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Johnson v. Bechtel Associates Professional Corp.

Citations: 230 U.S. App. D.C. 297; 717 F.2d 574Docket: Nos. 82-2017, 82-1784, 82-1809, 82-1813, 82-1899, 82-2062, 82-2063, 82-2148, 82-2374, 82-2458, 82-2459, 82-2525, 82-2529, 82-2530, 82-2531 and 83-1003

Court: Court of Appeals for the D.C. Circuit; August 19, 1983; Federal Appellate Court

Narrative Opinion Summary

The consolidated appeals involve negligence claims by employees of contractors working on the WMATA subway project. The claims arise from respiratory injuries due to silica dust and a construction accident. After receiving workers' compensation, the employees filed third-party negligence claims against WMATA and Bechtel, the project's safety engineer. The district court granted summary judgment for WMATA and Bechtel, leading to appeals on four issues. The court upheld Bechtel's agency status under the WMATA Compact, making WMATA liable for Bechtel’s torts, and reversed WMATA’s summary judgment, denying it immunity under section 905(a) of the Longshoremen’s Act. The case was remanded for further factual development regarding the inclusion of WMATA as a defendant under Rule 15(c). The court also affirmed the dismissal of a negligence suit filed beyond the statutory limit set by section 33(b) of the Longshoremen’s Act. The rulings underscore the statutory interpretation of agency and employer immunity, highlighting the procedural requirements for amending pleadings and maintaining third-party claims. The outcome reversed WMATA's immunity and upheld its liability, necessitating further proceedings to resolve remaining factual disputes.

Legal Issues Addressed

Agency and Liability under WMATA Compact Section 80

Application: Bechtel was deemed an agent of WMATA, which is exclusively liable for Bechtel’s torts due to their contractual relationship and WMATA's control over Bechtel's operations.

Reasoning: Bechtel was deemed an agent of WMATA, which is exclusively liable for Bechtel’s torts under section 80 of the WMATA Compact, affirming the summary judgment for Bechtel.

Amendment of Pleadings under Federal Rule of Civil Procedure 15(c)

Application: The court remanded the case for further factual development regarding the addition of WMATA as a defendant, examining whether the requirements of Rule 15(c) were satisfied.

Reasoning: A remand is necessary to develop a complete factual record regarding WMATA's addition as a defendant under Fed. R.Civ. P. 15(c).

Employer Immunity under Longshoremen’s Act Section 905(a)

Application: WMATA does not receive employer immunity under section 905(a) despite voluntarily providing workers' compensation insurance, as it was not legally required to do so.

Reasoning: WMATA is not entitled to employer immunity under section 905(a) of the Longshoremen’s Act, leading to the reversal of the summary judgment in its favor.

Limitations on Third-Party Actions under Longshoremen’s Act Section 33(b)

Application: The court affirmed the dismissal of a third-party negligence action filed outside the six-month period after accepting a compensation award, as required by the statute.

Reasoning: Under section 33(b) of the Longshoremen’s Act, an injured employee cannot file a third-party negligence action post the six-month period after accepting a compensation award, resulting in the affirmation of the dismissal of the Williams case.