Florida Supreme Court Clarifies Ambiguities In State’s Workers’ Compensation Law
The Supreme Court of Florida clarified the scope of the state’s workers’ compensation law holding that: (1) a workers’ compensation exclusion provision in an employer liability policy operates to bar coverage of tort claims arising out of the same underlying incident; and (2) a release in a workers’ compensation settlement may prohibit an estate from collecting a tort judgment on the same claim.
In the underlying case, a man was killed while working for his employer. Subsequently, his spouse entered into a workers’ compensation settlement with the employer’s workers’ compensation and employer liability insurance carrier. The agreement contained a release indicating that the spouse elected the workers’ compensation settlement as the sole remedy for her claims. Separately, the man’s estate brought a wrongful death action against the employer alleging negligence that resulted in the grant of a default judgment. On appeal, the Eleventh Circuit, seeking clarification as to Florida workers’ compensation law, certified the following questions to the Supreme Court of Florida: (1) whether “the provision in the employer liability policy which excludes from coverage ‘any obligation imposed by workers’ compensation . . . law’ operates to exclude coverage of the [employee’s] estate’s claim against [the employer liability insurance carrier for a separate] tort judgment [against the employer]; and (2) whether “the release in [a] workers’ compensation settlement agreement otherwise prohibits[s] the estate’s collection of [the separately obtained] tort judgment?”
The Supreme Court of Florida answered both of these questions in the affirmative. As to the first, the court explained that under the plain language of the workers’ compensation exclusion, any obligation that was imposed by workers’ compensation law was excluded from coverage under the employer liability policy. Thus, it was clear that the exclusion barred coverage of the wrongful death claims, which were claims of negligence against the employer and, as such, would be covered by workers’ compensation.
With regard to the second question, the court explained that per the plain language of the release, the deceased’s spouse elected the workers’ compensation settlement as her sole remedy for any claims related to her husband’s death. Further, the court noted that under Florida workers’ compensation law, where an employee’s death results from an employer’s negligence, “the workers’ compensation liability is ‘exclusive and in the place of all other liability.’” The court explained that the Florida law fixes the amount due to the employee’s beneficiaries, and that a surviving spouse may enter into an agreement to claim such amount. The court stated that in the instant case, the settlement agreement complied with Florida’s Workers’ Compensation law and that the deceased’s spouse, represented by counsel, had chosen to enter into the settlement. Therefore, the court found that the release further precluded the estate from collecting on the tort judgment.
