CHRIS EDENFIELD, APPELLANT,
v.
B & I CONTRACTORS, INC., APPELLEE
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Edenfield appeals a summary judgment dismissing his wrongful termination claim based on a prior workers' compensation settlement. The court reverses, holding that a settlement of prior workers' compensation claims does not bar a subsequent wrongful termination action alleged to result from filing the original claim, and that factual disputes remain regarding the August 1991 termination.
A settlement and release of a matured workers' compensation claim does not bar a subsequent wrongful termination action based on the filing of that claim. Summary judgment was improperly granted because the record did not conclusively foreclose Edenfield's allegation of wrongful termination in August 1991. Evidence of pre-release incidents may be admissible if probative of the wrongful termination claim.
[1] A settlement and release of a workers' compensation claim does not bar a subsequent action for wrongful termination if the termination is alleged to be a result of the wo…
[2] A party moving for summary judgment bears the burden of demonstrating conclusively that the non-moving party cannot prevail.
Previewing 2 of 4 headnotes on this case. FLexlaw’s editorially structured points of law — every proposition, pinpointed — are reserved for members.
Join FLexlaw to unlock all legal intelligence“The settlement and release of the workers' compensation claim would not bar an action for subsequent wrongful termination alleged to be the result of the workers' compensation claim.”
Establishes the core holding that a prior workers' compensation settlement does not extinguish claims for subsequent wrongful termination based on the filing of that claim.
Previewing 1 of 3 key quotes on this case — the court’s exact language, pinpointed for members.
Join FLexlaw to unlock all legal intelligenceIn May 1991, Edenfield executed a release settling his workers' compensation claim with B & I Contractors. In August 1991, B & I terminated Edenfield'…
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BLUE, Judge.
Chris Edenfield appeals from a final summary judgment against him and in favor of B & I Contractors, Inc. He contends a factual dispute remains unresolved on his claim that he was wrongfully discharged because he filed a workers’ compensation claim. We agree that the final summary judgment was improperly granted and reverse. The issue of Edenfield’s wrongful termination from his employment was not factually foreclosed by the record before the trial court.
Edenfield filed a complaint alleging B & I terminated his employment in August 1991 in violation of section 440.205, Florida Statutes (1991).1 B & I answered, denied the allegations, and filed eight affirmative defenses. B & I’s defenses relied on a joint petition dated May 21, 1991, which released and settled Edenfield’s workers’ compensation claim. B & I also filed interrogatories requesting that Edenfield describe the incidents to support his allegations of demotion, reduction in pay, and general intimidation and harassment resulting from filing the workers’ compensation claim. Edenfield’s answers to the interrogatories listed multiple incidents occurring before the May 21, 1991, release.
B & I then filed a motion for partial summary judgment. Following the hearing on B & I’s motion, the trial court granted final summary judgment. The court ruled that the release entitled B & I to partial summary judgment because it had no responsibility for damages resulting from events occurring on or before the date of the workers’ compensation claim release. Eden-field concedes there is no error in that ruling. The trial court went on to hold, “... since no issues have been raised in the Plaintiffs Complaint nor proved to be in existence by virtue of the Plaintiffs Interrogatory responses after -the date of the release and Workers’ Compensation Order entered thereon, the Defendants are granted a Final Summary Judgment against the Plaintiff in this cause.”
The trial court properly ruled Eden-field was not entitled to damages for any incidents or claims which occurred prior to the date of the release. However, the trial court erred in granting final summary judgment on Edenfield’s alleged August 1991 wrongful termination. The settlement and release of the workers’ compensation claim would not bar an action for subsequent wrongful termination alleged to be the result of the workers’ compensation claim. See Sottile v. Gaines Construction Co., 281 So. 2d 558 (Fla. 3d DCA 1973) (release valid only to claims which had matured at the time of its execution), review denied, 289 So. 2d 737 (Fla.1974), receded from on other grounds, Brown v. Brown, 432 So. 2d 704 (Fla. 3d DCA 1983).
The burden is on the party moving for summary judgment to demonstrate conclusively that the non-moving party cannot prevail. Holland v. Verheul, 583 So. 2d 788 (Fla. 2d DCA 1991). The record before the trial court included only the complaint alleging wrongful termination, the answer denying the allegation with affirmative defenses, and answers to interrogatories. The record failed to demonstrate conclusively that Eden-field’s allegation of wrongful termination from employment in August 1991 was untrue.
Implicit in the trial court’s order is the finding that because Edenfield had released all claims for damages prior to May 21, 1991, he would not be entitled to adduce at trial any evidence of alleged intimidation or harassment which occurred prior to the date of the release. Further, without the benefit of such evidence, Edenfield would be unable to prove a wrongful termination. We disagree and hold that Edenfield would not be barred from presenting evidence of events occurring prior to the release date if probative of the wrongful termination issue.
We approve that portion of the court’s order which barred claims for damages arising prior to May 21, 1991; however, we reverse the final summary judgment because there remains a factual issue on the question of wrongful termination. We affirm in part, reverse in part and remand for further proceedings consistent with this opinion.
CAMPBELL, A.C.J., and PARKER, J., concur. . Section 440.205 provides that "[n]o employer shall discharge, threaten to discharge, intimidate, or coerce any employee by reason of such employee's valid claim for compensation or attempt to claim compensation under the Workers’ Compensation Law.”
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Rease v. Anheuser-Busch, Inc., 644 So. 2d 1383 (Fla. 1st DCA 1994)…Anheuser-Buseh’s state of mind in terminating Rease after 1987. The statute of limitations does not bar the introduction of evidence offered to prove a cause of action brought within the limitations period. See Edenfield v. B & I Contractors, Inc., 624 So. 2d 389 (Fla. 2d DCA 1993); Robbins v. City of Miami Beach, 613 So. 2d 580 (Fla. [*1388] 3d DCA 1993). As the court in Robbins stated, “[T]he fact that limiting statutes bar the bringing of a cause of action on stale facts does not, alone, render those same…
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Anderson v. TBA P'ship, Ltd., 733 So. 2d 1032 (Fla. 2d DCA 1998)…PER CURIAM. Affirmed. See Edenfield v. B & I Contractors, Inc., 624 So. 2d 389 (Fla. 2d DCA 1993). PATTERSON, A.C.J., and WHATLEY, J., concur. ALTENBERND, J., dissents with opinion.…
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Borque v. Trugreen, Inc., 389 F.3d 1354 (11th Cir. 2004)…t agreement was not binding. See Jacobsen v. Stores, 882 So. 2d 431, 433 (Fla. 1st DCA 2004). Neither party has done so here. The validity of using a general release has been confirmed by the Florida courts in Edenfield v. B&I Contractors, Inc., 624 So. 2d 389, 390 (Fla. 2d DCA 1993). Edenfield involved a situation somewhat analogous to the one at issue here. In Edenfield the court upheld a portion of a trial court’s order that granted summary judgment on a retaliatory discharge claim using a workers’ c…
Authorities Cited
- Holland v. Gustav Verheul and Elizabeth Verheul, 583 So. 2d 788 (Fla. 2d DCA 1991)
- Brown v. Brown, 432 So. 2d 704 (Fla. 3d DCA 1983)
- Sottile v. Gaines Constr. Co., 281 So. 2d 558 (Fla. 3d DCA 1973)
- Gaines Constr. Co. v. Sottile, 289 So. 2d 737 (Fla. 1974)