Dead woman's family cannot sue for motor vehicle injuries; workers compensation is exclusive remedy
Christy Kappel, as Personal Representative of her daughter's Estate, sued Jacob Maurer after his negligent driving resulted in Kappel's daughter's death. Kappel's daughter, Mary Ann Miller, accompanied Maurer, an Engineer co-worker at Trelleborg Automotive, to a customer's location to make adjustments to machinery. Maurer lost control of his car en route and crashed, causing Miller's death. His insurer argued that it did not owe anything to the family.
The Court dismissed Kappel's claim, holding that workers compensation was the "exclusive remedy" for Miller's death. Workers compensation does not allow for any recovery for the family's loss of society and companionship with the decedent, so Kappel appealed. Her attorneys argued that since workers compensation does not apply to protect employees on their way to and from work, it should not apply under these circumstances to eliminate Miller's family's rights. The Court of Appeals rejected this argument. It held that even though Maurer was driving his own car, Trelleborg was "furnishing Miller's transportation" and because Trelleborg would derive a "special benefit" from the customer visit, Miller was engaged in her employer's business at the time of her death.