Can workers' compensation exclusivity bar additional contractual benefits? Shattuck-Owen v. Snowbird Corp. Explained

In Shattuck-Owen v. Snowbird Corp., the Utah Supreme Court addressed whether the Workers’ Compensation Act’s exclusive remedy provision bars breach of contract claims for benefits beyond those provided by the compensation system.

Background and Facts

Shattuck-Owen, a Snowbird employee, was sexually assaulted at work while resting between shifts. The assault was captured on surveillance video, which Snowbird showed to approximately ten to thirteen people during the investigation. After the incident, Snowbird’s Human Resources Director allegedly promised to pay for private therapy costs but later refused payment. Shattuck-Owen sued for invasion of privacy and breach of contract. The trial court granted summary judgment, ruling both claims were barred by the Workers’ Compensation Act’s exclusive remedy provision.

Key Legal Issues

The court addressed two primary issues: (1) whether showing surveillance video to a limited number of investigation personnel constitutes public disclosure sufficient for an invasion of privacy claim, and (2) whether the Workers’ Compensation Act bars contractual claims for benefits supplemental to those provided by the compensation system.

Court’s Analysis and Holding

For the invasion of privacy claim, the court applied the Restatement standard requiring public disclosure of private facts. The court affirmed summary judgment, finding that showing the video to ten to thirteen people for legitimate investigative purposes did not constitute sufficiently “public” disclosure. The court emphasized that disclosure must be “to the public at large, or to so many persons that the matter must be regarded as substantially certain to become one of public knowledge.”

However, the court reversed on the breach of contract claim. It held that the Workers’ Compensation Act’s exclusive remedy provision does not bar contracts for benefits in addition to those mandated by the Act. The court distinguished between tort claims masquerading as contract claims (which are barred) and legitimate contractual agreements for supplemental benefits (which are enforceable under normal contract principles).

Practice Implications

This decision clarifies that employers may contractually agree to provide benefits beyond workers’ compensation without triggering exclusivity bars. For practitioners, the decision emphasizes the importance of distinguishing between tort claims recast as contract claims and genuine contractual obligations for supplemental benefits. The ruling also demonstrates that invasion of privacy claims require careful analysis of what constitutes sufficiently “public” disclosure.