SSC Selma Operating Company v. Fikes

Supreme Court of Alabama

Dallas County | 238 So. 3d 635 | May 19, 2017

Court Reverses Trial Decision, Mandating Arbitration in Retaliatory-Discharge Claim

In 2016, Fikes initiated a lawsuit against her employers, asserting a claim for workers' compensation benefits due to a work-related injury she sustained in 2013. Additionally, Fikes contended that her employers wrongfully terminated her employment in 2014 in retaliation for filing the compensation claim. In response, the companies sought to push the retaliatory-discharge claim to arbitration based on their Employment Dispute Resolution (EDR) program, to which Fikes had consented. However, Fikes argued that her retaliatory-discharge claim wasn't under the purview of the EDR program. In October 2016, the trial court declined the companies' motion for arbitration. The companies appealed this decision.

Central to the dispute was whether Fikes's retaliatory-discharge claim was covered by the EDR program. The program's agreement stipulated that most workplace disagreements, including those around legal rights like freedom from retaliation, were to be settled through arbitration. Nonetheless, it specifically excluded disputes related to workers' compensation. Fikes maintained that her retaliatory-discharge claim was intrinsically linked to her workers' compensation claim, hence falling outside the EDR program's scope. Contrarily, the companies argued that the two claims were distinct, with the former being a tort action.

Citing precedent, the appellate court agreed with the companies. It recognized the distinction between claims arising purely from workers' compensation acts and retaliatory-discharge claims, which are rooted in general tort law. The court determined that Fikes's retaliatory-discharge claim was apt for arbitration under the EDR program. As a result, it reversed the trial court's order, compelling arbitration for Fikes's claim.