Beauchamp v. Dow Chemical Co.

398 N.W.2d 882, 427 Mich. 1 (1986)

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Beauchamp v. Dow Chemical Co.

Michigan Supreme Court
398 N.W.2d 882, 427 Mich. 1 (1986)

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Facts

Ronald Beauchamp (plaintiff) worked for Dow Chemical Co. (defendant) as a research chemist. During his employment, Beauchamp was exposed to agent orange and suffered mental and physical damages. Beauchamp sued, alleging that Dow intentionally assaulted him and breached its contract to provide a safe workplace. Dow argued that Beauchamp failed to state a claim for which relief could be granted because the workers’-compensation act was the exclusive remedy for nonintentional injuries arising from employment. The trial court granted summary judgment for Dow, holding that Beauchamp failed to state a claim for which relief could be granted. Beauchamp appealed. Michigan’s appellate court affirmed, finding that an intentional tort outside of the workers’-compensation remedy requires that the employer must intend the injury itself, not just the activity leading to the injury. Beauchamp appealed to the Michigan Supreme Court.

Rule of Law

Issue

Holding and Reasoning (Levin, J.)

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