In two separate decisions issued on March 23, 2010, the Supreme Court of Ohio upheld the constitutionality of an Ohio law that limits the ability of workers injured on the job to sue their employers for "workplace intentional torts." The statute at issue, Ohio Revised Code 2745.01, provides that a worker bringing an intentional tort claim against his or her employer must prove that the employer acted "with a deliberate intent to cause injury" to the worker.
In Kaminski v Metal & Wire Products Co., the Court held in a 6-1 decision that R.C. 2745.01 did not violate the Ohio Constitution. Rose Kaminski was a press operator at the Salem, Ohio metal fabrication manufacturing facility of Metal & Wire Products Company. She applied for and received workers' compensation benefits after a coil of rolled steel fell onto her legs and feet, injuring her. She also brought a lawsuit against her employer that alleged Metal & Wire committed an intentional injury for which Kaminski should receive additional damages. Kaminski asked the Court to hold that R.C. 2745.01 was unconstitutional and to consider her claim under the Court's previous standard stated in Fyffe v. Jeno's Inc., which held that an injured worker may sue for an intentional tort when she can prove that her employer knew about a workplace condition that was "substantially certain to cause injury" to the worker. The court rejected Kaminski's argument. It held that the Ohio Constitution grants the legislature wide authority to enact laws regulating wages, hours and workplace conditions, and to adopt laws in order to balance the rights and obligations of employers and employees in the operation of the state workers' compensation system. As a result, the legislature did not exceed its authority by enacting R.C. 2745.01 and limiting workplace intentional torts.
In a separate decision, Stetter v. R.J. Corman Derailment Services, the Court answered a series of state law questions submitted by the U.S. District Court for the Northern District of Ohio. Carl Stetter was an employee at the Millbury, Ohio facility of R.J. Corman Derailment Services. He applied for and was granted workers' compensation benefits after he was injured while inflating a truck tire that exploded. Like the plaintiff in Kaminski, Stetter brought a lawsuit against his employer alleging that R.J. Corman committed an intentional injury for which Stetter should receive additional damages. After Stetter filed a motion asserting that R.C. 2745.01 was unconstitutional, the district court asked the Supreme Court to answer eight questions of state law that corresponded to Stetter's motion. The Court addressed each question and found that R.C. 2745.01 does not violate the provisions of the Ohio Constitution that guarantee trial by jury, a remedy for damages, open courts, due process, equal protection of the laws, or the separation of powers between the legislative and judicial branches of government. The Court also held that while R.C. 2745.01 restricts the right of a worker to bring an intentional tort claim against the employer, it does not eliminate that right entirely.
Kaminski and Stetter are a resounding victory for R.C. 2745.01 and its limitation on workplace intentional torts. The Court's decisions reflect the fact that a large majority of states impose similar limitations on workplace injury suits based on the strong public policy favoring "no-fault" workers' compensation systems. Under these systems, employees give up their right to sue their employer in tort in exchange for a system of no-fault liability, under which employees may recover an award even when they are injured as the result of their own negligence. The purpose of this exchange between employer and employee is to avoid excessive litigation over common workplace injuries. The decisions in Kaminski and Stetter bring Ohio in line with a majority of states that apply standards the same as or similar to those contained in R.C. 2745.01. They also strengthen Ohio's workers' compensation system by assuring the system maintains a balance of sacrifices between employers and employees.