Fernando Rodriguez-Flores A/k/a Jose Edgardo Pizarro-Plaza v. U.S. Coatings, Inc.

Summary

The court held that the Longshore and Harbor Workers’ Compensation Act barred Rodriguez-Flores’s state-law fraud claim because the alleged misrepresentations concerned the denial or withholding of workers’ compensation benefits and did not allege the specific intent to injure required for the narrow intentional-tort exception. It further held that the Act did not preempt his Alabama retaliatory-discharge claim because both federal and state law prohibit retaliatory discharge, and the differing remedies did not create a conflict with federal objectives. Justice Murdock, concurring in the result, relied on Rodriguez-Flores’s failure to challenge the relevant precedents or argue that his fraud claim avoided preemption.