Presley v. Dalton Logistics

Citations: 167 So. 3d 337; 2014 WL 5785802Docket: 2130892

Court: Court of Civil Appeals of Alabama; November 6, 2014; Alabama; State Appellate Court

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Dalton Logistics seeks a writ of mandamus to compel the Choctaw Circuit Court to grant its motion for summary judgment in a case brought by employee Ernest Harold Presley under the Alabama Workers’ Compensation Act. The employer argues that the Act does not apply to Presley’s claim, related to an injury he sustained in North Dakota, and asserts that the trial court lacks subject-matter jurisdiction. The court agrees, concluding that the Act does not provide a remedy in this instance and that the trial court lacks jurisdiction. 

The facts indicate that Presley was informed of job openings in North Dakota by his brother-in-law, communicated with the employer's secretary, and completed necessary paperwork sent via facsimile to finalize his employment. He later traveled to North Dakota, where he worked in a "man camp" and sustained an injury in August 2012 while moving oil-drilling equipment. The employer filed for summary judgment in March 2014, which was denied by the trial court in June 2014. Dalton Logistics subsequently filed its mandamus petition for review within the acceptable timeframe. The court notes that it can review claims of trial-court error regarding jurisdiction in such cases involving extraterritorial injuries.

The primary legal issue concerns the applicability of the Act to the employee’s workplace injury, which occurred in North Dakota, not Alabama. The location of the injury does not automatically disqualify the employee from receiving benefits under the Act. Benefits are available if the employee would have qualified for Alabama workers' compensation had the injury occurred there, provided one of several conditions is met. Specifically, benefits are payable if, at the time of the injury, the employee's work was "principally localized" in Alabama, or if the employee had an employment contract in Alabama under specific circumstances, such as employment not principally localized in any state or localized in a state whose workers' compensation laws do not apply to the employer.

The parties dispute where the employee's employment was "principally localized." The employer argues it was North Dakota, while the employee claims it was either Alabama or not localized in any state. According to the Act, employment is "principally localized" in a state where the employer has a business presence and the employee regularly works or resides while spending significant working time for the employer. The evidence indicates the employee was provided transportation to and accommodation in North Dakota, working exclusively at oil-rig locations there. Although the employee returned to Alabama periodically and had Alabama income taxes withheld, he performed no work in Alabama. Therefore, it is concluded that the employee’s work was "principally localized" in North Dakota, aligning with the precedent established in similar cases.

The court determined that the employee's employment was primarily localized in North Dakota, despite the employment contract being formed in Alabama. The relevant legal question involves whether the Alabama workers' compensation Act has extraterritorial application for injuries sustained in North Dakota when the employer may not be subject to North Dakota's workers' compensation laws. The court acknowledged that the employment contract was likely formed in Alabama and that the employment was indeed localized in North Dakota. The employer argued that North Dakota’s workers’ compensation laws apply broadly, while the employee contended they do not pertain to their relationship. The employee relied on North Dakota Century Code § 65-08-01, which outlines when injuries sustained outside the state are compensable, but the court clarified that this statute does not apply to injuries occurring within the state, such as the employee's alleged injury. The employee also claimed the employer’s failure to file a required injury report indicated non-applicability of North Dakota laws; however, the court noted that such failure actually implies acknowledgment of potential compensability under those laws. The court referenced a precedent (Barry v. Baker Elec. Coop. Inc.) where North Dakota law was upheld over Minnesota law in a similar context, emphasizing North Dakota's commitment to prioritizing its workers' compensation system. Ultimately, the court concluded that the employee did not sufficiently demonstrate that North Dakota's workers' compensation laws were inapplicable, thus affirming the trial court's jurisdiction to hear the employee’s claim under the Act.

The trial court's denial of the employer's summary-judgment motion was deemed outside its discretion due to the absence of alternative requirements for extraterritorial applicability of the Act as outlined in 25-5-35(b) and discussed in Williams. The court granted the employer's petition for a writ of mandamus, instructing the trial court to vacate its previous order and enter a summary judgment in favor of the employer. The employer's reliance on grounds from a motion to dismiss does not preclude seeking mandamus relief based on the summary-judgment ruling. The court rejected the employee's argument that the employment was "principally localized" in Alabama due to the withholding of state income taxes, emphasizing that extraterritorial income remains taxable under Alabama law. The cited North Dakota statute pertains only to the authority of its workforce-safety insurer and does not affect the case. The employment contract was signed in Minnesota, but the duties and the employee's death occurred in North Dakota, establishing a valid claim for workers’ compensation benefits under North Dakota law.