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Keywords

negligenceappealtrialduty of care

defendantappealtrial

Related Cases

Satterfield v. Breeding Insulation Co., 266 S.W.3d 347

Facts

Amanda Nicole Satterfield was diagnosed with mesothelioma, a cancer primarily caused by asbestos exposure, and filed a negligence suit against her father's employer, Alcoa, before her death. The estate claimed that Alcoa allowed the father to wear asbestos-contaminated work clothes home, which led to the daughter's prolonged exposure to asbestos fibers. Alcoa was aware of the dangers of asbestos and had failed to educate its employees about the risks associated with taking contaminated clothing home.

The estate alleged that the employer had negligently permitted her father to wear his asbestos-contaminated work clothes home from work, thereby regularly and repeatedly exposing her to asbestos fibers over an extended period of time.

Issue

Whether Alcoa owed a legal duty to Amanda Nicole Satterfield to prevent her from being exposed to asbestos fibers carried home on her father's work clothes.

The only issue on this appeal is whether the complaint of a woman who succumbed to mesothelioma should have been dismissed solely because the defendant did not have a duty to act reasonably to prevent her from being exposed repeatedly and regularly over an extended period of time to the asbestos fibers on her father's work clothes.

Rule

An employer has a duty to use reasonable care to prevent exposure to harmful substances not only to its employees but also to those who come into close regular contact with its employees' contaminated work clothes.

An employer has a duty to use reasonable care to prevent exposure to asbestos fibers not only to its employees, but also to those who came into close regular contact with its employees' contaminated work clothes over an extended period of time.

Analysis

The court determined that it was foreseeable that the employee's child would come into contact with the contaminated work clothes, and thus, Alcoa had a duty to prevent exposure to asbestos fibers. The court emphasized that the employer's failure to take reasonable precautions created an unreasonable risk of harm to the daughter, which justified the imposition of a duty.

We have determined that it does because, under the facts alleged in the complaint, the employer owed a duty to those who regularly and for extended periods of time came into close contact with the asbestos-contaminated work clothes of its employees to prevent them from being exposed to a foreseeable and unreasonable risk of harm.

Conclusion

The Supreme Court affirmed the Court of Appeals' decision, holding that Alcoa owed a duty of care to Amanda Nicole Satterfield and that the trial court erred in dismissing her complaint.

We have determined that the trial court erred by dismissing Ms. Satterfield's complaint and that the Court of Appeals properly reversed the trial court's dismissal of the complaint.

Who won?

The estate of Amanda Nicole Satterfield prevailed in the case because the court recognized that Alcoa had a duty to prevent foreseeable harm to individuals exposed to asbestos through its employees' contaminated clothing.

The Tennessee Court of Appeals filed an opinion reversing the dismissal of Ms. Satterfield's complaint after concluding that the trial court had erred by holding that Alcoa owed no duty to Ms. Satterfield under the facts alleged in the complaint.

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