Does workers' compensation bar negligence suits between employees on employer premises? Brown v. Williams Explained

In Brown v. Williams, the Utah Court of Appeals addressed whether workers’ compensation law precludes negligence suits between employees injured on employer premises, even when the employer does not own the property.

Background and Facts

Marjorie Ann Brown was injured in an auto-pedestrian accident while walking through an IRS employee parking lot on her way to work. The accident occurred within a fenced area designated for IRS employees, controlled by security personnel requiring employee badges for access. After her federal workers’ compensation claim was denied, Brown filed a negligence suit against her co-worker. The defendant moved for summary judgment, arguing the exclusive remedy provision of the Utah Workers’ Compensation Act barred the negligence claim.

Key Legal Issues

The court addressed two primary issues: whether workers’ compensation law or tort law applied to determine if the employees acted within the course of employment, and whether summary judgment was appropriate given disputed facts about the IRS’s ownership and control of the premises.

Court’s Analysis and Holding

The Court of Appeals applied the premises rule exception to the “coming and going rule,” which provides workers’ compensation coverage for accidents occurring on employer premises. The court relied on Hope v. Berrett, finding that when an accident occurs between co-employees on employer premises, workers’ compensation provides the exclusive remedy. Significantly, the court rejected Brown’s argument that the IRS’s lack of ownership or control over the parking lot precluded application of the premises rule, noting that such a restrictive interpretation would conflict with the Act’s liberal construction requirement.

Practice Implications

This decision reinforces that Utah courts apply workers’ compensation law broadly to protect the exclusive remedy provision. Practitioners should recognize that ownership and control are not determinative factors under the premises rule—rather, courts focus on whether the location constitutes employer premises where employees have a tangible connection to their employment. The decision also demonstrates that creative legal arguments challenging well-established premises rule applications are unlikely to succeed when framed as factual disputes.