The Legislature finds that actions filed on behalf of injured employees against officers, directors, agents, servants, or employees of the same employer seeking to recover damages in excess of amounts received or receivable from the employer under the workers’ compensation statutes of this state and predicated upon claimed negligent or wanton conduct resulting in injuries arising out of and in the course of employment are contrary to the intent of the Legislature in adopting a comprehensive workers’ compensation scheme and are producing a debilitating and adverse effect upon efforts to retain existing, and to attract new industry to this state. Specifically, the existence of such causes of action places this state at a serious disadvantage in comparison to the existing laws of other states with whom this state competes in seeking to attract and retain industrial operations which would provide better job opportunities and increased employment for people in this state. The existence of such causes of action, and the consequent litigation resulting therefrom, results in substantial costs and expenses to employers which, as a practical matter, must either procure additional liability insurance coverage for supervisory and management employees or fund the costs of defense, judgment or settlement from their own resources in order to retain competent and reliable personnel. The existence of such causes of action has a disruptive effect upon the relationship among employees and supervisory and management personnel. There is a total absence of any reliable evidence that the availability of such causes of action has resulted in any reduction of the number or severity of on-the-job accidents or of any substantial improvement on providing safe working conditions and work practices. The intent of the Legislature is to provide complete immunity to employers and limited immunity to officers, directors, agents, servants, or employees of the same employer and to the workers’ compensation insurance carrier and compensation service companies of the employer or any officer, director, agent, servant, or employee of such carrier or company and to labor unions and to any official or representative thereof, from civil liability for all causes of action except those based on willful conduct and such immunity is an essential aspect of the workers’ compensation scheme. The Legislature hereby expressly reaffirms its intent, as set forth in Section 25-5-53, as amended herein, and Sections 25-5-144 and 25-5-194, regarding the exclusivity of the rights and remedies of an injured employee, except as provided for herein.
(Acts 1984, 2nd Ex. Sess., No. 85-41, p. 44, §1.)
Notes of Decisions
Cited in
16
cases (
2 in the last 5 years), 1988–2026 · leading case:
Reed v. Brunson, 527 So. 2d 102 (Ala. 1988).
Reed v. Brunson, 527 So. 2d 102 (Ala. 1988).
· cites it 4× “" § 25-5-14. In Section 3 of the Act (§ 25-5-11), the legislature limits an employee's claim for damages, where workmen's compensation benefits are payable, in actions against "a workers' compensation insurance carrier of the employer or any person, firm, association, trust,…”
Iddings v. Mee-Lee, 919 P.2d 263 (Haw. 1996).
· cites it 2× “…of on-the-job accidents or of any substantial improvement on providing safe working conditions and work practices. Ala.Code § 25-5-14 (1992).”
State Farm Mut. Auto. Ins. Co. v. Carlton, 867 So. 2d 320 (Ala. Civ. App. 2001).
· cites it 2× “The portions of § 25-5-14 emphasized here indicate the legislature's *327 intent to provide complete immunity to employers, and limited immunity to coemployees and other entities connected with employers because, according to the legislature, "such immunity is an essential…”
Norman v. S. Guar. Ins., 191 F. Supp. 2d 1321 (M.D. Ala. 2002).
· cites it 2× “1975 Ala.Code § 25-5-14. 11 Therefore, all *1337 of Norman’s negligence-based claims are due to be dismissed; Alabama law itself does not allow them to proceed.”
Brunson v. Lucas, 5 So. 3d 1274 (Ala. Civ. App. 2008).
· cites it 5× “” Ala.Code 1975, § 25-5-14. Sections 25-5-11 and 25-5-53 also express the intent to extend immunity to co-employees except in cases involving willful conduct on the part of the co-employee.”
Cason v. Miller, 202 So. 3d 669 (Ala. 2016).
“Further, § 25-5-14, Ala.Code 1975, provides: “The intent of the Legislature is to provide complete immunity to employers *671 and limited immunity to officers, directors, agents, servants, or employees of the same employer .”
Harris v. Beaulieu Grp., LLC, 394 F. Supp. 2d 1348 (M.D. Ala. 2005).
· cites it 3× “, supra, and Ala.Code § 25-5-14 (1975)). As further observed by Progress Rail Services, quoting again from McCartney, a 1992 amendment to a different provision of the Act, i.”
Ex Parte Newton, 895 So. 2d 851 (Ala. 2004).
“" § 25-5-14 (emphasis added). "Willful conduct," for the purposes of co-employee liability, is defined by § 25-5-11(c) to include, in pertinent part: "(1) A purpose or intent or design to injure another; and if a person, with knowledge of the danger or peril to another,…”
Beard v. Mobile Press Register, Inc., 908 So. 2d 932 (Ala. Civ. App. 2004).
“In addition to §§ 25-5-52 and 25-5-53, § 25-5-14, which was enacted in 1985, provides further support for the principle of exclusivity.”
Britt v. Shelby Cnty. Health Care Auth., 850 So. 2d 322 (Ala. Civ. App. 2001).
· cites it 2× “" § 25-5-14. The Legislature added: "[S]uch immunity is an essential aspect of the workers' compensation scheme.”
Coates v. Guthrie, 707 So. 2d 204 (Ala. 1997).
· cites it 2× “The legislative intent regarding co-employee actions is set out in § 25-5-14: “The legislature finds that actions filed on behalf of injured employees against .”
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