Leonard Phillips v. American Elastomer Products, LLC

CourtCourt of Appeals of Texas
DecidedJune 17, 2010
Docket14-09-00164-CV
StatusPublished

This text of Leonard Phillips v. American Elastomer Products, LLC (Leonard Phillips v. American Elastomer Products, LLC) is published on Counsel Stack Legal Research, covering Court of Appeals of Texas primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Leonard Phillips v. American Elastomer Products, LLC, (Tex. Ct. App. 2010).

Opinion

Affirmed and Opinion filed June 17, 2010.

In The

Fourteenth Court of Appeals

NO. 14-09-00164-CV

Leonard Phillips, Appellant

v.

American Elastomer Products, L.L.C., Appellee

On Appeal from the 129th District Court

Harris County, Texas

Trial Court Cause No. 2007-35985

O P I N I O N

Appellant, Leonard Phillips, appeals from two summary judgments rendered against him in his personal injury suit against appellee, American Elastomer Products, L.L.C. (“AEP”).  After sustaining a work-related injury, Phillips filed suit against AEP for negligence, gross negligence, and intentional torts.  AEP filed two summary judgment motions, contending that (1) Phillips’s negligence claims were barred by the borrowed servant doctrine and the Texas Workers’ Compensation Act (“TWCA”), and (2) there was insufficient summary judgment evidence to support the intentional tort claims.  The summary judgments were granted, and Phillips filed the instant appeal.  In two issues, Phillips contends that the trial court improperly granted summary judgment because (1) AEP failed to establish as a matter of law that Phillips was not a borrowed servant, and (2) the summary judgment evidence was sufficient to raise genuine issues of material fact on the intentional tort claims.  We affirm. 

I.  BACKGROUND

This personal injury case arises from a back injury Phillips sustained as a result of an autoclave explosion at AEP’s rubber manufacturing plant in Houston.  About a year prior to the explosion, AEP was in the process of transporting new equipment to its Houston plant.  To make room for the new equipment, AEP placed some of its older equipment outside the plant building.  One of the pieces of equipment AEP decided to store outside was the autoclave in question.  The autoclave—a vessel used to heat rubber—was taken out of commission and placed just outside the plant building.  For the following year, the autoclave remained out of commission and was not inspected or maintained while out of service.  About a year later, space inside the plant building became available, and AEP decided to move the autoclave back into the plant building and bring it back into service.   AEP’s maintenance managers started a series of tests on the vessel to assure its safe re-commission.  During the preliminary tests, the autoclave failed and exploded on March 8, 2007.  Many people were injured, one fatally. 

When the autoclave exploded, Phillips was operating a press machine nearby. Phillips came to work at AEP through a staffing agency, Staffing United (“Staffing”).  Phillips was interviewed by Staffing, and AEP trained Philips at the plant.  Upon hearing the explosion and feeling its concussion, Phillips attempted to flee the plant building. As he ran, he tripped and injured his back.  Phillips claimed that he suffered from herniated discs and was later diagnosed with post-traumatic stress disorder.  Phillips reported his back injury to Staffing.  Staffing did not contest Phillips’s request for workers’ compensation, and the workers’ compensation insurance carrier paid Phillips statutory benefits.[1]  

Thereafter, Phillips filed suit against AEP, initially asserting negligence, gross negligence, and premises liability.  AEP moved for summary judgment, claiming that the negligence claims were barred under the exclusivity provision of the TWCA because Phillips was a borrowed servant.  Phillips amended his petition, adding intentional infliction of emotional distress (“IIED”).  AEP moved for summary judgment on the IIED claim on both no-evidence and traditional grounds.  Phillips amended his petition once again, removing the IIED claim and adding intentional assault and battery claims.  The trial court granted the first summary judgment addressing the negligence claims. 

AEP then moved for summary judgment on the remaining intentional tort claims, arguing that there was insufficient evidence on the assault, battery, and IIED claims.[2]  Upon objection, the trial court—in two separate orders—struck most of Phillips’s summary judgment evidence because the documents were either untimely filed or contained inadmissible hearsay.  Phillips did not challenge the evidentiary rulings.  The trial court granted AEP’s no-evidence and traditional summary judgments on the intentional tort claims, and this appeal ensued.  

On appeal, Phillips raises two issues.  In his first issue, in which he challenges the first summary judgment dismissing his negligence claims, Phillips contends that because he was not a borrowed servant, his common-law negligence claims were not subject to the TWCA’s exclusivity provision.  In his second issue, challenging AEP’s second summary judgment on his intentional assault claims, Phillips contends he produced sufficient summary judgment evidence on the element of intent.

II.  STANDARDS OF REVIEW

While AEP clearly moved for summary judgment under rules 166a(c) and 166a(i)—traditional and no-evidence grounds—on Phillips’s intentional tort claims, AEP did not specify whether it was making a traditional motion for summary judgment or a no-evidence motion on the negligence claims.  Compare Tex. R. Civ. P. 166a(c), with Tex. R. Civ. P. 166a(i).  Because the two forms of summary judgment are distinct and invoke different standards of review, we must make an initial determination regarding which type of summary judgment was filed on the negligence claims before we can reach the merits of the trial court’s ruling on these particular claims. 

When a motion does not clearly and unambiguously state that it is being filed under rule 166a(i), the nonmovant has no notice that the movant is seeking a no-evidence summary judgment.  Grimes v. Reynolds, 252 S.W.3d 554, 558 (Tex. App.—Houston [14th Dist.] 2008, no pet.).  Accordingly, we construe such summary judgment motion as a traditional motion under rule 166a(c).  See id. (concluding that when a motion for summary judgment fails to unambiguously state it is filed under rule 166a(i), and does not strictly comply with the requirements of that rule, the motion will be construed as a traditional motion for summary judgment); see also Adams v. Reynolds Tile and Flooring, Inc., 120 S.W.3d 417

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Leonard Phillips v. American Elastomer Products, LLC, Counsel Stack Legal Research, https://law.counselstack.com/opinion/leonard-phillips-v-american-elastomer-products-llc-texapp-2010.