errors of law, and if the trial court has not ruled on an issue, we will not address it.

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