Lake v. Construction MacHinery, Inc.

787 P.2d 1027, 1990 Alas. LEXIS 21, 1990 WL 19185
CourtAlaska Supreme Court
DecidedFebruary 23, 1990
DocketS-3027
StatusPublished
Cited by20 cases

This text of 787 P.2d 1027 (Lake v. Construction MacHinery, Inc.) is published on Counsel Stack Legal Research, covering Alaska Supreme Court primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Lake v. Construction MacHinery, Inc., 787 P.2d 1027, 1990 Alas. LEXIS 21, 1990 WL 19185 (Ala. 1990).

Opinion

OPINION

BURKE, Justice.

An employee injured in the course of his employment brought a damage action against several third parties. He filed this petition after the superior court ruled that the third parties were entitled to assert, as a partial defense, that the plaintiffs employer was negligent. The question that we must decide is whether the employer is one of the parties among whom the finder of fact must allocate fault pursuant to the rule of modified joint and several liability found in AS 09.17.080, thereby reducing the liability of the third parties to the employee. For the reasons set forth below we hold that the employer’s negligence, if any, is relevant, but that its use by the jury is limited.

I

The underlying facts are not in dispute. Phillip Lake suffered an injury in the course and scope of his employment with Wormald Fire Systems, Inc., when he fell fifty feet from a manlift.

Lake filed products liability claims against the manlift manufacturer, JLG Industries, Inc.; the distributor, Construction Machinery, Inc.; and several intermediate vendors. The distributor filed a third party complaint against the employer on a theory of express indemnity. The distributor defended partly on the ground that the finder of fact should attribute negligence among all parties allegedly responsible for Lake’s injury, including the employer, and that the distributor’s ultimate liability to Lake should be determined pursuant to the rule of modified joint and several liability found in AS 09.17.080(d). 1

Lake moved to strike the defense, Alaska R.Civ.P. 12(f), arguing that the exclusive liability provision of the Workers’ Compensation Act, AS 23.30.055, precluded the trier of fact from considering the negligence of the employer. The superior court denied the motion to strike and a subsequent motion for reconsideration. We granted Lake’s petition for review. 2

II

Under the Alaska Workers’ Compensation Act, AS 23.30.005-.270, an employer is liable to pay compensation to an employee injured in the course and scope of employment, regardless of fault. AS 23.30.045(a), *1029 (b). In return, the employer is relieved from all further liability to the employee or any other person otherwise entitled to recover damages from the employer on account of the injury. AS 23.30.055. 3

An employee who believes that a third party is liable for the employee’s injuries may file suit to recover damages from the third party whether or not the employee has received compensation payments. AS 23.30.015(a). If the employee recovers damages, the employee must reimburse the employer for compensation paid and the cost of benefits provided, and any excess recovery is credited against future compensation payments. AS 23.30.015(g). 4 If the employee fails to file suit within one year of receiving a compensation award, the employer or its insurance carrier may sue the third party to recover damages. AS 23.30.-015(b), (i), AS 23.30.050. The exclusive liability provision precludes the assertion of a contribution claim against the employer, even if the employer’s negligence was a proximate cause of the employee’s injury. State v. Wien Air Alaska, 619 P.2d 719, 720 (Alaska 1980); cf. AS 09.16.010(a), (b).

In Arctic Structures v. Wedmore, 605 P.2d 426 (Alaska 1979), an employee who collected workers’ compensation benefits sued three third parties for damages. The third parties argued that, under the recently-adopted rule of pure comparative negligence, 5 the employee’s recovery should be reduced by the percentage of fault attributable to the employer, and that each third party should be liable to the employee only for that portion of the total liability corresponding to its percentage of fault. We ruled that (1) the common law rule of joint and several liability survived judicial adoption of the doctrine of pure comparative negligence, id. at 428-35, (2) third parties may not reduce their total liability to the employee in proportion to the percentage of negligence attributable to the employer, id. at 435-38, and (3) the employer is entitled to full reimbursement for compensation paid to the employee, even if the employer’s negligence is a proximate cause of the employee’s injury, id. at 438-40.

A year later we reaffirmed the decision in Arctic Structures, stating:

We have considered our holdings in Arctic Structures and, although we agree with the State that under these holdings injustices can arise in many cases, we are unpersuaded that we should alter these holdings in the case before us. As we pointed out in Arctic Structures, we are most reluctant to modify an existing legislative scheme in order to achieve an equitable result. 605 P.2d at 440. The statutes with which we are concerned express major policy decisions which are peculiarly within legislative competence. For example, we have no knowledge of the financial impact of deviating from the exclusive liability provision of the workmen’s compensation statute. That is a matter which could be clarified by legislative hearings, a process not available to this court. We have no comprehension of the economic tradeoffs which might be involved in a major overhaul of these statutes. Decisions concerning such matters are typically a legislative function.

Wien, 619 P.2d at 720.

In 1986, the legislature modified the rule of joint and several liability. AS 09.17.-080(d). 6 Under the new statute, the finder *1030 of fact must fix the damage awards, and determine the respective percentages of fault. Id. The court then enters judgment on the basis of modified joint and several liability. AS 09.17.080(c), (d).

Ill

Petitioners contend that the superior court erred in refusing to strike the challenged defense because AS 09.17.080(a)(2) does not specifically include statutorily immune employers in the group among whom the total fault must be allocated. Respondents contend that the purpose of AS 09.-17.080 will be frustrated if the employer’s fault is not considered.

This is a question of statutory interpretation subject to the independent judgment standard of review. Norton v. Alcoholic Beverage Control Bd., 695 P.2d 1090, 1092 (Alaska 1985). We will “adopt the rule of law that is most persuasive in light of precedent, reason, and policy.” Guin v. Ha, 591 P.2d 1281, 1284 n. 6 (Alaska 1979).

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Bluebook (online)
787 P.2d 1027, 1990 Alas. LEXIS 21, 1990 WL 19185, Counsel Stack Legal Research, https://law.counselstack.com/opinion/lake-v-construction-machinery-inc-alaska-1990.