Case File
A worker’s hand was crushed by a 2,500-pound check valve during a plant turnaround project. Could he avoid Louisiana workers’ compensation exclusivity by alleging an intentional tort and suing the plant owner?
Case
Knight v. Methanex USA, LLC, No. 26-30178 (5th Cir. 08/10/26)
What Happened?
A worker crushed his hand while installing a “check valve” at a methanol plant for which his employer provided contract work. The worker sued the plant, alleging that the plant failed to provide scaffolding large enough for him to evade the valve when it slipped. The District Court granted summary judgment, finding that the plant was the worker’s statutory employer, and so the Louisiana Workers’ Compensation Act provided the worker’s exclusive remedy.
The worker appealed to the 5th U.S. Circuit Court of Appeals
Rule of Law
A “principal” may be a statutory employer for LWCA purposes where it contracts with the injured worker’s direct employer for work that is “an integral part of or essential to the ability of the principal to generate that individual principal’s goods products, or services.
When a valid written contract recognizes the existence of a statutory employer relationship, “there shall be a rebuttable presumption of a statutory employer relationship between the principal and the contractor’s employees.”
What the 5th Circuit Said
The 5th Circuit agreed with the District Court that plant was the worker’s statutory employer because:
(1) The maintenance turnaround work the employer was performing under its contract with the plant was “an integral part of or essential to” the plant’s business.
(2) The parties’ contract expressly provided that the plant was the statutory employer of the employer’s workers.
Workers’ Comp 101: In Harris v. Murphy Oil, U.S.A., Inc., 980 F.2d 991 (5th Cir. 1992), the 5th Circuit established that maintenance turnaround work of an oil refinery was integral to the refinery’s business.
The 5th Circuit explained that the worker’s argument was “unavailing” because he only claimed that he should have been allowed more time to discover evidence relevant to the plant’s statutory employer defense.
Verdict: The 5th Circuit affirmed the District Court’s ruling in the plant’s favor.
Takeaway
In Louisiana, statutory employer status will be found when work a contractor is performing is “an integral part of or essential to” the employer’s business and where a contract expressly provides statutory employer status.
