Can an employee recover both workers' compensation and uninsured motorist benefits? Lieber v. ITT Hartford Insurance Center, Inc. Explained

The Utah Supreme Court’s decision in Lieber v. ITT Hartford Insurance Center, Inc. clarifies a critical intersection between workers’ compensation and uninsured motorist coverage. The case definitively establishes when employees can pursue both types of benefits following work-related vehicle accidents.

Background and Facts
Randy Lieber was injured in a multi-vehicle accident while driving a company vehicle for his employer Kraft. He received workers’ compensation benefits from Hartford Insurance and also sought uninsured motorist coverage from the same insurer for damages caused by unknown drivers who fled the scene. Hartford moved for summary judgment, arguing that Utah’s Workers’ Compensation Act provided Lieber’s exclusive remedy and that its policy excluded coverage for employees receiving workers’ compensation benefits.

Key Legal Issues
The court addressed three primary questions: (1) whether Utah Code § 31A-22-305(4)(b)(ii) bars employees from collecting both workers’ compensation and uninsured motorist benefits, (2) whether Hartford’s policy exclusions were valid, and (3) whether Lieber was entitled to attorney fees. The interpretation of the exclusive remedy provision under Utah Code § 34A-2-105(1) was central to the analysis.

Court’s Analysis and Holding
The court applied correctness review to the statutory interpretation issues. It held that the Workers’ Compensation Act’s exclusive remedy provision only bars claims against employers and their officers, agents, or employees—not third-party tortfeasors. The court distinguished between situations where uninsured drivers are employers or co-employees (where exclusive remedy applies) versus third parties (where both benefits are recoverable). The decision relied heavily on Thamert v. Continental Casualty Co., a 1980 precedent that Hartford failed to cite.

Practice Implications
This decision provides important guidance for practitioners handling work-related vehicle accidents. Employees maintain viable tort claims against third-party uninsured motorists despite receiving workers’ compensation benefits. Insurance policy exclusions that conflict with statutory requirements may be invalidated. The court’s criticism of Hartford’s failure to cite adverse controlling authority also reinforces ethical obligations under Professional Conduct Rule 3.3(a)(3) and potential attorney fee consequences for meritless positions.