Court Determines Employer Does Not Have a Duty to Protect Employee-Plaintiff Outside the Scope of Employment

Recently, a state appellate court issued an opinion in a wrongful death case brought by the estate of a woman who was hit by a train after being told to leave her workplace while intoxicated. The court had to determine if the estate could prevail in a negligence lawsuit based on the fact that the woman’s employer provided her with alcohol, knowing she was an alcoholic, and then ejected her from the premises. Ultimately, the court concluded that the duty an employer owes to an employee does not extend beyond the scope of employment and rejected the estate’s lawsuit.

The case presents an interesting issue for employees injured in Washington, D.C. workplace accidents that were caused by a third party.

The Facts of the Case

The deceased employee worked for a company that maintained a bar on the premises. Employees were encouraged to stay after work and have a drink, in hopes that the employees would stay at work longer and produce more output.

One day, the employee, who was required to take Alcoholic Anonymous classes, was drinking after work at the employer’s bar. The employee was provided with a number of drinks, to the point at which she became intoxicated. As she became intoxicated, she started to get agitated at her fellow employees. Eventually, she was escorted out of the building, and her access was revoked.

The woman started walking in the direction of her home but was struck by a train on the way home. The woman’s estate filed a wrongful death lawsuit against the woman’s employer, arguing that it was negligent in providing her with alcohol, knowing that she was an alcoholic.

The Court’s Decision

The court found in favor of the employer and rejected the estate’s case. The court first explained that there is no independent cause of action an employee has against an employer for an injury that occurs outside the context of the employee’s position with the company. The court then went on to explain that although the trajectory of events ultimately leading up to the woman’s death began at her place of employment, the employee’s own actions were the legal cause of her death, rather than the employer’s decision to provide her with alcohol. Thus, the court determined that the employer had no legal duty to protect the employee in this particular circumstance, and it dismissed the estate’s case.

Have You Been Injured in a Washington, D.C. Accident?

If you or a loved one has recently been injured in a Washington, D.C. workplace accident, you may be entitled to monetary compensation. While workers’ compensation benefits may be the only available benefits in some on-the-job injury cases, claims against third parties or claims that are brought against an employer but are unrelated to the scope of employment are not subject to these limitations. The dedicated Washington, D.C. personal injury and wrongful death lawyers at the law firm of Lebowitz & Mzhen Personal Injury Lawyers have extensive experience handling all types of personal injury cases, including those arising out of workplace accidents. To learn more, call 410-654-3600 today.

More Blog Posts:

Court Determines that Grocery Store’s Ignorance of Risk Cannot Excuse Its Lack of Knowledge in Recent Premises Liability Case, Washington DC Injury Lawyer Blog, May 16, 2018

Court Reverses Summary Judgment in Favor of Plaintiff in Recent Premises Liability Lawsuit, Washington DC Injury Lawyer Blog, June 4, 2018

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