Lefiell Manufacturing Company, Petitioner v. the Superior Court of Los Angeles County, Respondent; O’neil Watrous…

Summary

The court held that an injured employee's spouse may not pursue a loss-of-consortium claim against the employer when the employee's workplace injury qualifies for the statutory power-press exception to workers' compensation exclusivity. The exception permits the injured employee to seek tort damages in addition to workers' compensation benefits, but it does not remove the industrial injury from the workers' compensation system or authorize derivative claims by a spouse when the employee survives. The court therefore reversed the portion of the Court of Appeal's judgment concerning the spouse's claim and affirmed the remainder.