Gomez v. Crookham Co.

In 2015 Crookham Company (defendant) installed new equipment for sorting seeds. The equipment did not have proper guards or safety mechanisms. Prior to 2015, the Occupational Safety and Health Administration (OSHA) had issued citations against Crookham for violating safety requirements. On January 20, 2016, Francisca Gomez, a Crookham employee, was killed while cleaning the equipment after her hair was pulled into the machine—an accident that would not have occurred if the equipment had the required guards and safety mechanisms. The Gomez family (plaintiffs) received workers’-compensation benefits from Crookham. In addition, the Gomezes filed a wrongful-death action against Crookham in Idaho court. Under Idaho state law, workers’-compensation benefits were generally the exclusive remedy available to employees who were entitled to the benefits. The exclusive-remedy provision in the law contained an exception for injuries that occurred as a result of an employer’s willful or unprovoked physical attack against an employee. In such cases, an employee was entitled to workers’-compensation benefits and to bring a civil lawsuit against her employer. Crookham filed a motion for summary judgment, arguing that the exclusive-remedy provision barred the Gomezes’ wrongful-death action. The Gomezes opposed the motion, arguing that the exception to the exclusive-remedy provision applied because Crookham consciously disregarded knowledge that its failure to meet safety requirements would lead to an employee’s injury. The Gomezes highlighted the previous citation by OSHA against Crookham and presented an expert witness who testified that Crookham’s actions were intentional, reckless, and negligent. The district court granted summary judgment for Crookham. The Gomezes appealed.