Justia Alabama Supreme Court Opinion Summaries

Adam P. Harrington was injured on February 15, 2018, while using a swing rope to transfer from an offshore gas platform to a transport vessel. Harrington, employed by Skelton's Fire Equipment, Inc., was inspecting fire-suppression equipment on Exxon's platform. Due to rough seas, Harrington mistimed his swing and fractured his leg. His medical expenses were covered by Skelton's workers' compensation insurer.Harrington sued Exxon for maritime negligence and wantonness in the Mobile Circuit Court. Before trial, the court granted Harrington's motion to exclude evidence of his medical expenses being paid by the workers' compensation insurer. The jury found Exxon liable for $1,500,000 in damages, reduced by 10% for Harrington's fault, resulting in a $1,350,000 judgment. Exxon's postjudgment motion for a new trial, arguing the exclusion of evidence was erroneous, was denied.The Supreme Court of Alabama reviewed the case. Exxon argued that the trial court erred by excluding evidence of the workers' compensation payments, citing Alabama Code § 12-21-45. However, the court held that substantive maritime law, which includes the collateral-source rule, applied. This rule prevents the reduction of damages by amounts received from third parties, such as insurance. The court found that applying § 12-21-45 would conflict with maritime law.Exxon also claimed that Harrington's expert witness opened the door to admitting evidence of the workers' compensation payments. The court disagreed, stating that the expert's testimony did not justify introducing such evidence under the doctrine of curative admissibility.The Supreme Court of Alabama affirmed the trial court's judgment in favor of Harrington and dismissed Harrington's conditional cross-appeal as moot. View "Exxon Mobil Corporation v. Harrington" on Justia Law