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Hughes Wood Products5/25/2000
On Petition for Review from the Court of Appeals for the Ninth District of Texas
Argued November 17, 1999
Justice O'Neill delivered the opinion of the Court.
This case presents a choice of law question. Plaintiff was injured while performing logging operations in Louisiana and filed a personal injury suit against the defendants in Texas. Defendants moved for summary judgment contending that, as a matter of law, the Louisiana Workers' Compensation Act's exclusive-remedy provision barred plaintiff's Texas action. The trial court granted summary judgment for the defendants. The court of appeals reversed, holding that Texas law applied under the "most significant relationship" test found in sections 6 and 145 of the Restatement. See 979 S.W.2d 84, 86-87; Restatement (Second) of Conflict of Laws §§ 6, 145 (1971). Defendants contend that the appeals court erred in failing to apply section 184 of the Restatement, which precludes tort recovery if the defendant is immune from liability under another state's workers' compensation statute. See Restatement (Second) of Conflict of Laws § 184 (1971).
We hold that the court of appeals erred in its conflicts analysis by failing to consider which state has the most significant relationship to the issue to be resolved, that is the exclusive-remedy issue. Nevertheless, the defendants failed to show that they are immune from liability under Louisiana's workers' compensation law and thus failed to prove that they are entitled to Restatement section 184's protections. Accordingly, we affirm the court of appeals' judgment reversing the trial court's summary judgment and remanding the case to the trial court. See 979 S.W.2d at 88. We leave open the question of which state's law the trial court should apply to the particular substantive issues to be resolved below.
I. Background
Plaintiff, Mack Wagner, lives in Newton, Texas, and was recruited in Texas to work as a logger. As a logger, he drove equipment owned by Bailey Wagner and cut timber owned by Hughes Wood Products, Inc. in Louisiana. After the timber was cut, at least some of it was hauled to Hughes's mill in Texas. Hughes is a Texas corporation, and its home office and principal place of business are in Newton, Texas. Bailey Wagner also lives in Texas. While plaintiff was working as a logger in Louisiana, a tree fell and crushed his foot. He received emergency treatment for his injury in Louisiana and then returned to Texas, where the rest of his medical treatment took place.
When plaintiff was injured, Hughes had Louisiana workers' compensation coverage, but the company did not file a report with the Louisiana office of workers' compensation administration reporting the injury. Hughes did make payments to the plaintiff after his injury, but it is not clear from the record what these payments were for or how many were made. Hughes did not have Texas workers' compensation insurance when the plaintiff was injured. Bailey Wagner had neither Texas nor Louisiana workers' compensation insurance.
Plaintiff filed this personal injury suit against the defendants, Hughes and Bailey Wagner, in Texas. Defendants filed a joint motion for summary judgment arguing that, under Restatement section 184, Louisiana law controls and plaintiff's suit was barred by the Louisiana Workers' Compensation Act's exclusive-remedy provision. Alternatively, they argued that even under Texas law, workers' compensation benefits were plaintiff's exclusive remedy because he was "an employee covered by workers' compensation insurance," Tex. Lab. Code § 408.001(a), albeit in Louisiana. The trial court granted defendants' motion for summary judgment without specif
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