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Pike v. Harold (Chubby) Baird Gate Co., Inc.

Citations: 705 S.W.2d 947; 1986 Ky. App. LEXIS 1050

Court: Court of Appeals of Kentucky; February 14, 1986; Kentucky; State Appellate Court

Narrative Opinion Summary

The case involves an employee who filed a wrongful discharge lawsuit against her employer, alleging that her termination was due to her pursuit of workers' compensation benefits for an injury. The employer moved to dismiss the lawsuit on the grounds that it was filed outside the statutory limitations period and argued that a statutory provision preempted the employee's common law tort claim. The trial court dismissed the case as time-barred, applying a one-year statute of limitations applicable to personal injury claims. However, the appellate court found that the trial court erred in its application of the statute of limitations, determining that the five-year limitations period for statutory liabilities was appropriate. Additionally, the appellate court held that the statutory provision did not preempt the employee's common law rights, as established in precedent. Consequently, the appellate court reversed the trial court's decision and remanded the case for a trial on the merits, thus reinstating the employee's claim and allowing for further appellate proceedings under civil procedure rules.

Legal Issues Addressed

Appellate Review and Remand

Application: The appellate court reversed the trial court's decision, allowing the case to proceed on its merits.

Reasoning: The appellate court reversed the trial court's judgment, remanding the case for a trial on the merits...

Preemption by Statute

Application: The court determined that statutory provisions do not preclude common law claims for wrongful discharge when filing workers' compensation claims.

Reasoning: The court found that KRS 342.197 does not abolish the common law tort action established in Firestone Textile Co. Div. v. Meadows.

Statute of Limitations for Wrongful Discharge

Application: The appellate court clarified the applicable statute of limitations for wrongful discharge claims, applying the five-year period for statutory liabilities.

Reasoning: The trial court dismissed her claim as time-barred, incorrectly applying the one-year statute of limitations under KRS 413.140(1)(a)... rather than the five-year statute under KRS 413.120(2).

Wrongful Discharge and Workers' Compensation Claims

Application: The court examined whether an employee could maintain a wrongful discharge claim after seeking workers' compensation benefits, despite statutory provisions against discrimination.

Reasoning: Naomi Ruth Pike filed a wrongful discharge complaint against her employer... claiming her termination... was solely due to her seeking workers' compensation benefits.